Huru Privacy Policy

This privacy policy (the "Privacy Policy") applies to you on your use of the application of Huru Payment Services Provider L.L.C. (referred to as "Huru") (as available on the Google Play Store or the Apple App Store) and/or the website of Huru (collectively referred to as the "Platform"). Please note that the terms "we", "our", and "us" refer to Huru, and the terms "you", "your", and "user" refer to you as the user of the Platform. If you are not a user of the Platform, this Privacy Policy would not apply to you or your affiliates or any party accessing the Platform through you. The terms of this Privacy Policy are applicable to you for accessing our various services (the "Services") as detailed in our 'Terms of Use' document that can be accessed through the Platform and is available at https://www.huru.co/terms.

Introduction

You hereby agree and confirm that by availing of the services on the Platform, you have explicitly consented to the terms of this Privacy Policy and/or the Terms of Use. Huru is a payment services provider licensed by the Central Bank of the UAE to offer services in line with the Stored Value Facility (SVF) & Category 2 of the Retail Payment Services Card Scheme (RPSCS) Regulations. We understand the significance of safeguarding your personal information, and please be assured that our commitment to ensuring the privacy of your personal information is unwavering. Our Privacy Policy aims to ensure that your sensitive personal information remains secure and confidential. You can trust us to handle your personal information (as defined hereafter) with utmost care, robust security measures and industry best practices. With Huru, you can enjoy the Platform's features and functionalities with ease, knowing that your personal information and privacy are treated with the seriousness they deserve.

This Privacy Policy is prepared in alignment with the Central Bank of the UAE's Consumer Protection Regulation and Standards, as well as Federal Decree Law No. 45 of 2021 Regarding the Protection of Personal Data ("UAE Data Protection Law"). We are committed to protecting your data and ensuring transparency in our data processing activities.

User Consent and Rights

1. By using this Platform, you consent to the collection, storage, usage, and processing of your personal information by us following this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use or continue using this Platform.
2. You have the right to withdraw your consent at any time by contacting us, and we will take the consequent reasonable measures. Please note that once you withdraw your consent to this Privacy Policy, we may be unable to provide you with the ongoing Services availed by you.
3. Notwithstanding anything in this clause 2, we may be required to retain your personal information to comply with necessary applicable legal or regulatory obligations, including those mandated by the Central Bank of the UAE and the UAE Data Protection Law.

Your Rights under UAE Data Protection Law and Consumer Protection Standards:

Following Federal Decree Law No. 45 of 2021 Regarding the Protection of Personal Data, you have the following rights concerning your personal information:

• Right of Access: You have the right to obtain information on the categories of Personal Information being processed, the purpose of the processing, the decisions made upon automated processing, and entities with whom the Personal Information is shared.
• Right to Request Personal Information Portability: You have the right to receive your Personal Information in a structured and machine-readable format.
• Right to Rectification or Erasure of Personal Information: You have the right to rectify inaccurate Personal Information and the right to delete your Personal Information and be forgotten, subject to provisions of applicable law and terms of this Privacy Policy.
• Right to Restriction of Processing: You have the right to restrict and stop the processing of your Personal Information upon receiving the request from you, where it is inaccurate, or you would object to the purpose of the processing of the Personal Information.
• Right to Object to Processing and Automated Processing: You have the right to object to automated decisions made to your Personal Information.
• Right to Complain to the Relevant Data Protection Authority: You have the right to complain to the relevant data protection authority in case of any contravention of any of the legal provisions of the applicable Data Protection Law.

To exercise any of these rights, please contact us at help@huru.co or dpo@huru.co for grievances on the usage of personal information.

Collection of Personal Information

1. By accessing or using the Platform, you consent to provide us with your personal information and agree to the terms of this Privacy Policy.
2. We may collect and receive personal information as outlined below from you when you access our Platform, register for your account (if applicable) with us or when you access the services of an external third-party service provider via the Platform.
3. We may monitor the use of the Platform through the use of certain tracking mechanisms. This information helps us to build your profile, make the Platform user-friendly and render better Services to you.
4. We may collect the following personal information, including but not limited to, from you:
   • a. Login Information: Details of your name, mobile number, email address, application pin, fingerprint or any information we may ask of you at the time of sign-up and/ or Login to the Platform.
   • b. Transactional Information: Details of the recipient/beneficiary, such as the recipient/beneficiary's name, address, national ID, bank account details, card number, wallet address or any other information that may be required at the time of the transaction. If we determine necessary, at our sole discretion, we may also request and collect additional information from third-party entities. For instance, obtaining credit-related information from a credit bureau (to the extent permitted by applicable law) or verifying the identification details provided by you.
   • c. Identity Information: Details of date of birth, gender, relevant Emirates ID, employment status (including but not limited to company name, segment, designation, monthly income, sponsor details, monthly transaction volume), United Arab Emirates (UAE) residential address, passport details, liveness test or any other information that may be required at the time of identity verification for KYC compliance.
   • d. Device Information: Details of device attributes and identifiers, plugins, name of your mobile operator or ISP, SMS, device make, device model, device language, time zone, geographic location, IP address, connection speed, device application, contact list, or any information available on such device.
   • e. Installed Applications and Device Security Data: To protect customers from fraud, malware, and account compromise, the Huru mobile application may collect limited information about the applications installed on your device, including application package names and metadata required to identify potentially harmful applications. This information is used exclusively for detecting malicious or fraudulent applications, identifying device compromise risks, preventing unauthorised access to Huru accounts, and improving fraud detection and risk scoring systems. Huru does not access the content, messages, files, or personal data within other applications installed on your device, and the collection of installed application information is conducted solely for security and fraud prevention purposes, not for advertising, analytics unrelated to security, or marketing.
5. You acknowledge that it is your responsibility to ensure that your personal information is always accurate, complete, and up-to-date. We will also make reasonable efforts to allow you to request corrections to your personal information if it is found to be inaccurate.
6. You acknowledge that you are aware that you can request the deletion of your personal information, subject to applicable law. However, we reserve the right to reject deletion requests that contravene the terms of this Privacy Policy or any relevant applicable laws, including those on AML/CFT obligations and consumer protection. We or the third party service provider, subject to applicable law, may also decline requests that require disproportionately extensive technical efforts, endanger the privacy of others, or are highly impractical.

Usage of Personal Information

1. The personal information collected will be used to enable you to use the Services provided by us, help promote a safe experience of the Services availed by you, calibrate consumer interest in Services, inform you about promotional offers and new updates, troubleshoot problems, customize your user experience, detect and protect us against any error, fraud and other criminal activity, collect money, enforce our Service usage terms and conditions, and any such other purpose as described to you at the time of collection of such personal information.
2. The personal information collected will also be used for internal record-keeping purposes, to process billing and payment, including sharing of such information with third-party service providers in connection with the Services.
3. You agree and acknowledge that we may periodically send emails and SMSs on the email address and mobile number you provide regarding transaction updates, notifications, alerts on action taken on Platform, information on new products or services, special offers from us or other information about us that we think would be relevant in enhancing your user experience on Huru.
4. We may use your personal information to assist law enforcement agencies, respond to subpoenas, prevent fraudulent transactions, monitor against theft and criminal activity, and protect the rights, safety, and property of the Platform. Your information helps us to prevent you from fraudulent transactions, monitor against theft, and protect against criminal activity within the Platform, safeguarding the rights, safety, and security of users.
5. You hereby understand and confirm that by accepting the terms of this Privacy Policy, you explicitly authorise us with your own free will and choice to permit us to deal with your personal information for the provision of the Services to you.
6. You agree and confirm that your personal information may be processed, shared, and/or provided to third parties to fulfil the services offered by Huru. This sharing of your personal information will be limited to what is necessary to deliver the products and services provided by Huru.
7. You hereby agree that if it is unclear how your personal information is being used, you will have the option to discontinue accessing the Platform and/or using the Services.
8. You hereby agree that you have decided to avail the Services on your own volition without any undue pressure or influence from anyone representing/associated/affiliated with us.
9. In case of any grievance regarding the usage of personal information, feel free to contact us at dpo@huru.co.
10. You hereby agree and confirm that the limited data, as mentioned in this clause 4, will be stored for a minimum period of 5 years after you end your relationship with us, or for a longer period as required by applicable laws and regulations, including those related to AML/CFT.
11. You hereby agree and confirm that you are aware that you have the right to end your association with the Platform and with us and to ensure that the limited data provided to us is erased, subject to applicable law.
12. Please note that you may end your relationship with us by way of explicitly requesting us to delete your account with us by following the steps as indicated by Huru once we receive your account closure request.

Sharing and Disclosing of Your Personal Information

1. Disclosure: We will disclose or share your personal information, without notice, for the primary purposes for which it was collected under the terms of this Privacy Policy, including, without limitation:
   • a. Where you have consented to such disclosure or sharing without limitation by consenting to the terms of this Privacy Policy;
   • b. Where permitted under the applicable law and relevant data protection laws, including the UAE Data Protection Law. For this Privacy Policy, the UAE Data Protection Law in Article 2 has defined personal data (which may include "personal information") as "any information that relates to an individual and by which that individual can be identified, directly or indirectly, including, but not limited to, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual";
   • c. Where it is necessary to protect and defend the rights or property of Huru, our third-party service providers, and/or our other vendors in connection with the Services;
   • d. Where it is necessary to act under exigent circumstances to protect the personal safety of other users on the Platform, or the general visitors visiting the Platform;
2. Sharing your personal information with Service Providers/Partner: We work with certain third-party service providers and/or partners to execute various functionalities of the platform and to provide the relevant services. We may share your personal information with such third-party service providers and/or partners to ensure a better customer experience of the Platform. We ensure that such third parties are contractually obligated to protect your data under this Privacy Policy and applicable UAE laws.
3. Sharing your personal information with group companies: Subject to applicable law, we may share any data, including personal information that we collect from you, with our group companies for product research and development, for making our Services better, and tailoring the Platform for your benefit. We will not use any of your personal information for upselling and/or cross-selling without your prior consent.
4. Sharing your personal information with law enforcement agencies as and when needed: We will share your personal information, without prior notice, on a request from any competent governmental authority or a court of competent jurisdiction or law enforcement agencies that we find appropriate or necessary to comply with applicable law, including AML/CFT regulations.
5. Sharing your personal information during a change of our business: In the event of a reorganization, material financing event (as decided by us), material investment activity, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any of our business, assets or stock, or bankruptcy or similar proceedings, you hereby agree and confirm that we retain the right to enable your personal information to be shared or transferred, subject to standard confidential agreements and compliance with applicable data protection laws.

Storage, Processing and Retention of Personal Information

1. Personal information collected by us may be stored and/or processed in the UAE, where we or third-party service providers maintain the relevant infrastructure. We will also be entitled to use Amazon Web Services to store your Personal Information. The storage location(s) are chosen to operate efficiently, improve performance, and reduce the probability of errors for protecting your personal information in the event of an outage or other problems. We take steps to ensure that the personal information we collect is processed according to the provisions of the terms of this Privacy Policy and relevant UAE data protection laws.
2. We may retain your personal information for a minimum period of 5 years after you have ended your relationship with us as indicated in Clause 4.15 above, or for a longer period as required by applicable laws and regulations, including those related to Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) obligations as mandated by the Central Bank of the UAE.
3. We will cease to retain your personal information or decide how the data would be associated with you as soon as it is reasonable to assume that such retention (as indicated in Clause 6.2 above) no longer serves the purpose for which the personal information was collected and is no longer necessary for legal or business purposes subject to applicable laws.

Minimum Age Requirement

Please note that you must be aged 18 years or older to use the Services. If we have accidentally obtained any information from you and you are under the age of 18 years, please inform us immediately.

Data Security

1. All data is securely hosted on third-party servers like Amazon Web Services.
2. We employ industry-standard data security practices to keep your personal information safe from cyberattacks and threats, in line with the requirements of the UAE Data Protection Law and the Central Bank of the UAE's Consumer Protection Standards.
3. We undertake periodic assessments of the platform’s safety and security practices.
4. We strive to maintain the security and safety of your personal information in line with industry standards. Once we have received your information or personal information, we use strict procedures and security features as per industry standards and the relevant data protection laws to try to prevent unauthorised access, loss, misuse, unauthorised disclosure and dissemination, destruction and alteration of your personal information.
5. Steps taken to ensure personal information security:
   • a. You are responsible for keeping your credentials for accessing the Platform confidential. You should not share your password/application PIN or login details with anyone. We will not be responsible for any liability or obligation you may face if you share your confidential account details with anyone.
   • b. While we sincerely strive to protect your Personal Information, we cannot guarantee its security, or warrant that no harmful code will enter the Platform (including but not limited to viruses, bugs, trojan horses, spyware, malware, forks or adware). Transmission of information through the Internet is not completely secure. You should be aware of the risks associated with disclosing any information or transacting over the internet or when using online portals. We urge you to take every precaution when using the internet to disclose your Personal Information to us, including using a strong password/App PIN and changing your password/App PIN regularly. You agree and acknowledge that any information you provide us is at your own risk and discretion.
   • c. You agree to immediately notify us if you discover or otherwise suspect any security issues related to any of our Services or your account. You can contact us at help@huru.co.

Third Party Services and Links

The Services offered on the Platform are either provided directly by us or through third-party service providers. Use of such third-party services will be subject to your compliance with any additional terms and conditions and privacy policy applicable to such services. You acknowledge and accept that we will not be responsible and will have no liability for any default or breach of the terms of third-party services and any policies. Further, you accept and acknowledge that the third-party service providers will be solely responsible for the provision of such third-party services, and you shall have no right against us for any act or omission of such third-party service providers.

The Platform may contain links to or information about third-party websites that are not within our control. We are not responsible for the data privacy practices of any external third-party website or platform. You hereby agree that we are not liable in any manner, whatsoever, for any content as may be displayed on such third-party websites. Such links do not constitute an endorsement by us of those external websites. You acknowledge that we are providing these links to you only as a convenience, and further agree that we are not responsible for the content of such external links. If you follow a link to any third-party websites or platforms, please note that we do not accept any responsibility or liability for the same. Please check the relevant policies before you submit any information to these websites, platforms, or their affiliates.

Certain Services available through the Platform may include materials from third-party entities. We are not responsible in relation to such third-party content, products and services. We shall not be responsible for examining or evaluating the content or accuracy, and further, we do not warrant and will not have any liability or responsibility for any third-party materials or websites. Please review carefully the third party’s policies and practices and make sure you understand them before you engage in any transaction. Complaints, claims, concerns, or questions regarding third-party services shall be directed to the third party.

Restricted Jurisdiction

You agree that the intended recipient/beneficiary shall not be a citizen or resident of a geographic area in which access to or participation in such Service is prohibited by applicable law, decree, regulation, treaty, or administrative act. This aligns with our commitment to international sanctions and AML/CFT compliance.

Changes to this Privacy Policy

Notwithstanding anything contained in the terms of this Privacy Policy or the terms of any other contract with you, we reserve the absolute and unconditional right to update, modify, delete, or otherwise make changes to the terms of this Privacy Policy at any time. Any changes to this Privacy Policy will be reflected in the Platform and will be notified to you from time to time as applicable. You can determine when this Privacy Policy was last modified by referring to the “Last updated on” legend at the beginning of this Privacy Policy. It shall be your sole responsibility to check this Privacy Policy periodically for changes, if any. Any changes to this Privacy Policy will take effect and be binding on you from the time of posting the changes to the Platform. If you continue to use any Services following any changes to this Privacy Policy, you will be deemed to have accepted the changes to the terms of this Privacy Policy and the updated version of this Privacy Policy. If you do not agree with the changes to the terms of this Privacy Policy, please refrain from using our Platform. It is your responsibility to review this Privacy Policy (and the applicable conditions) from time to time. If any provision of this Privacy Policy shall be held to be invalid, illegal, or unenforceable for any reason whatsoever, the invalidity, illegality, and enforceability of the remaining terms of this Privacy Policy shall not in any way be affected or impaired thereby.

Complaints

If you wish to complain about how we process data, please write to us at help@huru.co. We will endeavour to respond to your complaints as soon as reasonably possible, in line with the Central Bank of the UAE's consumer protection regulations.

Contact

Questions, comments and requests regarding the terms of this Privacy Policy are welcome and should be addressed to help@huru.co. with the subject line “Query on Privacy Policy”.