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Privacy Policy

Version 1.0 Last Modified: 11th April 2022

This privacy notice (“Notice”) describes the manner in which Appro Onboarding Solutions FZ-LLC (“Appro”, “we”, “our”, or “us”), may collect use store disclose or otherwise process Personal Data of its (i) current and former visitors to the Website, (ii) Users (including his/her/its Authorized Representative) and/or (iii) directors or owners, as applicable (“you”, “your”, or “user”), including Personal Data in the context of your application for, or access and use of, the Mobile App, the Website and/or the Appro Services, and the steps we take to protect such information. By entering into the Terms and Conditions and/or by using the Mobile App, accessing the Website, providing any User Data and/or using the Appro Services, you hereby agree to the terms of this Notice and provide your consent to our use and disclosure of your Personal Data (including any Sensitive Personal Data) in accordance with this Notice. This Notice is incorporated into and subject to the Terms and Conditions available at appro.ae Further, if you are accessing the Appro Services through the Mobile App, then while this Notice shall apply to such use, there may be privacy terms (such as the terms imposed by mobile application stores like App Store (iOS), Android’s (Google) Play Store, Microsoft’s store, Amazon’s Appstore, Huawei AppGallery from time to time) which will govern the use of the Mobile App. Appro is committed to maintain the confidentiality, integrity and security of all information of our Users. It is important to read the entire Notice along with our Terms and Conditions carefully as some of the provisions affect your legal rights and obligations. Any term that is capitalised herein and not defined in this Notice shall have the meaning given to it in the Terms and Conditions available at appro.ae


Frequently Asked Questions

1. Definitions

Account” means the account created by the User on the Website or Mobile App after successful completion of registration.

Appro Services” means the service of providing the Website, the Mobile App and the Platform which facilitates (i) the pre-processing and filtration of applications for retail lending products; and (ii) such other services that may be provided by Appro on the Platform from time to time.

Authorized Representative” means the employee or authorised representative of the User who is specifically authorized to register on the Website on behalf of the User to apply for the Appro Services.

CIC” means a credit information company that has been granted a certificate of registration under the respective jurisdiction in which it is incorporated, including but not limited to the United Arab Emirates credit bureau (“AECB”).

“Credit Information” means collectively the information you provide to us in the online application which pertains to your financial background and such other information obtained from the CIC.

Mobile App” means the mobile application belonging to Appro, which is developed and designed to run on various mobile operating systems, for providing the Appro Services.

Partner” means third party partners of Appro from whom Appro may obtain certain services in relation to the Website including but not limited to the CICs, verification companies, information repositories, data analytics providers, payment gateways etc. to provide the Appro Services.

“Platform” means the digital platform which currently is in testing stage and accessible to a closed set of users operated and maintained by Appro, the front-end version of which is accessible through the Website and Mobile App.

Personal Data” is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank details, email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, employment information and financial information.

Sensitive Personal Data (SPD)” means data pertaining to your race, national ID information, religious beliefs, background information (including financial and criminal records, where legally permissible), health data, disability, marital status and biometric data, as applicable.

Third Party Service Providers” means service providers including banks, credit bureaus, service providers and logistics providers.

Usage Information” means information that we automatically collect about how you access and interact with the Appro Services.

User” means any individual/organisation (as the case maybe) registered on the Website for using the Appro Services.

User Data” means any data submitted by the User or the Authorized Representative on behalf of the User, to us or in relation to the Appro Services.

Website” means the domain https://appro.ae/ and/or the Mobile App.

2. Personal Data We Collect

2.1 User-Provided Information: This Notice applies to User Data collected from you and/or from our Partnersin relation to you, such as details pertaining to your name, parentage, nationality, state/city of residence, residential address, e-mail address, date of birth, gender, contact number/mobile number, user IDs, passwords, net banking credentials, bank account details, recent photograph, signature image, income proof, credit score, Credit Information report, and other Know Your Customer ( KYC) documents including identity and address proof, driver
license or other government issued identity proof, which may be shared/ uploaded by you, as and when you avail any Appro Services, and to which Appro may become privy to.

2.2 Information We Automatically Collect: In addition to information, you provide to us, we may collect certain information about how you access and interact with the Appro Services (“Usage Information”). This Usage Information is a key part of how we improve your experience on our Website and Mobile App and enables us to provide you with more personalized services.

We may use various technologies to collect and store such Usage Information in connection with the Appro Services. These may include things like cookies, browser web storage (e.g., HTML5), web beacons and similar technologies. There are three types of Usage Information we may collect:

(a)    Device Information. This is information about how you access Appro Services, such as the operating system, hardware model, application or browser type and version, and unique identifiers associated with your device.

(b)    Log Information. There are certain pieces of information we collect in system logs or similar files about how you interact with Appro Services, such as which features you visit or click on. This Log Information may also include things like your IP address, browser or device configuration, date and time of access and cookie information.

(c)    Location Information. We may use certain information like your IP address or other Device Information or Log Information to estimate your location (e.g. your city or tate). We may also request to use location-enabled services on your device (which typically provide GPS or Wi-Fi access point details) to enhance our services. We will only use these location-enabled services on your device with your consent, though.

2.3 Third Party Web Beacons and Third Party Buttons: We may display third-party content on the Website or Mobile App, including third-party advertising. Third-party content may use cookies, web beacons, or other mechanisms for obtaining data in connection with your viewing of the third party content on the Website. Additionally, we may implement third party buttons (such as “like” or “share” buttons, social media buttons, etc.) that may function as web beacons even when you do not interact with the button. Information collected through third-party web beacons and buttons is collected directly by these third parties, not by Appro. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.

2.4 Information from Other Sources: Many of our features rely on information about you that we collect from Partners and Third Party Service Providers, such as information pertaining to you in relation to your Credit Information, corporate information, etc. from the records maintained by governmental authorities or our Partners.

2.5 Personal Data requested by Appro is usually necessary for the provision of a service or product to you, or your use of the Mobile App and/or the Website. If you do not provide us with your Personal Data needed to meet our legal and regulatory obligations and/or to enter into an agreement with you we may not be able to provide you with the products or services you have requested.

3. Consent

3.1 By providing your consent to our processing of your Personal Data in accordance with this Notice you hereby acknowledge and agree that you are providing your consent to Appro (including its marketing channels, Partners and Third Party Service Providers) to contact you through SMS, telephone, e-mail, push notifications, social media and/or other channels that may be used for communication from time to time and with follow-up communication in relation to the Appro Services, for imparting product knowledge, offering promotional offers running on the Website, and various other offers offered by the Third Party Service Providers or Appro.

3.2 The usage of the Website may also require you to provide consent for keying in/ uploading your User Data (including but not limited to user IDs and passwords), as may be necessary to process your application through the Platform. Any User Data which requires to be keyed in/ uploaded is required for enabling hassle free, faster and paperless (to the extent possible) processing of applications for Appro Services availed to you.

3.3 You hereby authorize and expressly provide consent for us to share your User Data with third parties including but not limited to Partners including CICs, and Third Party Service Providers.

3.4 Appro reserves the right (and you expressly authorize Appro) to share or disclose your User Data when Appro determines, in its sole discretion, that the disclosure of such information is necessary or appropriate under applicable laws.

3.5 We may use certain systems and services to process your information, which will provide us with an automated decision on whether or not to continue to provide Appro Services to you. For example, when processing your application, we are required to conduct certain checks (such as, know your customer checks and credit worthiness checks) the system we use to do this will provide us with an automated result and we will base out decision on that result. By signing up for the provision of Appro Services, you consent to our use of automated decision making as described in this paragraph.

3.6 We may use profiling, including behavioural analysis, to assist us to provide you with better services, to make decisions and to prevent money laundering, terrorism, fraud and other financial crime. If any profiling will result in an automated decision relating to you, we will let you know and you will have the right to discuss the decision with us.

3.7 You have the right to withdraw your consent to the use of your Personal Data at any time. Any such withdrawal of consent will not affect the lawfulness of Personal Data processing that occurred prior to such withdrawal or any subsequent processing related to Appro’s business operations. Please refer below to Section 7 [Your Privacy Choices] for further information on withdrawal of consent.

4. Credit Information Reports

4.1 Your Credit Information is procured from AECB, Appro has no control over the content or accuracy of information provided in your Credit Information by AECB. Appro receives this information from a AECB once you provide authorization/ consent in a template provided and incorporated into the Terms and Conditions to appoint Appro as your lawfully appointed authorized agent/ representative for receiving your Credit Information.

4.2 By authorizing us to receive your Credit Information report, in accordance with clause 4.1 above, you agree that Appro and AECB shall be entitled to rely on your authorization and consent granted by you to Appro.

4.3 Appro may analyze and use your Credit Information in order to provide Appro Services to you. Any derivative outputs so developed independently by Appro may be shared with Third Party Service Providers to enable them to provide you with the financial services you have applied for on the Website or Mobile App, and you hereby consent to such access by Third Party Service Providers of your Credit Information including your Personal Data and SPD.

5. How We Use the Personal Data We Collect

We use the User Data for the following purposes and in a variety of ways in providing the Appro Service and operating our business, including the following:

5.1 To operate, maintain, enhance and provide all features of the Appro Service, to provide services and information that you request, to respond to comments and questions and otherwise to provide support to Users, and to process and deliver entries and rewards in connection with promotions that may be offered from time to time on the Website.

5.2 For training and quality monitoring.

5.3 To access your Credit Information from the CIC on your behalf and create our independent derivative outputs from such Credit Information for the provision of Appro.

5.4 To understand and analyze the usage trends and preferences of our Users, to improve the Appro Service, and to develop new products, services, features, and functionality.

5.5 To contact you for administrative purposes such as customer service or to send communications, including updates on promotions and events, relating to products and services offered by us and by third parties and you hereby consent to receiving such communications by agreeing to these terms.

5.6 We may use cookies and automatically collected Personal Data information to: (i) personalize the Appro Service, such as remembering information about you so that you will not have to re-enter it during your visit or the next time you visit the Website or use the Mobile App; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of the Appro Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of Users, features used, and pages viewed; and (v) track your interactions, submissions, status or other activities on the Platform. Please refer to our Cookie policy located on our website for additional information.

5.7 We will not retain information you provide for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force.

6. When We Disclose or Transfer your Personal Data

Except as described in this Notice, we will not disclose User Data to third parties except as otherwise detailed in this Notice. We may disclose information to third parties in the following circumstances:

6.1 For availing services from Users, Third Party Service Providers or Partners – We provide our Third Party Service Providers your User Data to enable them to provide certain services to you via the Platform, and to Partners in order to obtain information from them, as described in this Notice. We may share your SPD with our Partners and Third Party Service Providers. We may also provide your User Data to other Users to facilitate your transactions with such Users on the Platform.

6.2 When we collaborate with third parties to provide or improve Appro Services- We may work with other third parties to provide website and application development, hosting, maintenance, and other services for us. These third parties may have access to or process information about you as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.

6.3 As part of a corporate change – User Data maybe disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of any insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

6.4 Business or marketing purposes – We may make certain aggregated, automatically-collected, or otherwise non-personal information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Appro Service.

6.5 For legal reasons – We may disclose User Data if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

6.6 With your consent – There may also be other limited contexts in which we share specific types of User Data with your express consent.

7. Your Privacy Choices

7.1 You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Website, Mobile App and the Platform. However, please note that by applying for the Appro Services and accepting the Appro Terms and Conditions you are under a contractual obligation to provide such information to us so that we can provide the Appro Services to you. You may update, correct, or delete your User Data and preferences at any time by accessing your Account preferences page on the Website. If you wish to withdraw consent that you have given to this Privacy Notice or to the Terms and Conditions, you may contact us at support@appro.ae Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, where we otherwise reasonably believe that we have a legitimate reason to do so or there is a contractual obligation or legal requirement/obligation to retain/hold the information or otherwise permitted by applicable law to retain it.

7.2 Based on your provided consent, where you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt out from receiving commercial emails from us by sending your request to us by email at support@appro.ae. We may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us through the Account preferences page on the Website.

7.3 Where you opt out of receiving commercial emails from us or otherwise modify the nature or frequency of promotional communications you receive from us, we will aim to process such requests without undue delay and within ten business days. Additionally, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Appro Services you have applied or opted for.

7.4 You may choose to opt out of SMS promotional services as well. To opt out, send an SMS . Once you send the request, it may take up to 10 business days to process your request. Further, upon a request to opt-out of SMS communication, you will be able to opt out of only promotional messages. You will continue to receive transaction related messages.

8. Data Security

8.1 Appro has technical and organizational security measures in place to safeguard your Personal Data. We take all reasonable and appropriate measures to protect all collected Personal Data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data that we process and risks associated with Sensitive Personal Data we collect. We process Personal Data in a way that is compatible with and relevant for the purpose for which it was collected.

8.2 You should be aware that the transmission of Personal Data via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data including the risk of access and interference by unauthorized third parties; any transmission is at your own risk.

9. Data Transfers

9.1 Personal Data may be transferred to, or stored at, a location outside of the UAE, which may or may not have an adequate level of data protection compliance, as determined under applicable data protection laws. When we transfer your Personal Data, we will take such steps as are necessary in accordance with applicable data protection laws to ensure appropriate safeguards apply to maintain the same levels of protection as are needed under adequate data protection laws. We may do this through contractual provisions, including any required by a privacy regulator, and oversight of the Third Party Service Provider. Regardless of where Personal Data is transferred, we take all steps reasonably necessary to ensure that Personal Data is kept securely. The security of your Personal Data is important to us. When using external Third Party Service Providers, we require that they adhere to security standards mandated by Appro as well as have in place necessary technical and organizational security measures to safeguard your Personal Data.

10. Data Subject Rights

(a) Subject to applicable law, regulations and/or banking industry guidelines, you may have the right to invoke a data subject right in relation to your Personal Data being processed by Appro. The rights that you can invoke as a data subject may, depending on applicable law, include: Right of Access. You have the right to obtain information from Appro on the types of Personal Data that is processed; the purposes of processing; decisions made based on automated processing, including profiling; controls and standards for the periods of storing and retaining Personal Data; protection measures for cross-border processing etc..

(b) Right to Correction or Erasure. Except in very specific cases, where provided by applicable law, you have the right to request (without undue delay) the correction/rectification of inaccurate personal data concerning you and, you have the right to request the erasure of personal data concerning you (without undue delay) where one of the following grounds applies:

(i) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

(ii) you withdraw your consent on which the processing is based and there is no other legal ground for the processing;

(iii) you object to the processing and there are no overriding legitimate grounds for the processing;

(iv) the Personal Data have been unlawfully processed; or

(v) the Personal Data have to be erased for compliance with a legal obligation to which Appro is subject.

(c) Right to Restriction of Processing. Except in very specific cases, where provided by applicable law, you have the right to obtain from Appro restriction of processing where one of the following applies:

(i) you contest the accuracy of your Personal Data (in such a case, the restriction will be for a period enabling Appro to verify the accuracy of said data); or the processing is unlawful;

(ii) Appro no longer needs the Personal Data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; or

(iii) you object to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.

(d) Right to Data Portability. You have the right to the transfer of your Personal Data to another financial institution or financial service provider, upon your request and where the processing is based on your consent.

(e) Right to Stop Processing: You have the right to object to and stop the processing of your Personal Data in any of the following cases:

(i) if the processing is for direct marketing purposes, including Profiling related to direct marketing.

(ii) if the processing is for the purposes of conducting statistical surveys, unless the Processing is necessary to achieve the public interest; or

(iii) if the processing is not carried out in a fair, transparent and lawful manner and/or where Personal Data is collected for a specific and clear purpose, the processing of such Personal Data is not processed at any subsequent time in a manner incompatible with that purpose.

(f) Right to Object to Automated Processing. You have the right to object to decisions issued with respect to automated processing that have legal consequences or seriously affect you, including profiling except in the following cases:

(i) if the automated processing is included in the terms of the contract entered into between you and the data controller;

(ii) if the automated processing is necessary according to other legislation in force in the State; or

(iii) if you have given prior consent to the automated processing in accordance applicable law. 10.2 To invoke your data subject rights, please send an email to support@appro.ae

11. Confidentiality of Login ID and Password

11.1 You are responsible for maintaining the security of your login ID and password for your Account and must not provide these credentials to any third party. If you believe that they have been stolen or been made known to others, you must contact us immediately at support@appro.ae We are not responsible if someone else accesses your Account through the login credentials they have obtained from you or through a violation by you of this Notice or our Terms and Conditions.

12. Changes and Updates to this Notice

12.1 We may amend or update our Notice. Please revisit this page periodically to stay aware of any changes to this Notice, which we may update from time to time. We may provide you notice of material amendments to this Notice, as appropriate, and update the “Last Modified” date at the top of this Notice. Your continued use of the Appro Services after the effective date of an updated version of the Notice will indicate your acceptance of the Privacy Notice as modified. In some cases, you will have to expressly accept changes to Notice to continue using the Appro Services. We encourage you to periodically review our Website and the Mobile App for the latest information on our data privacy practices. If you do not accept the terms of the Notice, we ask that you do not use the Appro Services, Website and Mobile App.

13. Complaints

13.1 Appro is committed to providing the highest level of care to all our customers. If you feel that, our service has not met your expectations, then please tell us. Customer complaints are important to our organization. They offer specific insights into how we might improve our services, processes and procedures.

13.2 Please contact us at support@appro.ae , detailing the nature of your complaint and providing all relevant information and your contact details. To ensure that your complaint is resolved as soon as possible, please outline any steps you would like us to take in addressing the issue.

14. Data Protection Officer

14.1 If you have any concerns or questions in relation to this Notice, you may address them to our Data Protection Officer whose name and contact details are as follows:

Name: at Anto Felix Rajan

Email: at Antofelix.rajan@appro.ae