Data Privacy
Policy

Pasiv Financial 2026

Data Protection & Privacy Policy

Last Updated: February 2, 2025

This Privacy & Data Policy sets forth how personal information is collected and used, that is provided on the Internet Web site located at www.pasiv.ae (the "Site") and our mobile application (collectively, "Pasiv"). Unless otherwise indicated, this Policy only applies to personal information collected through Pasiv by Pasiv Financial Ltd, or any of its respective affiliates (together, for purposes hereof, "Pasiv"). By using Pasiv, you agree to be bound by this Privacy & Data Policy and our Client Agreement, as they may be amended from time to time in the future (see "Change to this Privacy Policy" below).

We are registered with the DIFC and are subject to the DIFC Data Protection Law 2020. This regulation explains how and why we use your personal information when you use Pasiv. You can chat with us through the app or send us an email at support@pasiv.ae if you have any questions or concerns.

Our Commitment

Pasiv is committed to maintaining the confidentiality, integrity and security of any personal information about our users. This Policy explains how we protect personal information provided through Pasiv and how we use that information in connection with our service offered through the Pasiv (the "Service" or "Services"). "Personal information" for purposes of this Policy means information that identifies you, such as your name, address, phone number, fax number, or email address.

We Collect, Use, and Retain Information About You

Information you give us through the Pasiv app, when you register to use the app, sign up for an account, correspond with us, use the app chat, engage in promotions or reward schemes, or other communications: Your name, phone number, home address, date of birth, residency, Your email address, details of your device, Your Emirates ID information, or passport and any other identification documents, Your photo if you upload one, The login and registration information and settings you choose for your app (including username, password), Your bank account details, including account number and IBAN, Your location, Your employment information and your source of wealth, Details you give us which we pass to our partners when you let us know you are interested in their services, Information you give us through the app chat or records of discussions if we contact each other, The email address you use and the contents of your email (and any attachments), Public details from your social media profiles (Facebook, Instagram, or Twitter) if you reach out to us via these platforms, and the contents of your messages or posts to us, Answers you give to surveys, Details about deposits and withdrawals to and from your account, including amounts and beneficiaries' bank details, Details about services from us and our partners that you express interest in, Details about how you use our app.

Information We Collect From Your Device

As part of the mobile service we provide you, the mobile app allows us to collect certain information of yours: The mobile network information and operating system, the type of mobile browser you use, Your login information, browser type and version and information, The type of device you use, unique device identifier, Your IP (Internet Protocol) address and device ID for security reasons, Your mobile advertising ID, so we can share it with companies that help us with advertising online. You can reset this ID or limit tracking in 'Settings' on your phone, Your location so we can help protect you against fraud which we track your location using GPS and your IP address, Your phone contacts solely to show you who in your contact list uses Pasiv if you give us access to do so, Information on your use of the app, including links to, through and from our website to other sites, Transaction data to do with your investments and holdings.

Information From External Sources

We obtain information about you from external sources to enable us complete an appropriate risk assessment on your account application, fraud prevention agencies and KYC (Know Your Customer) and AML (Anti Money Laundering) service providers to fulfil our legal duties, Information from your social media network if you log in to our app from your social media account, we will receive information to authenticate you.

Cookies Policy

We use cookies, pixels, and other technologies (collectively, "Cookies") to recognise your browser, or device, learn more about your interests, and provide you with essential features and services and for additional purposes including: Recognising you when you sign-in to use our services. This allows us to provide you with product recommendations, display personalised content, enable you to use 1-Click transactions and provide other customised features and services. Keeping track of your specific preferences. This allows us to honour your likes and dislikes, such as whether or not you would like to see interest-based ads. You may set your preferences through Your Account. Conducting research and diagnostics to improve our content, products, and services. Preventing fraudulent activity. Improving security. Delivering content relevant to your holdings. Reporting. This allows us to measure and analyse the performance of our services. Cookies and other similar technologies may collect data such as language preference, country, and previously viewed pages. To summarise, we use the following cookies: Necessary cookies: these cookies enable the basic use of our Service, Personalisation cookies: these cookies allow our Service to be personalised for you, Analytical cookies: these cookies allow us to see how people use our Service so that we can understand how to improve it. By using our Service, you agree to place the cookies described above on your device. You have the right to withdraw your consent at any time. If you would like to delete our cookies, you can do so by changing the settings of your browser. Blocking or deleting cookies may mean that some features of the Service may not be available to you.

Why We Use Your Information

We must have a lawful basis for using your personal data. At least one of the following must apply: contractual or legal duty, legitimate interest, public interest, vital individual interest, or consent. In this section we explain which one we rely on to use your data in a certain way.

We Need to Use Your Data for a Contract We Have With You

We use details about you to: consider your application, including our KYC, customer due diligence and security checks, give you the services we agreed to in line with our terms and conditions, to process your transactions, send you updates and communications about your account and other services you use if you get in touch, or we need to notify you of changes to our Services, tell you about something or contact you through customer support services to handle your enquiries in our communication, exercise our rights under contracts we have entered into with you, allow our partners to provide information on their services if you agree to receive such information, investigate and resolve complaints and other issues.

We Need to Use Your Data to Comply With the Law

We use your details to: check your identity when you sign up or get in touch, check your record at immigration and fraud prevention agencies, prevent illegal activities like money laundering, tax evasion and fraud, keep records of information we hold about you in line with legal requirements, adhere to banking laws and regulations (these mean we sometimes need to share customer details with regulators, tax authorities, law enforcement or other third parties), compare information we hold about your account with your tax residency information to make sure we do not have a reason to doubt it.

When It Is in Our 'Legitimate Interest

We need to use your data for our legitimate interests, or those of a third party. This means using data in a way that you might expect us to, for a reason which is in your and/or our (or a third party's) interest and which does not involve overriding your privacy rights.

Product Development and Marketing

We will tell you about products and services through the app or other channels, like social media companies, based on how you use our products and services and other information we hold about you. We do this so we can make sure our marketing is useful. We do not share any identifying information with social media companies other than your mobile advertising ID. We track, analyse, and improve the services we give you and other customers and how you respond to ads we show. We may ask for feedback if you have shown interest in a service. We do this so that we can make our products better and understand how to market them.

Special Features

We will continue to build special features which will give you a unique user experience. We will use your transactional data for these features.

Security and Business Management

Protect the rights, property or safety of us, our customers, or others carry out security and maintenance checks to make sure our app, website and other services run smoothly for you, share information with fraud prevention agencies so we can benefit from up-to-date information when we make decisions about accounts. This helps us fight financial crime, share your name, title and account number with other banks and financial institutions so that people making payments to you can confirm the name they have for you matches the name we hold in our records. This helps us fight financial crime.

Companies That Give Services to Us

We share your information with companies that help us provide our services.

Consent

We will ask for your consent to: tell you about our products and services, and those of our partners by email or push notification if we think they are of interest to you. You can unsubscribe from these by email or via the app, help protect you against fraud by sending you a One Time Password, consent to trade execution and/or withdrawals from your account, show your profile picture in the app if you add one, show your profile picture and name to contacts in the app, provided they have stored your phone number & you consent to enable our community feature & share with the community, share information about you with companies we work with when we need your permission. You do not have to share information about yourself if you do not want to. But if you do not, you may not be able to use some (or any) of our services.

We May Share Your Data With

Companies that give services to us: Here we mean companies that help us provide services you use and need to process details about you for this reason. We share as little information as we can and encrypt and/or make it impossible for you to be identified by the recipient where possible (for instance by using a User ID rather than your name).

Compliance with Applicable Laws

We share your personal data with third parties that help us provide services you use or to comply with applicable laws. We will never sell your personal data to other organisations.

Others

Business partners that provide services to us, including IT and brokerage services, Know Your Customer (KYC) service providers that help us with identity verification or fraud checks, cloud computing power and storage providers, our business intelligence and analytics partners, companies that help us with functional analytics (to help us solve technical issues with the app for instance), companies that help us with marketing (but we will not share identifiable personal data with third parties for their own direct marketing unless you give us permission, and you can opt out any time), software companies that we use for emailing you, or for processing and storing email communications with you, companies that help us with customer support, financial institutions that provide complementary services such as money remittance to or from your bank account, legal or regulatory authorities where we have a legal obligation to do so or to prevent fraud.

We Will Use This Information To

Verify your identity and make sure what you have told us is true, help detect and prevent fraud, crime, and money laundering, manage your account with us, make sure our offers are relevant for you. Anyone you give us permission to share it with, we tell you in the app when we need your consent to share your data with other applications.

Law Enforcement and Other External Parties

We may share your details with authorities that spot and stop financial crime, money laundering, terrorism, and tax evasion if the law says we have to, or if it is necessary for other reasons, or; the police, courts, or dispute resolution bodies if we have to, or; other banks to help trace money if you are a victim of fraud or other crimes or if there is a dispute about a payment, or; any other third parties where necessary to meet our legal obligations.

Corporate Finance Events

We may also share your details with people or companies if there is a corporate restructure, merger, acquisition or takeover.

Retention of Data

We keep most of your data as long as you are using your account, and for 6 years after that to comply with the law and if we face a legal challenge. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer if we need to (that is in our legitimate interest) and/or the law says we have to.

Your Rights

You have the right to: access the personal data we hold about you, or to get a copy of it, make us correct inaccurate or out of date personal information, ask us to delete your data unless we have a legal obligation to retain it, ask us not to contact you for marketing purposes, withdraw any consent you have given us or object to processing of your personal information, ask a member of staff to review a computer-made (automated) decision, contact us at support@pasiv.ae.

Where We Store or Send Your Data

To provide our services to you we may transfer and store the data we collect from you to organisations outside of the DIFC. When we do this, we make sure that your data is protected and that appropriate security measures are in place.

How We Keep Your Data Secure

Your data is stored on secure servers. We maintain reasonable security measures to safeguard your personal data from loss, interference, misuse, unauthorised access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and it is accurate, complete, and up to date. Any payment transactions carried out by us or our payment-processing providers will be encrypted using Secured Sockets Layer technology or a secure virtual private network, encrypted using transport layer security (TLS).

How to Make a Complaint

If you have a complaint about how we use your personal information, please contact us through the website or send an email to support@pasiv.ae and we will do our best to fix the problem.

Other Websites

Your data may be shared with affiliates and trusted partners for service provision. External websites are not under our control; review their privacy practices.

Changes to This Notice

Any changes we make to our privacy policy will be posted here and if they are significant changes, we will let you know via email.

AI & Data Privacy

Pasiv utilises AI technologies to enhance your experience. We ensure your data is handled with the utmost care. AI processes user data for personalised responses and to improve our services.

Ethical Use of AI

We are committed to ethical AI use, protecting user data, and ensuring fairness, transparency, and accountability in AI-driven processes.

User Consent and Notification

We inform users about AI data usage. Consent is obtained for AI processing, especially for financial data. Users are notified of AI-driven responses.

Data Security

Robust security measures safeguard user data, especially sensitive financial information, from unauthorised access or breaches.

Accountability

Clear responsibilities are established for AI-related actions and decision-making. Procedures for addressing user grievances are in place.

User Data Processing

Data processing is limited to defined purposes and requires user consent, especially for financial data processing.

User Consent and Notification

Users receive clear, explicit notices about data use in the AI process. We explain the impact of AI on their rights, particularly data privacy and sensitivity.

Limitation on High Risk Activities

High-risk processing activities are identified and additional safeguards applied as needed.

Record Keeping

Detailed records of AI system processing activities, especially those involving personal data, are maintained.

Temporary Custodian Concept

We abide by the concept of 'temporary custodian' for inadvertently obtained information. This includes provision on managing such information and outlining the role and responsibilities of the temporary custodian internally.

Waivers & Cross-Border Data Transfers

We have the right to a waiver for the 'records of processing activities' requirements for companies with fewer than 50 persons, unless they engage in high-risk processing activities. We also detail the management of digital communication consents and transfer only within 'adequate jurisdictions' approved for cross-border personal data transfers.

Data Transfers to the USA

We acknowledge that as part of our services, there may be a cross-border transfer of data to the USA. However, such transfers will only occur in compliance with legal requirements and under secure and verifiable conditions. We prioritise data security and privacy for our users.

Data Deletion Rights

You have the right to ask for all your data to be deleted from our servers, except for data that we must retain in accordance with applicable laws and regulations in the DIFC or the UAE. If you request an account cancellation or deletion, our teams will ensure that all your data apart from that which we need to retain is scrubbed from our servers within 48 hours and we will notify you of the same.