PRIVACY&COOKIE POLICY

February 2, 2026

1. INTRODUCTION

DubaPays ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our payment processing services.

This policy applies to information collected through our website (dubapays.com), mobile application, and services.

2. INFORMATION WE COLLECT

2.1 Personal Information

We collect the following personal information:

Account Registration:

• Full name (first and last name)
• Email address
• Company name and registration details
• Company website URL
• Telegram username
• Business address
• Phone number
• Tax identification number

Payment Information:

• Bank account details
• Transaction history
• Payment amounts and currencies
• Invoice and order descriptions

Identification Documents:

• Government-issued ID
• Business licenses
• Proof of address
• Beneficial ownership information

2.2 Automatically Collected Information

Technical Data:

• IP address
• Browser type and version
• Device information
• Operating system
• Access times and dates
• Pages viewed and interactions
• Referring website addresses

Cookies and Tracking:

• Session cookies
• Preference cookies
• Analytics cookies
• Security cookies

2.3 Customer Payment Data

When your customers make payments:

• Cardholder name
• Payment card information (processed by our PCI-compliant partners)
• Billing address
• Transaction amount and currency
• Payment timestamp

3. HOW WE USE YOUR INFORMATION

We use collected information for the following purposes:

3.1 Service Provision

• Creating and managing your Account
• Processing payment transactions
• Generating payment links and QR codes
• Providing customer support
• Sending service-related communications

3.2 Compliance and Security

• Verifying your identity (KYC)
• Preventing fraud and unauthorized access
• Complying with legal obligations
• Anti-money laundering (AML) screening
• Detecting and preventing security incidents

3.3 Business Operations

• Analyzing usage patterns and trends
• Improving our Services
• Developing new features
• Conducting market research
• Reconciling payments and generating reports

3.4 Marketing (with consent)

• Sending promotional materials
• Providing product updates
• Conducting surveys
• Personalizing your experience

4. LEGAL BASIS FOR PROCESSING (GDPR)

We process your data based on:

• Contract Performance: Processing necessary to provide our Services
• Legal Obligation: Compliance with AML, KYC, and financial regulations
• Legitimate Interest: Fraud prevention, service improvement, and security
• Consent: Marketing communications and optional features

5. HOW WE SHARE YOUR INFORMATION

5.1 Third-Party Service Providers

We share information with trusted partners who assist us in operating our Services

• Payment Providers
• Banking Partners: For fund transfers and settlements
• Cloud Services: For data storage and hosting
• Analytics Providers: For service improvement
• Customer Support Tools: For responding to inquiries
• Security Services: For fraud detection and prevention

All third parties are contractually obligated to maintain confidentiality and security.

5.2 Legal Requirements

We may disclose information when required by law:

• In response to subpoenas or court orders
• To comply with regulatory requirements
• To report suspicious transactions to authorities
• To protect our rights and safety
• To prevent fraud or criminal activity

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

5.4 With Your Consent

We may share information with other parties when you explicitly consent.

6. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries outside the UAE. We ensure adequate safeguards through:

• Standard Contractual Clauses
• Adequacy decisions
• Appropriate technical and organizational measures

7. DATA RETENTION

We retain your information for as long as:

• Your Account is active
• Required to provide Services
• Necessary for legal and regulatory compliance (typically 7 years for financial records)
• Needed to resolve disputes or enforce agreements

After retention periods expire, we securely delete or anonymize your data.

8. YOUR RIGHTS

Depending on your jurisdiction, you may have the following rights:

8.1 Access and Portability

• Request a copy of your personal data
• Receive your data in a structured, machine-readable format

8.2 Rectification

• Correct inaccurate or incomplete information
• Update your Account details

8.3 Erasure ("Right to be Forgotten")

• Request deletion of your data (subject to legal retention requirements)

8.4 Restriction

• Limit how we use your information

8.5 Objection

• Object to processing based on legitimate interests
• Opt-out of marketing communications

8.6 Withdraw Consent

• Withdraw previously given consent at any time

8.7 Complaints

• Lodge a complaint with your local data protection authority

To exercise your rights, contact us at: order@dubapays.com

9. DATA SECURITY

We implement industry-standard security.

10. COOKIES AND TRACKING TECHNOLOGIES

10.1 Types of Cookies We Use

Essential Cookies: Required for Services to function (session management, security)

Functional Cookies: Remember your preferences and settings

Analytics Cookies: Help us understand usage patterns (Google Analytics, etc.)

Marketing Cookies: Track effectiveness of promotional campaigns

10.2 Managing Cookies

You can control cookies through your browser settings. Note that disabling essential cookies may affect functionality.

11. CHILDREN'S PRIVACY

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect information from children. If you believe we have collected data from a child, please contact us immediately.

12. THIRD-PARTY LINKS

Our website may contain links to third-party sites. We are not responsible for the privacy practices of these external sites. Please review their privacy policies.

13. DO NOT TRACK SIGNALS

Our Services do not currently respond to "Do Not Track" browser signals, as there is no industry standard for compliance.

14. UPDATES TO THIS POLICY

We may update this Privacy Policy periodically. We will notify you of material changes via:

• Prominent notice on our website

Continued use of Services after changes constitutes acceptance.

15. CONTACT INFORMATION

Data Protection Officer / Privacy Inquiries:

DubaPays
Unit No: BA2337
DMCC Business Centre
Level No 1
Jewellery & Gemplex 3
Dubai, United Arab Emirates

Email: order@dubapays.com

For privacy-related requests, please include:

• Your full name
• Account email address
• Description of your request
• Proof of identity (for security purposes)

16. CONSENT

By using our Services, you consent to the collection, use, and sharing of your information as described in this Privacy Policy.