Privacy Policy
Last updated: February 11, 2025
Welcome to Uqudo! We respect Your privacy and are committed to protect Your Personal Data. This Privacy Policy (“Privacy Policy” or “Policy”) describes Our policies and procedures on the collection, use, process and disclosure of Your information when You use Our Website and/or Services and tells You about Your privacy rights and how the law protects You.
It is important that You read this Privacy Policy together with any other privacy policy We may provide on specific occasions when We are collecting or processing Personal Data about You so that You are fully aware of how and why We are using Your data. This Policy supplements other privacy policies and is not intended to override them.
We use Your Personal Data to provide and improve the Service. By accessing and using Our Services and/or Website, You agree to the collection and use of Your Personal Data in accordance with this Privacy Policy.
Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
- Account means a unique account created for You to access our Service or parts of our Service on the Website.
- Company (referred to as either “the Company”, “We”, “Us” or “Our” or “Uqudo”) in this Agreement) refers to Uqudo Technology Limited, Uqudo Unit GA-00-VZ-01-FL-190 Level 1 Gate Avenue Dubai International Financial Centre PO Box 120252 Dubai, United Arab Emirates.
- Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- Country refers to United Arab Emirates
- Device means any device that can access the Service and/or Website such as a computer, a smartphone or a digital tablet.
- Personal Data is any information that relates to an identified or identifiable individual, such as Your name, identification number or online identifiers, contact, financial, biometric, transaction, technical, profile, usage and/or marketing and communications data as further described in this Privacy Policy.
- Service(s) refers to the range of services and products offered by Uqudo, as detailed on the Website and updated from time to time and further described in these Terms.
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Website refers to Uqudo’s website accessible from www.uqudo.com.
- You or Your means the individual accessing or using the Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service or Website, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Uqudo may collect, use, store, and transfer various types of Personal Data about You, including, but is not limited to:
- Identity Data: including full name, username, title, government-issued ID, date of birth, and gender.
- Contact Data: including email address, phone numbers, and address.
- Financial Data: including bank account details, payment card information, refunds, and transaction records related to purchases on Our Website.
- Transaction Data: including purchase history, including details about payments.
- Profile Data: including username, password, purchase history, preferences, and feedback, and any other information You provide while using Our Services.
- Usage Data: including information on how You interact with Our Website, including navigation paths and page views, the time and date of Your visit, the time spent on those pages. This also includes internet protocol (IP) address, Your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, installed apps, unique device identifiers, other diagnostic data, and other technology on the Devices You use to access this Website. Usage Data is collected automatically when using the Service or accessing our Website.
- Marketing and Communications Data: including Your preferences for receiving marketing from Us, Our service providers and Your communication preferences.
- Biometric Data: including facial recognition data, fingerprint scans, palm prints, voice patterns, and any other biometric identifiers collected for identity verification and authentication purposes.
We may also collect information that Your browser sends whenever You visit Our Service and/or Website or when You access the Service and/or Website by or through a mobile device.
We collect data from Your phone to provide a segmented risk profile and generate an aggregated statistical information. To protect Your identity, We remove all personal identifiers (if any) and pseudonymize such information. Any metadata processed in this way cannot be used to reproduce the original data collected.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from Your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal Your identity. For example, We may aggregate Your Usage Data to calculate the percentage of users accessing a specific website feature. 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.
| Category of Personal Data | Purpose of Processing | Legal Basis |
|---|---|---|
| Identity Data (e.g., full name, national ID/passport number) |
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| Contact Data (e.g., email, phone number, physical address) |
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| Financial Data (e.g., bank account details, payment card information, transaction history) |
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| Profile Data (e.g., username, password, preferences) |
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| Usage Data (e.g., pages visited and interaction data) |
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| Biometric Data (e.g., facial recognition, fingerprint scans, palm prints, voice patterns, etc.) |
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| Compliance Data (e.g., ID) |
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How Is Your Personal Data Collected?
We collect Your Personal Data in the following ways:
- 1.1 Direct InteractionsYou may give Us Your Identity, Contact and Financial Data by filling in electronic forms or by corresponding with Us by post, phone, email or otherwise. This includes Personal Data You provide when You:
- create an account on Our Website;
- subscribe to Our Service;
- request marketing to be sent to You;
- fill out forms;
- are Corresponding with Us via email, phone, or other communication channels;
- making a purchase on Our Website; and/or
- participating in surveys or competition, survey, or promotional activities.
- 1.2 Third Parties or Publicly Available SourcesWe may receive Your Personal Data from third-party and public sources, including:
- Usage Data from the following parties:
- authorized analytics providers;
- advertising networks; and/or
- search information providers.
- Contact, Financial and Transaction Data from providers of technical and payment services.
- Usage Data from the following parties:
- 1.3 Automated TechnologiesAs You interact with Our Website, We may automatically collect Usage Data about Your browsing activities through Cookies, server logs and similar technologies. We may also receive Usage Data about You if You visit other websites employing Our Cookies.
Tracking Technologies and Cookies
We may use Cookies and similar tracking technologies to enhance Your experience on Our Website, improve and analyze Our Services, track Your activity on Our Website, and collect, track and store certain information. Depending on Your Cookie preferences, We may place Cookies on Your Device when You visit Our Website. Tracking technologies used are beacons, tags, and scripts. The technologies We use may include:
- Cookies or Browser Cookies. A cookie is a small file placed on Your Device. 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 Services and Website. Unless You have adjusted Your browser setting so that it will refuse Cookies, Our Services may use Cookies. Advertising and analytics cookies will only be used with your consent to improve User experience and delivering targeted ads.
- Flash Cookies. Certain features of Our Services and/or Website may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on Our Services and/or Website. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
- Web Beacons. Certain sections of Our Service, Website and Our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your 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.
You can manage Your cookie settings through Your browser, which may allow You to decline Cookies or notify You when a website attempts to place a cookie on Your Device. Please be aware that disabling certain Cookies may limit Your experience on Our Website.
Uqudo may permit third-party companies to display advertisements on Our Website, allowing them to set and access their cookies on Your Device. The use of these cookies by third parties is governed by their respective privacy policies, and they do not have access to Uqudo’s Cookies.
How We Use Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service: analyzing Your user behavior, including to monitor the usage of our Service to enhance Our offering, improve Our Website functionality and user experience.
- 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 the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
- 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, promotional content, 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 and to resolve inquiries, issues, and feedback.
- Security and Fraud Prevention: protecting against unauthorized activities, security breaches, and fraud.
- For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
- For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We process Your Personal Data based on one or more of the following lawful basis:
- Consent: Where You have given explicit consent for the processing of Your Personal Data.
- Contractual Necessity: Processing is necessary for the performance of a contract with You or to take pre-contractual steps at Your request.
- Legal Obligation: Processing is necessary to comply with a legal obligation to which We are subject to, such as anti-money laundering (AML) and know your customer (KYC) regulations to comply with applicable laws, regulations, and requests from governmental authorities, and to enforce Our terms and policies.
- Legitimate Interests: means the interest of Our business in conducting and managing Our business to enable Us to give You the best Service/product and the best and most secure experience. We make sure We consider and balance any potential impact on You (both positive and negative) and Your rights before We process Your Personal Data for Our legitimate interests. We do not use your Personal Data for activities where Our interests are overridden by the impact on You (unless We have Your consent or are otherwise required or permitted to by law). You can obtain further information about how We assess Our legitimate interests against any potential impact on You in respect of specific activities by contacting Us.
Your Data Protection Rights
Under certain circumstances, You have rights under data protection laws in relation to Your personal data:
- Right to Access Your Personal Data (commonly known as a ‘data subject access request’). This enables You to receive a copy of the Personal Data We hold about You and to check that We are lawfully processing it.
- Right to Rectification: Request correction of inaccurate or incomplete data We hold about You, though We may need to verify the accuracy of the new data You provide to Us.
- Right to Erasure: Request deletion of Your Personal Data.
- Request restriction of processing of Your Personal Data. This enables You to ask Us to suspend the processing of Your Personal Data in the following scenarios:
- If You want Us to establish the data’s accuracy.
- If You do not want Us to erase it.
- Where You need Us to hold the data even if We no longer require it as You need it to establish, exercise or defend legal claims.
- You have objected to Our use of Your Personal Data, but We need to verify whether We have overriding legitimate grounds to use it.
- Right to Object to processing of Your Personal Data where We are relying on a legitimate interest (or those of a third party) and there is something about Your particular situation which makes You want to object to processing on this ground as You feel it impacts on Your fundamental rights and freedoms. You also have the right to object where We are processing Your Personal Data for direct marketing purposes. In some cases, We may demonstrate that We have compelling legitimate basis to process Your information which override Your rights and freedoms.
- Right to Data Portability of Your Personal Data to You or to a third party. We will provide to You, or a third party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
- Right to Withdraw Consent at any time where We are relying on consent to process Your Personal Data. However, this will not affect the lawfulness of any processing carried out before You withdraw Your consent. If You withdraw Your consent, We may not be able to provide certain products or services to You. We will advise You if this is the case at the time You withdraw Your consent.
To exercise these rights, please contact Us at compliance@uqu.do . We will respond to all legitimate requests within 3 business days.
You will not have to pay a fee to access Your Personal Data (or to exercise any of the other rights). However, We may charge a reasonable fee if Your request is clearly unfounded, repetitive, or excessive. Alternatively, We could refuse to comply with Your request in these circumstances.
We may need to request specific information from You to help Us confirm Your identity and ensure Your right to access Your Personal Data (or to exercise any of Your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact You to ask You for further information in relation to Your request to speed up Our response.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary to fulfil the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your Personal Data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.
To determine the appropriate retention period for Personal Data, We consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of Your Personal Data, the purposes for which We process Your Personal Data and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We have to keep Personal Data about Our customers (including Contact, Identity, Financial and Transaction Data) for five (5) years after they cease being customers.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
| Retention Period | Purpose | |
|---|---|---|
| Identity and Contact Data | Retained for the duration of your account and up to 5 years after account closure. | For compliance purposes and enhance User experience. |
| Financial Data | Up to 7 years. | To comply with legal and tax obligations and auditing purposes. |
| Usage Data | Up to 3 years. | For analytics and improvement purposes. |
| Biometric Data | Retained for the minimum period necessary to fulfill the purpose of processing and deleted immediately after identity verification, unless longer retention is required by law or with the explicit consent of the data subject. In no event shall Biometric Data be retained beyond 3 years from the last interaction. | For identity verification, fraud prevention, security measures, and compliance with regulatory requirements (e.g., e-KYC and AML obligations). |
| Marketing Data | Retained until You withdraw your consent or opt-out of marketing communications. | For analytics and marketing purposes. |
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.
Disclosure of Your Personal Data
We may share Your Personal Data with the following third parties:
- With Service Providers: We may share Your Personal Data with trusted third-party service providers to provide, monitor and analyze the use of Our Service, who assist Us in operating Our Website and to contact You (e.g., IT support).
- With Partners: We may share Your Personal Data with Our partners who support Us in delivering Our Services, including but not limited to:
- i. Biometric Data processing;
- ii. Optical Character Recognition (“OCR”) for certain documents, which can be handled by a partner in specific cases;
- iii. Anti-Money Laundering (“AML”) and Counter-Financing of Terrorism (“CFT”) checks; and
- iv. National Citizen Register (“NCR”) checks, performed by a third-party governmental entity.
- For business transactions: We may share or transfer Your Personal Data 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. We will provide notice before Your Personal Data is transferred and becomes subject to a different privacy policy.
- With affiliates: We may share Your information with Our affiliates, in which case We will require those affiliates to honor 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 professional advisers acting on behalf of the Company including lawyers, auditors, and insurers who provide consultancy, legal, insurance and accounting services to the Company.
- 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.
- With Your consent: We may disclose Your Personal Data with other parties for any other purpose with Your explicit consent.
- With 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 and regulatory authorities (e.g., a court or a government agency).
- 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.
We require all third parties to respect the security of Your Personal Data and to process it in accordance with the law. We do not allow Our third-party service providers or partners to use Your Personal Data for their own purposes and only permit them to process Your Personal Data for specified purposes outlined above and in accordance with Our instructions.
Security of Your Personal Data
The security of Your Personal Data is important to Us, We have put in place appropriate security measures to prevent Your Personal Data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, We limit access to Your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process Your Personal Data on Our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify You and any applicable regulator of a breach where We are legally required to do so. However, 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. We encourage You to protect Your account by using strong passwords and enabling two-factor authentication.
Usage of Face Data
Our service provides a seamless onboarding experience for businesses looking to integrate consumers into their systems. This process involves a facial recognition technology, which functions as follows:
- Collection of Selfie for Verification: The consumer is required to take a selfie using their smartphone. This image is crucial for the subsequent verification process.
- Comparison with Identity Document: The selfie is then compared with the face image from the consumer’s scanned identity document. This step is essential to confirm the identity of the individual.
In line with our steadfast commitment to privacy, We implement the following measures to safeguard your information:
- No Permanent Storage of Selfies: We assure You that the selfies taken during the onboarding process are used solely for verification purposes. These images are not stored permanently in our system.
- Data Protection Compliance: We adhere to stringent data protection regulations and best practices. Our systems and processes are designed to protect consumer data from unauthorized access or breaches.
If You Fail To Provide Personal Data
Where We need to collect Personal Data by law, or under the terms of a contract We have with You, and You fail to provide that data when requested, We may not be able to perform the contract We have or are trying to enter into with You (for example, to provide You with goods or Services). In this case, We may have to cancel a product or service You have with Us but We will notify You if this is the case at the time.
Marketing and Advertising
We strive to provide You with choices regarding certain Personal Data uses, particularly around marketing and advertising. We may use Your Identity, Contact, Usage and Profile Data to form a view on what We think You may want or need, or what may be of interest to You. This is how We decide which products, Services and offers may be relevant for You.
We may process Your Personal Data to develop insights about Your preferences and interests, enabling Us to offer products, Services, or content that may be relevant to You. This may include sending You marketing communications about Our Services.
You have the right to object to receiving such communications or opt out at any time by contacting Us or third parties. Please note that even if You opt out of marketing communications, We may still send You messages related to transactions or ongoing Services related to Our business relationship. Where You opt out of receiving these marketing messages, this will not apply to Personal Data provided to Us as a result of Service purchase, product/Service experience or other transactions.
We will seek Your consent for processing Your Personal Data when the processing of Your data is for the purpose of sending third party direct marketing communications to You via email or text message for marketing purposes. You can withdraw Your consent for marketing preferences at any time by adjusting the relevant settings or contacting Us directly to opt out of receiving further marketing messages.
Children’s Privacy
Our Service does not directly address or process the Personal Data of individuals under the age of 18. However, We may process children’s Personal Data solely when You, as Our client, engage Us to provide onboarding and identity verification Services for Your underage customers. In such cases, it is Your full and exclusive responsibility to obtain the explicit consent of the child’s parent or legal guardian before submitting their Personal Data for processing by Uqudo. We shall not be held liable for any failure by You to obtain such consent, nor for any claims, damages, or disputes arising from Your non-compliance with parental consent requirements.
If You are a parent or guardian and You believe that Your child’s Personal Data has been submitted to Us without your consent, please contact the entity that collected and provided such data to Us. Uqudo does not have direct control over such data collection and shall not be responsible for verifying parental consent.
If We become aware that We have inadvertently processed Personal Data from anyone under the age of 18 without parental consent, We will take appropriate steps to delete such personal information from Our servers and systems.
By submitting children’s Personal Data for processing, You expressly confirm that You have obtained all necessary parental consents and indemnify Uqudo against any claims, liabilities, or legal actions resulting from Your failure to do so.
Links to Other Websites
Our Services and/or Website 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.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time to reflect changes in our practices or for legal, regulatory, or operational reasons and to better provide You with Our Services. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If You have any questions about this Privacy Policy, you can contact Us at:
- Email: compliance@uqu.do
- By visiting this page on our Website: uqudo.com/contact
