DEFINITIONS AND INTERPRETATION
"Splintr mobile application" means the mobile application developed by Splintr for merchants and consumers to use the Services.
"Splintr Payment System" means the system developed by Splintr for the implementation and administration of an online instalment payment solution, which includes performing validation checks and assessments on consumers and merchants using the system, managing accounts and processing transactions and requests.
"Splintr portal" means the online portal provided by Splintr to merchants and consumers to manage their respective accounts on the Splintr Payment System.
"Splintr website" means https://www.splintr.xyz/.
"Personal data" means any data, regardless of its format, about an individual who can be identified from that data or from that data and other information to which an organization has or is likely to have access.
COLLECTION OF PERSONAL DATA
Depending on the nature of your transaction with us, the personal data which we may collect from you includes (but is not limited to) your name and identification information such as your local identification number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, location and financial information such as credit card numbers, debit card numbers or bank account information.
Such personal data may be collected from you or from persons authorized by you to disclose your personal data to us through the following means, which are not exhaustive: creation of an account in the Splintr Payment System; creation of an order in the Splintr Payment System; use of the Splintr website, Splintr mobile application and/or the Splintr portals; provision of your contact details as an authorized representative of your company; and any interaction with us, including but not limited to any email exchange with us.
We may collect, use, process, disclose and/or transfer your personal data for any or all of the following purposes: performing obligations in the course of or in connection with our provision of the Services requested by you; verifying your identity, including distinguishing you from another person with the same or similar details as yourself; processing any payment or credit transactions; managing your relationship with us; responding to, handling and processing queries, requests, applications, complaints and feedback from you; carrying out reasonable business activities such as audits, risk management, business reporting, service quality control, statistical and trend analysis and other related or similar activities; complying with any internal policies, applicable laws, regulations, codes of practice, guidelines or rules (including those related to fraud, anti-money laundering and anti-terrorism), or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; collection and satisfaction of any debt owed by you to us; reporting information about you to a credit bureau or agency where necessary; sending you marketing communications including newsletters, notifications about new merchant additions, merchant engagements or merchant offers, conducting product surveys, advertising of similar products and services and event invitations, and you have the right to unsubscribe from such marketing communications; enforcing or defending our rights, contractual or otherwise, including investigations and participating in potential or actual litigation, arbitration or other legal process; any other purposes for which you have provided your personal data; and any other incidental business purposes related to or in connection with the above. These purposes may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you). The personal data that you provide us will not sold, traded, licensed, offered or otherwise used for commercial marketing purposes that are not related to Splintr and/or the Services.
DISCLOSURE AND TRANSFER OF PERSONAL DATA
We may disclose and/or transfer your personal data both within and outside of the UAE for the purposes specified above and as permitted or required by applicable laws and regulations to the following entities: any persons and entities involved in the provision of the Services to you, including merchants, credit card companies and processors and third-party payment providers; any third-party service provider, agent, contractor or other organization which we have engaged to carry out any of the purposes specified above; any third party involved in or in connection with potential or actual litigation, arbitration or other legal process with us; any person or entity to whom we are under any obligation or otherwise required to make disclosure pursuant to legal process or legal or regulatory obligation or request, including disclosure to any relevant governmental and/or regulatory authorities, whether in UAE or abroad. Any credit reference bureau or agency where necessary and appropriate; and any person to whom disclosure is reasonable considered by us to be necessary. We will reasonably endeavor to ensure that any third party who receives your personal data from us shall handle such personal data in accordance with the applicable regulation. Where we transfer your personal data to countries outside of the UAAE, we will obtain your consent for such transfer to be made and will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the applicable regulation.
WITHDRAWING YOUR CONSENT
The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing to our data protection officer at the contact details provided below. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the same manner. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
PROTECTION OF PERSONAL DATA
We are committed to protecting your personal data and will use reasonable endeavors to safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. In this respect, we have introduced appropriate administrative, physical and technical measures such as storing personal data on secured servers maintained in controlled facilities, using up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and we limit access to your personal data to authorized persons on a confidential and need-to-know basis. In respect of your financial information, we use credit card processors that comply with strict industry standards and we implement techniques to allow payments to be processed in our systems without saving such financial information.
ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you or your authorized representative. In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our data protection officer at the contact details provided below.
ACCESS TO AND CORRECTION OF PERSONAL DATA
Subject to certain exceptions, you may request a copy of or correction to your Personal Data held by us by contacting our data protection officer at the contact details provided below. Please note that a reasonable fee may be charged for an access request, and we will inform you of the fee before processing your request. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the applicable regulation).
RETENTION OF PERSONAL DATA
We may retain your personal data for as long as necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
AMENDMENTS AND MODIFICATIONS
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