Incodi

Introduction

INCODI FinTech Ltd ("the Company," "INCODI"), incorporated as Private Company under the Companies Law, DIFC Law No. 5 of 2018 (the 'Companies Law') on July 20, 2023, with registered number 7159, is operating at Gate Village, Building 10, Floor: 7, DIFC, Dubai United Arab Emirates.

At INCODI, safeguarding your privacy and protecting your personal data are paramount to our operations as a leading technology services provider. In today's digital landscape, trust is built on transparency and a steadfast commitment to data protection. This Privacy Policy serves as a comprehensive guide, detailing the types of personal information we collect from you, the methods by which we gather and utilize this data, the robust security measures we implement for its storage and protection, and the clear avenues available to you for exercising your data protection rights. Our aim is to ensure that you are fully informed and confident in how your information is handled when you engage with our services and interact with the Company.

1. Information We May Collect from You

As INCODI FinTech Ltd., we generally do not collect end-user or direct financial transaction data. However, in the course of our business relationships and service provision, we may collect and process the following types of information:

Contact Information: This may include your title, first name, surname, company name, business address, business telephone number(s), and business email address(es). This information is typically provided when you fill in forms on our websites, contact us with queries, or enter into business agreements.

Business Relationship Information: Information necessary to fulfill our obligations arising from service contracts between you and us.

Website Usage Data: When you visit our website, details of your visits, how you use our site, and the resources that you access on our site may be recorded as explained below or on the website. This data often consists of statistical information not containing personal details and is analyzed to provide you with a better service.

Survey Responses: Information you provide when you respond to surveys that we may conduct, and you have agreed to be contacted.

Security and Compliance Data: Information collected to comply with our legal obligations, prevent fraud, and ensure security.

2. Uses Made of the Information

The information collected by INCODI is utilized with precision and purpose, primarily to facilitate the seamless provision of our technology services, enhance user experience, and ensure compliance with legal and operational requirements. We process this data for the following key objectives:

Service Provision and Business Operations: We meticulously employ your information to manage and execute all necessary payment processes between the parties, fulfill our contractual obligations arising from agreements with you, provide exemplary customer service, efficiently operate our business, and continuously refine the quality and scope of our offerings.

Communication and Support: Your contact details enable us to proactively inform you about significant changes to our products or services and to provide prompt and comprehensive responses to your queries, complaints, or specific information requests.

Marketing and Promotions (with your explicit consent): With your prior consent, we may leverage your information to furnish you with detailed insights into our services, distribute informative newsletters, and communicate targeted promotions and offers that we believe align with your professional interests. Should you prefer not to receive such marketing communications, you retain the full right to opt-out by clearly indicating your preference via the designated tick-box during the website sign-up process.

Enhancing Website Experience: We utilize collected data to optimize and enrich your interaction with our website, ensuring a more intuitive and personalized browser experience.

Statistical Analysis and Service Improvement: Beyond direct personal data, we rigorously analyze and interpret your browsing patterns and preferences as a visitor to our site. This statistical data, devoid of personally identifiable information, is instrumental in our continuous efforts to deliver superior service and can be shared with our trusted associates to further refine and personalize your engagement with INCODI's ecosystem.

Company Activities Planning and Execution: Information supports our strategic initiatives to design, coordinate, develop, and meticulously execute company-specific commercial activities. Furthermore, it is critical for the robust planning and effective execution of our broader business development strategies.

Legal Compliance and Security Assurance: We process data to uphold our legal, technical, and commercial-occupational safety obligations for both the Company and all individuals with whom INCODI maintains a business relationship, thereby ensuring strict adherence to all applicable legal requirements.

3. Disclosure of Your Information and Transfer to Third Parties

INCODI recognizes the critical importance of data security and strict confidentiality in the disclosure and transfer of your personal information. We may share your data under specific, controlled circumstances and always with appropriate safeguards in place:

Business Partners and Service Providers:

We may disclose your information to our trusted suppliers when such sharing is essential for the execution of our internal processes. This also includes engaging third-party processors who assist us in managing information, for example, to effectively address your complaints or administer your requests. It is important to note that some of these processors may operate outside of United Arab Emirates. In such instances, INCODI undertakes all legally mandated steps to ensure the implementation of suitable safeguards, guaranteeing the protection of your information during international transfers.

Legal Obligations and Protection of Rights:

We are obligated to disclose or share your personal information when compelled by any legal requirement, or when such disclosure is necessary to protect the rights, property, or safety of INCODI, our other customers, or any other individuals. This commitment extends to exchanging information with other companies and organizations as a measure for fraud prevention and credit risk mitigation.

Corporate Transactions (Acquisitions or Sales):

In scenarios involving the potential sale or acquisition of any part or the entirety of our business or assets, your personal information may be disclosed to the prospective seller or buyer of such business or assets. Should INCODI, or substantially all of its assets, be acquired by a third party, the personal information held by us regarding our customers will be considered one of the transferred assets.

Intra-Group Transfers:

From time to time, and in alignment with our operational structure, your personal information may be disclosed to other companies within the business group of which INCODI is an affiliate.

Furthermore, any transfer of your information to third parties is strictly governed by the following conditions:

Only with your explicit and unequivocal consent.
When one or more of the specific data processing conditions stipulated in the applicable Law are demonstrably met.
If the recipient country to which the data is transferred offers an adequate level of data protection.
In the absence of adequate protection in the recipient country, if INCODI undertakes, in writing, to provide adequate protection with the Data Officer in the relevant foreign country, and obtains the necessary permission from the Personal Data Protection Board.

4. Where We Store Your Personal Information and Security Measures Taken

The integrity and security of your personal information are paramount to INCODI. We employ a multi-layered approach to protect your data, both in terms of storage location and the technical and administrative measures implemented.

Data Storage Location: The information we collect from you will predominantly be stored within the geographical territory of United Arab Emirates.

Robust Security Measures: To decisively mitigate risks such as unauthorized access, accidental data loss, or the unauthorized deletion or destruction of data, we deploy a comprehensive suite of reasonable technical and administrative safeguards. These measures include, but are not limited to:

Ensuring data security through the strategic deployment of advanced software and hardware solutions, including state-of-the-art virus protection systems and resilient firewalls.
Maintaining meticulous records of all access to personal data, creating an auditable trail for accountability.
Rigorously tracking personal data processing activities on a granular, business unit basis to ensure oversight and control.
Conducting all necessary inspections to ensure the consistent enforcement of the provisions outlined in the applicable legislation on protection of personal data.
Guaranteeing the continuous compliance of all data processing activities with the Law through adherence to stringent internal policies and procedures.
Implementing precise authorization protocols within the Company, granting access to data strictly in accordance with the sensitivity and quality of the information.
When external access to personal data is necessitated, for instance, through outsourcing arrangements, obtaining binding commitments from external service providers to ensure their full compliance with the Law.
Taking all requisite actions to thoroughly inform and train all our employees, particularly those authorized to access personal data, regarding their duties and responsibilities under the Law.

5. Cookies and Internet Tags

INCODI employs digital technologies such as cookies and internet tags to enhance your website experience and gain valuable insights into user interactions:

Cookies Definition and Purpose:

Cookies are diminutive data files that are securely placed onto the hardware device you utilize to browse the internet by the websites you visit. These files serve as digital memory, containing crucial information about your past visits to that specific website. The fundamental purpose of cookies is to enable our websites to recognize you and recall your Browse habits upon your subsequent visits, thereby facilitating a more streamlined and personalized experience. Comprehensive details regarding our cookie usage practices are meticulously outlined in our dedicated Cookie Policy.

Internet Tags and Analytical Applications:

In conjunction with cookies, we may also integrate internet tags across our website. These tags, which may be developed and deployed through collaboration with third-party advertising partners, are instrumental in our efforts to analyze the efficacy and reach of our advertising campaigns. It is important to note that through the combined operation of these internet tags and cookies, our third-party partners may have the capability to collect anonymous, aggregated data concerning visitors across various websites.

6. Your Rights

Data owners have the following rights against the data controller:

To find out whether Personal Data is processed, to request information about it if it is processed.
Learning the purpose of processing Personal Data and whether it is used in accordance with its purpose.
Knowing third parties to whom Personal Data are transferred domestically or abroad.
Requesting correction if Personal Data is incomplete or incorrectly processed.
Requesting the deletion or destruction of Personal Data within the framework of the conditions stipulated in the relevant legislation, requesting notification of the transactions made to third parties to whom Personal Data has been transferred.
Objection to the emergence of a result against the person by analyzing the processed data exclusively through automated systems.
Requesting the compensation of the damage in case the Personal Data is subject to illegal processing.

7. Use of Your Rights

If you submit your requests regarding your rights by filling out the Data Owner Application Form, according to the nature of your request, we will conclude your request free of charge within 30 (thirty) days at the latest. However, if the transaction also requires a cost, you will be charged accordingly with the tariffs determined by INCODI. We will be able to request information from you in order to determine whether the applicant is the Data Owner, and may ask questions regarding the application to you in order to clarify the issues specified in the application.

8. Changes to Our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on our website page and, where appropriate, notified to you by e-mail.

9. Contact

Questions, comments, and requests regarding this privacy policy are welcomed and should be addressed to [email protected]

Privacy Policy