Privacy Policy

1. About Xpence

 

Xpence Global Holdings Ltd.  (Xpence), is a limited liability company incorporated under the laws of

Abu Dhabi Global Market, with commercial registration number 000002192 and with its registered head office address at DD-15-134-004 – 007, Level 15, WeWork Hub71, Al Khatem Tower, Abu Dhabi Global Market Square, Al Maryah Island, Abu Dhabi, United Arab Emirates. ("Xpence").

You can contact us via the support button in the application or email us at info@xpence.co

 

2. Our Approach to Your Data

 

At Xpence, we recognise the importance of protecting your data. Our mission is to empower entrepreneurs to successfully grow and scale their businesses, and provide better access to Financial Services. This includes taking our responsibilities towards your data seriously. We will always use your data in a way that is legal, complies with the regulations under which we are authrosied to operated, that takes care of your privacy and ensures that Xpence works for you. We will never use your data in a way that could harm you. If you have any concern about your data or how it is used, please email us at info@xpence.co, we take all feedback, suggestions and complaints seriously.

 

3. The Privacy Policy

 

This Privacy Policy, together with our Terms and Conditions, and Fees and Charges, represent the legal Agreement with you, your Users and Xpence. The Terms and Conditions and Fees and Charges are available in the Xpence app, or can be provided to you by emailing info@xpence.co

 

The Privacy Policy outlines our policies and procedures on the collection, use and disclosure of Your information when You use Xpence Products and Services and tells You about Your privacy rights and how the law protects You.

 

We use Your Personal data to provide and improve our Products and Services. By applying to become a customer of Xpence and by using Xpence Products and Services, You agree to the collection and use of information in accordance with this Privacy Policy.

 

4. Collecting and Using Your Personal Data

 

Information that you give to us when you apply to become an Xpence customer, or though your use of our Products and Services, use in-app chat or email, speak to us on the phone or engage in promotions, reward schemes and other communications will be used and retained to allow Xpence to provide you with its Products and Services.

 

 

4.1 Data Collected

 

While using Our Service, We will ask You to provide Us with certain information including, but is not limited to:

 

  • Your first name and last name

  • Your e-mail address

  • Your phone number and details of your mobile device

  • Your home address

  • Your date of birth

  • Your residency and visa information

  • Your national identity documents and passport

  • A selfie that you take when you set up your relationship with Xpence, or your photo if you upload one

  • Any other demographic information you chose to share via application process or user surveys

  • Your log in and registration information and settings you chose in the app (including your user name and password)

  • Your company information and documents that you provide

  • Your bank account details including your account number and IBAN

  • Your location

  • Details which you give us which we pass to partners when you let us know that that you are interested in their services

  • If you contact us, we may keep a record of that correspondence

  • Any surveys or feedback sessions that you participate in

  • Public details from any social medial profiles that you provide to us

  • Public information from any websites that you provide to us

  • Details about top-ups into your account, payments to and from your account, and transfers you make between your account and other accounts including payment reason, and beneficiaries’ details

  • Details about how and when you use Xpence services

  • Details of any marketing information that we have sent to you

  • Information we collect from your device

    • The mobile network, operating system and browser information

    • The type of device that you use and unique identifier

    • IP address

    • Your location

    • Your phone contacts if you give Xpence access to these

    • Your photos if you give Xpence access to these

    • Information on your usage of the app

  • Information from external sources

    • Data provided by third parties to help us fulfil our regulatory duties with respect to financial crime management including fraud, anti-money laundering and counter terrorist financing.

  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

 

 

4.2 Tracking Technologies and Cookies

 

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service.

 

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.

 

We use both session and persistent Cookies for the purposes set out below:

 

Necessary / Essential Cookies

 

Type: Session Cookies Administered by: Us

 

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

 

Cookies Policy / Notice Acceptance Cookies

 

Type: Persistent

 

Cookies Administered by: Us

 

Purpose: These Cookies identify if users have accepted the use of cookies on the Website. Functionality Cookies

 

Type: Persistent Cookies

Administered by: Us

 

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

 

4.3 Use of Your Personal Data

 

Xpence may use Personal Data for the following purposes:

 

  • To provide and maintain our Service, including to monitor the usage of our Service.

  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

  • For a contract we have with your or to enter into a contract with you. We use your data to:

  • Consider your application including KYC, customer due diligence and security checks

  • Provide the products, items or services You have purchased or of any other contract with Us through the Service in line with our Terms and Conditions

  • To process your transactions

  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

  • To manage Your requests: To attend and manage Your requests to Us. We may share your personal information in the following situations:

 

With Service Providers: We may share Your personal information with Service Providers to monitor and analyse the use of our Service, to show advertisements to You to help support and maintain Our Service, to contact You, to advertise on third party websites to You after You visited our Service or for payment processing.

 

For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.

 

With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

 

With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

 

With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see You name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

 

4.4 Retention of Your Personal Data

 

We keep most of your data as long as you are using Xpence products and services, and for 7 years after that to comply with the law and if we face a legal challenge. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer if we need to (that is in our legitimate interest) and/or the law says we have to.

 
4.5 Where We Store Your Personal Data

 

The data that we collect from you may be transferred to, and stored at, a destination determined by us. It may also be processed by staff who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your request and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

 

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or mobile application, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

 

4.6 Transfer of Your Personal Data

 

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to and maintained on computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

 

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

 

5. Disclosure of Your Personal Data 

 

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

 

5.1 Law enforcement

 

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

 

5.2 Other legal requirements

 

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

 

  • Comply with a legal obligation

  • Protect and defend the rights or property of the Company

  • Prevent or investigate possible wrongdoing in connection with the Service

  • Protect the personal safety of Users of the Service or the public

  • Protect against legal liability

 

6. Security of Your Personal Data

 

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

 

7. Links to Other Websites

 

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

 

8. Changes to this Privacy Policy

 

We may update our Privacy Policy from time to time. To make sure You are aware of any changes, please review this policy periodically. Changes to this Privacy Policy are effective when they are posted on this page.

 

9. Contact Us

 

If you have any questions about this Privacy Policy, You can contact us by email at info@xpence.co

Xpence logo

Office 160

DIFC Innovation Hub

Gate Avenue

Dubai International Financial Centre

Dubai

United Arab Emirates

  • LinkedIn
  • Instagram
  • Facebook
  • Twitter
Visa logo

Xpence is a member of the  Visa Fintech Fast Track Programme.

Microsoft for Startups Logo
PCI DSS Logo

Xpence Ltd. is an incorporated company pursuant to Abu Dhabi Global Market Companies Regulations 2015 and is taken to be incorporated in Abu Dhabi Global Market.

ADGM FSRA has granted Xpence a Financial Services Permission (FSP # 180031)

Xpence Ltd (‘Xpence’) is regulated by the Abu Dhabi Global Market Financial Services Regulatory Authority (‘FSRA’) solely for the purpose of developing and testing innovative financial technology services within the Regulatory Laboratory (‘RegLab’). Xpence is only permitted to test its financial technology services with clients who have expressly given their consent in writing to participate, and acknowledged the risks of participating in the test. The test is subject to a maximum period of two years within the RegLab. At the end of the test period, Xpence will cease operations unless it receives the relevant approvals from the FSRA to continue operations outside the confines of the RegLab. Xpence’s clients may have limited recourse in the event of a failure or termination of the firm’s services.

The Central Bank of Bahrain has confirmed that "Xpence Ltd." is authorised to participate in the Fintech Regulatory Sandbox in the Kingdom of Bahrain and is henceforth granted authorisation to operate as a "Sandbox Ancillary Service Provider" for a limited period.