This policy, Version 1 is effective from November 29, 2022

1.1  Foreword

Wadiaa is a Fin-Tech services platform providing services in the financial services sector across select geographies. This Privacy Policy outlines Wadiaa’ s commitment to respecting and ensuring the privacy of our users and our privacy practices therefrom, including the collection, processing, and disclosure of information about users of our websites, including wadiaa.com, our apps and our associated services (collectively, referred to as our “site” and “services”).

This Privacy Policy is intended to describe to you what information we collect, how we collect it, as well as how and why we use your personal data when you use our site and services. It also describes options we provide for you to access, update, or otherwise take control of your personal information that we process. We will not use or share your information with anyone except as described in this Privacy Policy.

This Privacy Policy applies to all users of our site and services. A “user” refers to any of the following:

1. visitors of Wadiaa’ s websites, collectively, the “Wadiaa Platform,”
2. individuals who interact with Wadiaa or its services as defined below, and
3. individuals who create an account on the Wadiaa Platform, including “Fundraisers” and “Investors” (collectively, the “Users”).

By using our site and services, you acknowledge you have read and understood this Privacy Policy and our practices described below. Your registration on Wadiaa signifies your irrevocable consent to Wadiaa processing and retaining your personal data in accordance with the following terms and conditions.

Your use of our site and services is also subject to our General Terms of Use. Please note that any user information shared with one of our entities may be shared among our service partners, for and towards the performance of the services contracted by Wadiaa.

1.2  Definitions

• Personal Data: Refers to any information that is personally identifiable, including sensitive personal data or expression of opinion that relates directly or indirectly to a subject under consideration as part of a service or transaction initiated on the Wadiaa platform by the individual or initiated by a representative of the organization that the individual is affiliated to. This includes personal information, transactional history, and device information.
• Personal Information: Personal information includes information from which you may be identified both directly (from that information alone) and indirectly (when different pieces of information are combined) This includes, but is not limited to, information such as your full name, address, email, copies and details of identification documents (such as passport, national, resident, taxpayer identification or driver’s license), contact information, address proof (as obtained from bank statements, utility or telecom bills), gender, details of bank account, employment history, credit and references check, marital status, commission or alleged commission of offence, personal financial and social security detail, company, designation, location, password for the Wadiaa platform and any other information provided at the time of registration or at the time of accreditation or service request or delivery.
• Transaction History: Includes any and all information related to service requests, transactions, number of transactions and related date, time and value for services initiated or provided by the Wadiaa platform.
• Device Information: Includes and is not limited to information pertaining to the type of communication device used to access the platform and its services, such as device type, operating system, browser used, IP address, access details such as location or online traffic data, resources utilized, advertisements, linked websites accessed from the Wadiaa platform and other information obtained from cookies used by the platform.
• Collect: In this regard, the acts by which personal data enters or comes under the control of Wadiaa and its representatives.
• Disclosure: In this regard, the acts by which personal data is made available by the Wadiaa platform to authorized service providers in relation to service delivery or to regulatory bodies and their representatives in response to requests received  from authorized persons.

Processing: In this regard, the acts by which personal data collected from you is used to identify you as a qualified user or your organization as a qualified entity for provision of services. This may include checking information on law enforcement databases, international anti-money laundering or sanctions watchlists and ascertaining if you are qualified as per regulatory and legal guidelines for service on our platform. The data may also be used to ascertain eligibility to enhanced services and enhanced investment thresholds on our platform. The personal data collected may be processed through contracted third-party platforms that specialize in KYC, KYB and sanctions checks.

2.1  Information Collection

• We may collect and process personal information about you so that we can provide an exceptional experience when you utilize our site and services.
• Much of the Personal Information is collected from you at the time you use our Website and register for a User Account with us.
• Some of the information collected include your name, date of birth, email address, postal address, mobile number, phone number, bank details, and in the case of businesses, we will collect information about you in connection with your business registration and shareholder information.

2.2  Information Collection Events

• The events upon which personal information is collected include among others:

1. Creating a User Account with us
2. Providing written information, including by email.
3. Providing oral information by telephone (we may keep a record of the information you share with us)
4. Requesting assistance from a member of our staff.
5. Provide contact forms or request newsletters or other information from us.
6. Participate in surveys, or activities we promote that might require information about you.

2.3  What data we collect

• We collect additional information which may not be as obvious to you, to optimize our service delivery. These vary from time to time, depending on how our service is delivered. These can include:

1. Account related information collected in association with your use of our site and services, such as account number, information requests, customer service requests, notes or details explaining your request and how we responded.
2. Cookies and similar technologies on our Websites allow us to track your browsing behavior, links clicked, your device type, and other usage and interaction data, including analytics. This allows us to provide you with an improved user experience on our site, and to collect, analyse and improve the performance of our services. We may also collect your location (IP address) so that we can personalize our services.

1. Data about usage of services is automatically collected when you use and interact with our services, including metadata, log files, cookie/device IDs and location information.
2. Information about your interactions with the features, content and links including those of third parties, such as social media plugins contained within the services, Internet Protocol (IP) address, browser type, operating system and settings, the date and time of services used.
3. Information about browser configurations and plugins, language preferences and cookie data, information about devices accessing the services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and error data, and information capable of location approximation.
4. Supplemented Data may be received about you from other sources, including publicly available databases or third parties from whom we have purchased information, in which case we may combine this data with information we already have about you so that we can update, expand and analyse the accuracy of our records, identify new customers, and provide services that may be of interest to you.
5. Personal Information about others, when provided by you, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

3.1  Use of Your Information

• We collect summary data on usage and user interactions for analysis and service improvement. Much of these do not have personally identifiable information. However, where such personally identifiable data is collected, we follow the controls as outlined herein.
• We limit the use of Personal Information to only that for which we have been given permission and deemed as necessary to deliver the services you need, or as we might be required or permitted for legal compliance or other lawful purposes such as delivering, improving, updating, and enhancing services we provide to you.
• We collect information relating to your use and/or interactions with our services. We use this information to:

1. Improve and optimize the operation and performance of our services (again, including our Website)
2. Diagnose problems with and identify any security risks, errors, or needed enhancements to services
3. Detect and prevent fraud and abuse of our services and systems
4. Collect aggregate statistics about use of the services; or
5. Understand and analyse how you use our services and what services are most relevant to you.

4.1  Sharing with Third Parties

• We may share your Personal Information with trusted affiliate companies with whom we have partnered and integrated with to allow seamless service delivery.
• Trusted third-party service providers are necessary for them to perform specialized services on our behalf, such as:

1. Processing credit card payments
2. Performing analysis of our services and customers demographics
3. Communicating with you, such as by email or SMS delivery
4. Customer relationship management.
5. Conducting surveys

• We only share your Personal Information as necessary for any third-party to provide the services as requested or as needed on our behalf.
• These third parties (and any subcontractors) services are governed by clear and strict controls including adherence to international standards and are subject to strict data processing terms and conditions.
• These trusted third parties are prohibited from utilizing, sharing, or retaining your Personal Information for any purpose other than as they have been specifically contracted for and as governed by the permissions you have provided us with.

4.2  Communicating with You

• We may contact you directly or through a third-party service provider regarding services you have signed up from us, such as and as necessary to deliver transactional or service-related communications.
• We may also contact you with offers for additional services we think you will find valuable if you give us consent, or where allowed based upon legitimate interests. You do not need to provide consent as a condition to purchase our services. These contacts may include:

1. Email
2. Text (SMS) messages
3. Telephone calls
4. Automated phone calls or text messages.

• You may also update your subscription preferences with respect to receiving communications from us and/ or our partners by signing into your User Account and visiting “Account Settings” page.

4.3  Legal & Regulatory Compliance and Law Enforcement

• We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process, to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical.
• To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your Personal Information to third parties as part of a legal process.

4.4  Third-Party Websites 

• Our Website may contain links to third-party websites. We are not responsible for the privacy practices or the content of third-party sites.
• Please read the privacy policy of any third-party website you visit.

4.5  How We Protect Your Information

• Keeping your Personal information protected is important to us. We have put strict measures in place to safeguard the integrity of your Personal Information, including utilization of encryption where appropriate. Despite using this technology, we cannot guarantee the security of your Personal Information that you disclose to us. In using our Website, you accept the inherent risks of providing information and engaging in transactions online over the internet, and you will not hold us responsible for any breach of security, unless this is due to our negligence or willful default.

4.6  How We Store, Process and Retain Your Information:

• We follow generally accepted standards to store, process and protect the Personal Information we collect, both during transmission and once received and stored, including utilization of encryption where appropriate.
• Your Personal Information will be stored at or processed in the Sultanate of Oman. It may also be processed by staff operating outside Oman who work for us or one of our suppliers. Such staff may be engaged in, among other things, the provision of support services.
• We retain Personal Information only for as long as necessary to provide the services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods:

1. mandated by law, contract, or similar obligations applicable to our business operations
2. for preserving, resolving, defending, or enforcing our legal/contractual rights; or
3. needed to maintain adequate and accurate business and financial records.

• If you have any questions about the security or retention of your Personal Information, you can contact us at enquiries@wadiaa.com.

4.7  Changes to Our Privacy Policy

• We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and any other places we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make material changes to this Privacy Policy, we will notify you by email, or by means of a notice on our home page.