Privacy Policy

Latest update: 01/03/2023

This Privacy Policy applies to any information you provide to Pemo Payments Service Provider L.L.C., via the website www.pemo.io, the mobile application maintained and operated by us (together the “Platform” and the service provided on this Platform shall be referred to as the “Service”).

WHEN YOU USE THE PLATFORM, OR OTHERWISE PROVIDE ANY INFORMATION TO US, YOU AGREE TO THIS PRIVACY POLICY, INCLUDING THE MANNER IN WHICH WE USE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE SUBSEQUENTLY MAKE TO THIS PRIVACY POLICY, YOU MUST IMMEDIATELY STOP USING THE PLATFORM OR OTHERWISE PROVIDING ANY INFORMATION TO US.

This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller

The Platform is owned and operated by Pemo Payments Service Provider L.L.C., a private limited company incorporated in the United Arab Emirates with registered number 1081638 and registered address at office no. 09-124, 8th & 9th Floor, The Office 4, We Work, One Central, Dubai World Trade Centre, Dubai, United Arab Emirates (referred to as “we”, “our”, “us” and “Pemo”).

We are committed to protecting your personal information and other data provided to us via the Platform. 

Please read this Privacy Policy carefully as it contains important information about the use of any information you provide to us. This Privacy Policy explains what information we collect about you, how we use your information and sets out the circumstances where it could be shared with third parties.

Because of the financial nature of our business, our products and services are not designed to appeal to or to be sold to persons under the age of 18. Therefore, we do not knowingly attempt to solicit or receive any information from persons under the age of 18.

We have appointed a Data Protection Officer in our business who can deal with any data protection related matters. You can contact our Data Protection Officer by email at info@pemo.io

Types of Data collected

Personal Data is any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Among the types of Personal Data that this Platform collects, by itself or through third parties, there are: 

• Identity Data, such as your first name and last name.
• Contact Data, such as your email address, telephone/fax number, address and other contact details.
• Payment Data, such as credit/debit card and other billing information, including cardholder transaction data, card numbers, expiration dates, billing addresses and CVV codes;
• Enquiry Data, such as your enquiries.
• Correspondence Data, such as any correspondence between us and you about an enquiry.
• Technical Data such as information collected automatically through this Platform (or third-party services employed in this Platform), which can include: the IP addresses or domain names of your computer, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by you, the various time details per visit (e.g., the time spent on each page within the Platform) and the details about the path followed within the Platform with special reference to the sequence of pages visited, and other parameters about the device operating system and/or your IT environment.
• Marketing and Communications Data, such as your communications preferences and how you have responded to our marketing communications.
• Tracking Data, such as information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and other digital identifiers.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 

Aggregated Data may be derived from your Personal Data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Technical Data to calculate the percentage of users accessing a specific feature, or we may aggregate your Marketing and Communications Data to calculate the percentage of recipients who open our email newsletter. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not usually collect any special categories of Personal Data about you, but you may choose to disclose this data to us. Special categories of Personal Data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Unless we are required to do so to comply with a legal obligation, or as an integral part of providing the Service to you, we do not usually collect any Personal Data about you relating to criminal convictions or offences.

We may use the Data we collect to personalise your experience of the Service, to help you to maintain a logged-in session, and to help us select services or materials for inclusion in the Service which may be of interest to you. We may, from time to time, use your Personal Data to send you important notifications, updates and information regarding the Service. If you do not want to receive communications regarding the Service, you must cease to use the Service and ask us to delete your account. You can request this by contacting us by email at info@pemo.io.

Where you provide Personal Data to us, you represent and warrant to us that (i) the relevant individual has been notified of the purposes for which the data will be collected, processed, used and disclosed; and (ii) you have obtained the relevant individual's consent for the collection, processing, use and disclosure of such Personal Data by Pemo and have been duly authorized by the relevant individual to provide the Personal Data to us. You must promptly inform us upon you becoming aware of the withdrawal by the relevant individual of his/her consent to the collection, processing, use and/or disclosure by us of the Personal Data provided to us. The withdrawal of such consent may affect the Service which we are able to provide to you.

How we collect the Data

We collect information through one or more of the following ways:

• when you download and register to use the Platform;
• when you search for the Platform in the app stores;
• when you contact us by email and other communications;
• when you report a problem with the Platform; and
• through “cookies” (small text files placed by us on you device(s)), and other similar technological means. 

Methods of processing

We take appropriate security measures to prevent unauthorized access, disclosure, copying, modification, or unauthorized destruction of the Data.

We implement and maintain appropriate technical, security and organisational measures in relation to the processing of your Personal Data so that the processing will meet the requirements of applicable data protection laws and ensure the protection of your rights.

If you provide us with your credit card information, the information is encrypted. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated below. 

In some cases, the Data may also be made accessible by us to certain types of persons in charge, involved with the operation of this Platform (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed by us, if necessary, as data processors . The updated list of these parties may be requested at any time.

Legal basis of processing

We may process your Personal Data if one of the following applies:

• You have given your consent for one or more specific purposes. 
• provision of Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which we are subject;
• processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

We may also use Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including those outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. 

To ensure you are kept up to date with our products, we use Personal Data for marketing purposes, and may send you emails to update you on the latest offers and events. We may also show you online media communications through external social media platforms and external digital advertisers.

You have the right to opt out of receiving promotional emails at any time.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of our legitimate interests shall be retained as long as needed to fulfill such purposes. We may find specific information regarding the legitimate interests pursued by us within the relevant sections of this document or by contacting us.

We may be allowed to retain Personal Data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

We may use your Personal Data for our business purposes, such as:

a) to develop, improve and provide payment facilities, products or services (whether made available by us or through us), including but not limited to:

i. executing payments, commercial or other transactions and requests, including processing, settlement, clearing or reporting on these transactions;

ii. carrying out research, planning and statistical analysis; and

iii. analytics for the purposes of developing or improving our products, services, security, service quality, advertising or customisation strategies;

b) assessing and processing Platforms, instructions or requests from you;

c) communicating with you, including providing you with updates on changes to products, services and payment facilities (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such products, services and payments facilities and their terms and conditions;

d) managing our infrastructure, business operations and complying with internal policies and procedures;

e) responding to queries, complaints or feedback;

f) addressing or investigating any complaints, claims or disputes;

g) verifying your identity for the purposes of providing payments facilities, products or services;

h) conducting credit checks, screenings or due diligence checks as may be required under applicable law, regulation or directive;

i) complying with all applicable laws, regulations, rules, directives, orders, instructions, guidance and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;

j) monitoring products and services provided by or made available through us;

k) complying with obligations and requirements imposed by us from time to time by any credit bureau or credit information sharing services of which we are a member or subscriber;

l) creating and maintaining credit and risk related models;

m) financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;

n) enabling any actual or proposed assignee or transferee, participant or sub-participant of our rights or obligations to evaluate any proposed transaction;

o) in connection with any sale, acquisition, merger or restructuring of our business;

p) for the marketing of products and services ancillary or related to the use of the Platform;

q) to detect, prevent and investigate fraud;

r) enforcing obligations owed to us;

s) in connection with performance of our duties and obligations when seeking consultancy or professional advice, including legal advice; and/or

t) administering benefits or entitlements in connection with our relationship with you or arising from your participation in events, campaigns, or marketing promotions by us or in conjunction with our partners. This will include the administration of loyalty, rewards programmes, lucky draws, and/or sending gifts and awards.

Where necessary to fulfil our obligations in the course of or in connection with our provision of the goods and services requested by you, or to fulfil our business purposes stated above, we may from time to time disclose Personal Data to third parties such as the following:

a) regulatory authorities, courts, dispute resolution tribunals, and governmental agencies;

b) any agent, affiliate, business partner, supplier, vendor and sub-contractor which provides products and services to us in connection with the Platform and Services (for example, vendors who we engage to perform fraud detection and monitoring, payment intermediaries who we work with to provide payments services, and card issuers who we work with to offer you debit cards);

c) any actual or proposed assignee of us or transferee of our rights in respect of all or any part of our assets, properties or business;

d) any credit bureau as well as the members of such credit bureau (for example, banks, financial intermediaries, payment intermediaries, card network members and insurers);

e) financial institutions and other business partners with whom we jointly offers or develops the Service (but they may not use your Personal Data to independently market their own products or services to you unless you consent that they can do so); and

f) analytics and search engine providers that assist us in the improvement and optimisation of the Platform; and

g) anyone we consider necessary in order to provide our Service.

SOME PARTIES THAT PROCESS OR STORE PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY STATEMENT MAY BE LOCATED IN JURISDICTIONS OUTSIDE YOUR COUNTRY OF RESIDENCE OR OUR COUNTRY OF INCORPORATION. THEREFORE, BY GIVING YOUR CONSENT, YOU UNDERSTAND AND UNAMBIGUOUSLY AGREE THAT YOUR INFORMATION MAY BE PROCESSED AND STORED IN THESE JURISDICTIONS AND THAT DIFFERENT PRIVACY LAWS MAY APPLY IN THESE COUNTRIES WHICH MAY NOT ENSURE THE SAME LEVEL OF DATA PROTECTION AS GRANTED IN YOUR COUNTRY OF RESIDENCE. 

When we use third parties to assist us in collecting and/or processing your Personal Data, we typically request that they comply with this Privacy Policy and any other appropriate confidentiality and security measures. However, we make no representation or warranty that such third parties will comply with any such request.

Your rights 

You may exercise certain rights regarding your Data.

In particular, you have the right to do the following:

• Withdraw your consent at any time. You have the right to withdraw consent where you have previously given their consent to the processing of your Personal Data.
• Object to processing of your Data. You have the right to object to the processing of your Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access your Data. You have the right to learn if Data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. You have the right to verify the accuracy of your Data and ask for it to be updated or corrected.
• Restrict the processing of your Data. You have the right, under certain circumstances, to restrict the processing of their Data. In this case, you will not process their Data for any purpose other than storing it.
• Have your Personal Data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of their Data from us.
• Receive your Data and have it transferred to another controller. You have the right to receive your Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
• Lodge a complaint. You have the right to bring a claim before your competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to their particular situation to justify the objection.

You must know that, however, should your Personal Data be processed for direct marketing purposes, youcan object to that processing at any time without providing any justification. To learn, whether weare processing Personal Data for direct marketing purposes,   please see the relevant sections of this document. 

How to exercise these rights

Any requests to exercise yourrights can be directed to us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month.

Additional information about Data collection and processing

Marketing Information. 

With your consent, we will keep your name, address and contact details (including telephone numbers and email addresses) in our databases and may from time to time use that information to make you aware of our related products and services as well as updates on developments in our industry sector generally which may be of interest to you. We may contact you in writing, by telephone or email for this. If permitted by applicable law, we may share such information with our event sponsors and/or partners for their own commercial purposes without your consent. If at any time you decide that you do not want your contact details used or shared for these purposes, where applicable, you may object or revoke your consent for receiving marketing communications by following the instructions in the relevant marketing communication (e.g., clicking on the “Unsubscribe” button), by contacting us.

Legal action

Your Personal Data may be used for legal purposes by us in Court or in the stages leading to possible legal action arising from improper use of this Platform or the related Services.
You declare to be aware that we may be required to reveal Personal Data upon request of public authorities.

Additional information about your Personal Data

In addition to the information contained in this Privacy Policy, this Platform may provide you with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Platform and any third-party services may collect files that record interaction with this Platform (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from us at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Platform does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

We reserve the right to make changes to this Privacy Policy at any time by notifying youon this page and possibly within this Platform and/or - as far as technically and legally feasible - sending a notice to you via any contact information available to usIt is strongly recommended to check this page often, referring to the date of the last modification listed at the top. 

Should the changes affect processing activities performed on the basis of your consent, we shall collect new consent from you, where required.

Contact 

If you experience any technical problems during your interaction with the Platform, please contact us here: info@pemo.io

Queries, concerns or complaints regarding your privacy or this Privacy Policy: If you have queries regarding this Privacy Policy please contact us by sending an email to info@pemo.io

Cookies Policy

Like most websites and apps, we use cookies. By using our Platform you agree to our use of cookies.

What are Cookies?

A cookie is a small text file placed on your computer or mobile device when you visit a website or use a mobile application. Cookies collect information about users and their visit to the website or mobile application, such as their Internet protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another website) and how they navigate within the website or mobile application. 

Why do we use Cookies?

We use cookies and other technologies to facilitate your internet sessions and use of our Platform, offer you products and/or services according to your preferred settings, track use of our Platform and to compile statistics about activities carried out on our Platform. 

Storage and Types of Cookies

Cookies can be stored on your device anywhere from a few minutes through to [two years].

We use a few different types of cookies:

• Session cookies
• Persistent cookies
• Third-party cookies

We never use cookies to store your payment or banking details.

Session & Persistent Cookies

Session and persistent cookies track what you're doing during a specific visit. We use session cookies to improve our Platform, to give you a better experience. Session cookies let us see where you spend your tim and work out which areas are most effective. We use persistent cookies to recognise you when you come back. When we spot that it's you, we're able to show you the things that we think you may like.

Third-Party Cookies

Third-party cookies show you ads for things we think you'll be interested in. For example, if you visit www.pemo.io and look at information about a particular product, we may use cookies to show you ads about that product because we think it's something you may be interested in.

We also use third party cookies to find out if the ads we run encourage more people to visit our Platform. Third-party cookies work by sharing your browser identification with a third party, so they can show you ads on their sites and apps. These cookies can be session specific or persistent.

Turning off Cookies

If you wish to deny the use and saving of cookies from the Platform on to your computers and/or other electronic devices, you should take the necessary steps within your internet browsers’ security settings to block all cookies from the Platform. 

You can choose to delete the cookies at any time. However, do note that when you enable blocking of cookies, certain features and functions may be limited in your use of our Platform.

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