Yuze Digital Data Privacy Notice
Data Privacy Notice
The purpose of this document ("Data Protection Policy") is to inform you of how Yuze Digital Limited, DIFC branch (“YUZE DIGITAL”) manages Personal Data (as defined below) which is subject to the Dubai International Financial Centre ("DIFC") Data Protection Law (DIFC Law No. 5 of 2020) & the Data Protection Federal Law No. 45 of 2021 (the "Law"). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
By interacting with us, submitting information to us, or signing up for any products or services offered by us, you acknowledge that YUZE DIGITAL(including its respective representatives and/or agents ("Representatives") (YUZE DIGITAL and its Representatives collectively referred to herein as "YUZE DIGITAL", "us", "we" or "our") may collect, use, disclose and share amongst themselves your Personal Data, and disclose such Personal Data to YUZE DIGITAL’s authorised service providers and relevant third parties, including YUZE DIGITAL’s related corporations, head office and overseas branches and offices and overseas branches and officers of YUZE DIGITAL’s related corporations (the “Companies” and each, a “Company”)in the manner set forth in this Data Protection Policy.
YUZE DIGITAL may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. You acknowledge that you have reviewed and understood the terms of this Data Protection Policy as updated from time to time on our website http://www.YuzeDigital.com/Data-Protection-Policy.html. Please check back regularly for updated information on the handling of your Personal Data
Personal Data
In this Data Protection Policy, "Personal Data" refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, national identity card, passport or other identification number, telephone number(s), mailing address, email address, transactional data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us (including in the form of biometric data), or via other forms of interaction with you.
Collection of Personal Data
Generally, we collect Personal Data in the following ways:
when you submit any form, including but not limited to application forms or other forms relating to any of our products or services which you purchase through YUZE DIGITAL and/or the Companies;
when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;
when you interact with our staff, including relationship managers and their assistants, example via telephone calls (which may be recorded), letters, fax, face-to-face meetings and emails;
when your images are captured by us via closed-circuit television cameras ("CCTVs") while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events hosted by us;
when you use some of our services provided through online and other technology platforms, such as websites and apps, including when you establish any online accounts arranged by us;
when you request that we contact you, or include you in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
when you are contacted by, and respond to, our marketing representatives, agents and other service providers;
when we seek information about you and receive your Personal Data from third parties in connection with your relationship with us, for example, from referrers, business partners, external or independent asset managers, public agencies or the relevant authorities;
through physical access, internet and information technology monitoring processes;
in connection with any investigation, litigation, registration or professional disciplinary matter, criminal prosecution, inquest or inquiry which may relate to you or any Connected Person; and/or
when you submit your Personal Data to us for any other reason.
When you browse our website and platforms, you generally do so anonymously but please see the section below on cookies. We do not, at our website and platforms, automatically collect Personal Data, including your email address unless you provide such information or login with your account credentials.
If you provide us with any Personal Data relating to a third party (for example, information of your spouse, children, parents, or a Connected Person), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with his/her Personal Data for the respective purposes.
"Connected Person" may include but is not limited to any beneficial owner, authorised signatory, director, shareholder, officer of a company, partner or member of a partnership, settlor, trustee, beneficial owner, protector or grantor of trust, mandate holder, power of attorney holder, surety, third party security provider, provider of funds, founder and/or employee, payee of designated payment, representatives, agents or nominees.
You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested. You acknowledge that you should inform YUZE DIGITAL immediately of any change of facts or circumstances which may render any information or Personal Data previously provided inaccurate, untrue or incorrect and provide any information or documentation as YUZE DIGITAL may reasonably require for the purposes of verifying the accuracy of the updated information or Personal Data.
Purposes for the Collection, Use and Disclosure of Your Personal Data
Generally, YUZE DIGITAL collects, uses and discloses your Personal Data for the following purposes:
responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
verifying your identity and customer due diligence;
managing the administrative and business operations of YUZE DIGITAL or the Companies and complying with internal policies and procedures (including but not limited to facilitating business continuity planning);
audit purposes;
verifying or confirming trade orders or instructions from you or for your account (including but not limited to instructions on fund transfers or remittances);
facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of YUZE DIGITAL or the Companies;
matching any Personal Data held which relates to you for any of the purposes listed herein;
resolving complaints and handling requests and enquiries;
preventing, detecting and investigating crime, including fraud and money-laundering or terrorist financing, and analysing and managing commercial risks (including but not limited to preventing and detecting loss of YUZE DIGITAL’s proprietary and sensitive information);
project management;
providing media announcements and responses, for example in relation to complaints or law suits;
requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
managing and preparing reports on incidents and accidents;
organising events, seminars or trainings;
complying with any applicable rules, laws and regulations, codes of practice or guidelines, obligations, requirements or arrangements for collecting, using and disclosing Personal Data that apply to YUZE DIGITAL or that it is expected to comply, according to:
any law binding or applying to it within or outside the DIFC existing currently and in the future;
any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside the DIFC existing currently and in the future;
any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers that is assumed by or imposed on YUZE DIGITAL by reason of its financial, commercial, business, or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations;
to assist in law enforcement and investigations by relevant authorities;
in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
archival management (including but not limited to warehouse storage and retrievals); and/or
any other purpose relating to any of the above.
These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s) arranged by us.
In addition, YUZE DIGITAL collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:
If you are a prospective customer:
evaluating your eligibility to open an account arranged by us and your financial and banking needs and providing recommendations to you as to the type of products and services suited to your needs;
assessing and processing any applications or requests made by you for products and services offered by YUZE DIGITAL; and/or
any other purpose relating to any of the above.
If you are a customer holding an account arranged by YUZE DIGITAL or a Connected Person or an administrator, executor, liquidator, official assignee, receiver, judicial manager or other similar official who has been so appointed pursuant to bankruptcy or insolvency proceedings instituted in the DIFC or elsewhere in respect of a YUZE DIGITAL customer or any security provider:
Arranging the opening, maintaining or closing of accounts and our providing advisory services to you;
Arranging the processing of fund transfers or any other instructions provided in relation to the account of a YUZE DIGITAL customer;
where account or relationship managers or agents have been assigned to service your account or portfolio, using your telephone number(s) to contact you from time to time in order to take your instructions, and/or provide you with information, updates, or recommendations and / or in accordance with the terms and conditions of our agreement with you;
processing applications for and arranging the daily operation of services and arranging credit facilities provided to you or other persons or corporations for whom you act as surety or third party service provider;
conducting credit checks at the time of application for credit and at the time of regular or special credit reviews;
carrying out client reviews, for example, annual reviews of your portfolio;
to establish your financial situation, risk profile, investment experience and investment objectives to help you consider the suitability of the products you have invested or intend to invest;
arranging the provision of internet banking services (including but not limited to carrying out special handling requests for PIN mailers and tokens);
networking to maintain customer relationship;
providing client servicing (including but not limited to responding to individual requests by customers, mailing services, reconciliation services and providing customer satisfaction);
facilitating the arrangement for transfer of funds;
administering exceptional approvals, fee adjustments or waivers;
enabling any Company or third party to perform the functions that YUZE DIGITAL may have outsourced to it in relation to the management of your account or transactions; and/or
any other purpose relating to any of the above.
If you are an employee or agent of a referrer or other intermediary:
marketing services and products;
processing commission remuneration;
performing due diligence and reference checks; and/or
any other purpose relating to any of the above.
If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by YUZE DIGITAL;
managing project tenders or the supply of goods and services;
processing and payment of vendor invoices;
complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (which includes disclosure to regulatory bodies or audit checks); and/or
any other purpose relating to any of the above.
If you are a party or counterparty to a transaction (for example, a beneficiary of a fund transfer or payment):
If you are a party or counterparty to a transaction (for example, a beneficiary of a fund transfer or payment):
any other purpose relating to any of the above.
In addition, where permitted under the Law, YUZE DIGITAL may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as "Additional Purposes" for the handling of Personal Data):
providing or marketing services, products and benefits to you, including promotions, loyalty and reward programmes;
matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the customisation, provision or offering of products and services, marketing or promotions, whether by YUZE DIGITAL or other third parties;
sending you details of products, services, special offers and rewards, investment or research reports or guides, either to our customers generally, or which we have identified may be of interest to you; and/or
conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile.
If you have provided your telephone number(s) you consent to receiving marketing or promotional information via your telephone number(s), then from time to time, YUZE DIGITAL may contact you using such telephone number(s) (including via voice calls, text , fax or other means) with information about our products and services (including discounts and special offers). If you specifically instruct us in writing objecting to our use of personal data for direct marketing purposes we will stop using the data in such manner.
In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
Disclosure of Personal Data
YUZE DIGITAL will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas, including the United Arab Emirates outside the DIFC or in the DIFC:
the Companies;
counterparties and their respective banks in relation to transactions for your account including purchasing and selling of securities and investment products, fund transfers, payments, issuance of standby letters of credit, banker’s guarantees or letters of undertaking and drawing of cheques;
third party recipients of reference letters;
companies providing services relating to insurance and/or reinsurance;
insurers or brokers in relation to the insurance products or services that you have applied for or purchased;
trustees, attorneys and asset managers appointed by you to manage your account;
referrers who have referred you to YUZE DIGITAL;
agents, contractors, vendors, installers, or third party service providers who provide administrative or operational services to YUZE DIGITAL, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to YUZE DIGITAL;
agents, contractors, vendors or other third party service providers in connection with marketing, products and services offered by YUZE DIGITAL;
analytics, search engine providers or third party service providers that assist us in delivering our products, services, websites and platforms as well as improving and optimising the same;
credit reporting agencies;
debt collection agencies;
your employers which are financial institution, for their internal surveillance or monitoring purposes;
any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of YUZE DIGITAL or the Companies;
credit card companies and their respective service providers in respect of credit cards held by you;
translators;
our professional advisers such as our auditors and lawyers;
third parties who provide corporate advisory services or due diligence services in connection with you, any Connected Person or your account held with YUZE DIGITAL;
relevant government regulators, government ministries, exchange, statutory boards or authorities or law enforcement agencies who have jurisdiction over YUZE DIGITAL or any Company or over any transaction entered into by you, such as the Dubai Financial Services Authority and where applicable, competent authorities in the United Arab Emirates outside the DIFC, the Central Bank of UAE and other relevant authority;
any liquidator, receiver, administrator, judicial manager, trustees-in-bankruptcy, custodian or other similar official who has been so appointed, pursuant to bankruptcy, winding-up or insolvency proceedings instituted in the DIFC or elsewhere, in respect of you or your assets;
third parties who carry out registration of charge or pledge over the assets that you have pledged or charged to YUZE;
corporate service providers or lawyers, who are appointed by you;
providers of the DIFC Employee Workplace Savings Scheme (DEWS);
financial institutions, brokerage houses, clearing houses, depository, depository agents, managers, administrators, fund houses, registrars, custodians, external banks, nominee banks and investment vehicles in relation to asset management and investment product settlement processing;
collection and repossession agencies in relation to the enforcement of repayment obligations for loans;
third parties who organise promotional or marketing events, seminars or trainings;
any person to whom YUZE DIGITAL or any of the Companies is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to YUZE DIGITAL or any of the Companies, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers with which YUZE DIGITAL or any of the Companies are expected to comply, or any disclosure pursuant to any contractual or other commitment of YUZE DIGITAL or any of the Companies with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or industry bodies or associations of financial services providers, all of which may be within or outside the DIFC and may be existing currently and in the future; and/or
any other party to whom you authorise us to disclose your Personal Data to.
When transferring your Personal Data overseas to countries which do not have data protection laws or to countries where your privacy will not be protected as extensively, including transfers out of the DIFC to other parts of the United Arab Emirates, we will implement appropriate measures to ensure that your Personal Data remains protected and secure while and for as long as it remains under our control, for example, by implementing specific contractual clauses with the entities to whom we share your personal data.
Use of Cookies and Related Technologies
Our websites and platforms use cookies and other technologies. Cookies are small text files stored in your computing or other electronic devices when you visit our website and platforms for record keeping purposes. Cookies are stored in your browser’s file directory, and the next time you visit the website or platform, your browser will read the cookie and relay the information back to the website, platform or element that originally set the cookie. Depending on the type of cookie it is, cookies may store user preferences and other information.
Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our websites or platforms. Web beacons are usually used in conjunction with cookies and primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites and platforms, as well as finding out if an e-mail has been received and opened and to see if there has been any response.
We may employ cookies and other technologies as follows:
tracking information such as the number of visitors and their frequency of use, profiles of visitors and their preferred sites;
making our websites and platforms easier to use. For example, cookies may be used to help speed up your future interactions with our websites and platforms;
to better tailor our products and services to your interests and needs. For example, cookies information may be identified and disclosed to our vendors and business partners to generate consumer insights;
collating information on a user’s search and browsing history;
when you interact with us on our websites and platforms, we may automatically receive and record information on our server logs from your browser. We may collect for the purposes of analysis, statistical and site-related information including, without limitation, information relating to how a visitor arrived at the website or platform, the browser used by a visitor, the operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (which may include for example, information about which pages they have viewed, the time the pages were accessed and the time spent per web page);
using such information to understand how people use our websites and platforms, and to help us improve their structure and contents;
using cookies that are necessary in order to enable our websites and platforms to operate, for example, cookies that enable you to log onto secure parts of our websites and platforms; and/or
personalising the website and platform for you, including delivering advertisements which may be of particular interest to you and using cookie related information to allow us to understand the effectiveness of our advertisements.
Some cookies we use are from third party companies to provide us with web analytics and intelligence about our websites and platforms. These companies collect information about your interaction with our websites and platforms. We use such information to compile statistics about visitors who interact with the websites, platforms and other online content belonging to Oversea-Chinese Banking Corporation (“OCBC”), to gauge the effectiveness of our communications, and to provide more pertinent information to our visitors.
If you do not agree to such use of cookies, you can adjust your browser settings. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon as you visit our site or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies.
The way which cookies can be managed depends on your browser. The following links provide information on how to configure or disable cookies in each browser:
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Internet Explorer: http://windows.microsoft.com/en-SG/internet-explorer/delete-manage-cookies#ie=ie-9
Safari: http://support.apple.com/kb/HT1677?utm_source=Agillic%20Dialogue
Safari for iPhone: http://support.apple.com/kb/ta38619
Chrome for Android: https://support.google.com/chrome/answer/2392971?hl=en
If you do not agree to our use of cookies and other technologies as set out in this Data Protection Policy, you should delete or disable the cookies associated with our websites and platforms by changing the settings on your browser accordingly. However, you may not be able to enter certain part(s) of our websites or platforms. This may also impact your user experience while on our websites or platforms.
Data Security
YUZE DIGITAL will take appropriate efforts to protect Personal Data in our possession or our control by making appropriate security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. We have put in place procedures to deal with any suspected data security breach and will notify you and the data protection regulator, the DIFC Commissioner of Data Protection (the "Commissioner") of a suspected breach where we are legally required to do so or we consider it appropriate to do so. Although we will implement appropriate measures to keep your data secure, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). No communication over public internet can be guaranteed to be secure. You should be aware of the risks associated with using websites and the internet and take any necessary precautions.
While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or other electronic communications or when you use our electronic services, and we urge you to take every precaution to protect your Personal Data when you transmit your Personal Data via the Internet or other electronic communications. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
If applicable, you acknowledge that you should keep your username and password secure and confidential and should not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place.
Third-Party Sites
Our website may contain links to other websites operated by third parties. We do not control the privacy practices of websites operated by third parties that are linked to our website. We do not endorse or make any representations about third-party websites. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.
Contacting Us – Feedback and Requests relating to your Rights under the Law
Under certain circumstances, you may exercise any of the following rights:
Access your data – to request a copy of your Personal Data that we process about you;
Rectify your data – to request us to amend or update your Personal Data where it is inaccurate or incomplete;
Erase your data – to request us to delete your Personal Data where it is no longer necessary for the purpose(s) for which your information was originally collected;
Restrict your data – to request us temporarily or permanently to stop processing all or some of your Personal Data;
Object to the use of your data – at any time, to object to us processing your Personal Data where it is based exclusively on our legitimate interests (see above) or for direct marketing purposes;
Receive or transmit your data in a machine-readable and structured format (otherwise known as "data portability") – to request the receipt or transmission of your Personal Data to another organisation, in a structured and machine-readable format;
Object to any automated decision-making – to request us not to subject you to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect; and
Withdraw your consent – withdraw your consent at any time to the use of your Personal Data for a particular purpose (where we have asked you for consent to use your information for that particular purpose).
If you:
have any questions or feedback relating to your Personal Data or our Data Protection Policy;
would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
would like to exercise any of your other rights in relation to your Personal Data as set out in section 8.1 above, please contact us as follows:
Email:
Call:
+971 4 345 1197
Write in:
Data Protection Officer Yuze Digital Limited, DIFC Branch Dubai – UAE
If you feel that we do not comply with the Law, you may lodge a complaint with the Commissioner.
We confirm that we will not discriminate against you if you exercise any of your rights under this Data Protection Policy.
Please note that if your Personal Data has been provided to us by a third party, we recommend that you contact that party directly to make any queries, feedback and requests to YUZE DIGITAL on your behalf.
If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, YUZE DIGITAL may not be in a position to continue to provide its products or services to you, administer any contractual relationship in place, may also result in the termination of any agreements you have entered into with YUZE DIGITAL, which could have adverse impacts on your financial situation.
Last updated