Privacy policy

Financial Inclusion Technologies Ltd a private company incorporated in Abu Dhabi Global Markets (“ADGM”) with registration number 6946, a wholly owned subsidiary of Standard Chartered UK Holdings Limited with its principal office at Suites 507-509,15 Floor, Al Sarab Tower, ADGM Square, Al Maryah Island, Abu Dhabi, United Arab Emirates using the brand name myZoi (“myZoi”) is the entity which processes personal information about you. myZoi is committed to maintain the confidentiality, integrity and security of all information you provide to us. It is important to read this entire privacy notice (“Notice”) along with our Terms and Conditions carefully as some of the provisions affect your legal rights and obligations.

This Notice describes the manner in which myZoi ( “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  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 myZoi 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 myZoi 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 myZoi Terms and Conditions available at https://myzoi.life/

Further, if you are accessing myZoi 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, Amazon’s Appstore, Microsoft’s store, Huawei AppGallery from time to time) which will govern the use of the Mobile App.

myZoi is committed to maintain the confidentiality, integrity and security of all information of the Users. It is important to read the entire Notice along with the Terms and Conditions carefully as some of the provisions affect the Users’ 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 https://myzoi.life/

Definitions

• “Account” means the account created by the User on the Mobile App after successful completion of registration.
• “Mobile App” means the mobile application owned by myZoi, which was developed and designed to operate on various mobile operating systems, to provide myZoi’s Services.
• “myZoi Services” means the myZoi digital wallet offered to individuals, payroll services offered to organisations, access to the Website, use of the Mobile App and such other services as may be provided by us through such channels as we may decide, from time to time.
• “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, digital KYC providers and logistics providers and other partners from whom myZoi may obtain certain services in relation to the Mobile App, the Website and any other services needed to provide myZoi Services.
• “Usage Information” means information that we automatically collect about how you access and interact with myZoi Services.
• “User” means any individual/organisation (as the case maybe) registered on the Mobile App or any other platform for using myZoi Services.
• “User Data” means any data including Personal Data and SPD submitted by the User to us in connection with the use of myZoi Services or available to us as per Section 2 of this Notice.
• “Website” means the domain https://myzoi.life/

Personal Data We Collect

• User-Provided Information: This Notice applies to User Data collected from you and/or from any third parties in 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/pin, recent photograph, signature image, employment ID, employer name, employment status, designation, salary details, and other Know Your Customer (KYC) documents including identity and , other government issued identity proof, which may be shared/ uploaded by you, as and when you avail any myZoi Services, and to which myZoi may become privy to.
• Information We Automatically Collect: In addition to information, you provide to us, we may collect certain 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 myZoi 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:
  • Device Information. This is information about how you access myZoi Services, such as the operating system, hardware model, application or browser type and version, and unique identifiers associated with your device.
  • Log Information. There are certain pieces of information we collect in system logs or similar files about how you interact with myZoi Services, such as which features you visit or click on. This Log Information may also include your IP address, browser or device configuration, date and time of access and cookie information.
  • 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 state). 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.
• 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 myZoi. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.
• Information from Other Sources:  We may rely on information about you that we collect from other sources or from the public domain, for example if you are registered on the Mobile App we may obtain information from your employer and such other sources, in order to provide you with myZoi Services, including Third Party Service Providers and records maintained by governmental authorities.
• Personal Data requested by myZoi 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.

Consent

• 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 myZoi (including its marketing channels 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 myZoi Services, for imparting product knowledge, offering promotional offers running on the Website, and various other offers offered by the Third Party Service Providers or myZoi.
• The usage of the Mobile App 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. 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 myZoi Services availed by you.
• You hereby expressly authorize and provide consent for us to share your User Data with third parties including but not limited to Third Party Service Providers.
• myZoi reserves the right (and you expressly authorize myZoi) to share or disclose your User Data when myZoi determines, in its sole discretion, that the disclosure of such information is necessary or appropriate under applicable laws.
• 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 myZoi Services to you. For example, when processing your application, we are required to conduct due diligence (such as, know your customer checks) the system we use to do this will provide us with an automated result and we will base our decision on that result. By signing up for the provision of myZoi Services, you consent to our use of automated decision making as described in this paragraph.
• We may use profiling, including behavioral 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.
• 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 myZoi’s business operations. Please refer below to Section 6 Your Privacy Choices for further information on withdrawal of consent.

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 myZoi Services and operating our business relationship with you, including the following:

• To operate, maintain, enhance, and provide all features of myZoi Services, to process applications for myZoi Services, to provide products, 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 Mobile App and/or Website.
• For training, quality monitoring and operational purposes.
• To understand and analyze the usage trends and preferences of our Users, to improve myZoi Services, and to develop new products, services, features, and functionality.
• 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 this Notice.
• We may use cookies and automatically collected Personal Data information to: (i) personalize myZoi Services, 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 myZoi Services 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 Mobile App or Website. Please refer to our Cookie policy located on our website for additional information.
• To comply with applicable laws, regulations, directives, judgments or court orders, government sanctions or embargoes, reporting requirements under financial transactions legislation, and demands of any authority, regulator, tribunal, enforcement agency, or exchange body.
• We may also process your Personal Data to effect agreements between us and any authority, regulator, or enforcement agency; to comply with policies and good practice standards where it is in our legitimate interest to do so.
• Personal Data is also processed where it is in our legitimate interests to seek professional advice, including, in connection with any legal proceedings (including any prospective legal proceedings), for obtaining legal advice or for establishing, exercising or defending legal rights.
• 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.

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:

• For availing services from Third Party Service Providers – We provide our Third Party Service Providers your User Data to enable them to provide certain services to you via the Mobile App, as described in this Notice. We may share your SPD with our Third Party Service Providers. We may also provide your User Data to other Users to facilitate your transactions with such Users on the Mobile App.
• When we collaborate with third parties to provide or improve myZoi 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.
• As part of a corporate change – User Data may be disclosed and otherwise transferred to any actual or potential 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 or any officer, employee, agent or adviser of any of these parties.
• 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 myZoi Services.
• 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.
• With your consent – There may also be contexts in which we share specific types of User Data with your express consent.
• With group entities – We may disclose User Data with any member of myZoi’s group companies worldwide, including its officers, employees, agents, professional advisers and directors who may disclose your Personal Data to any of these parties worldwide: (i) professional advisers (including auditors), third party service providers, agents or independent contractors providing services to support our business; (ii) any person to whom disclosure is allowed or required by applicable law or regulation; (iii) any court, tribunal, regulator or authority; (iv) any financial institution to conduct credit checks, anti-money laundering related checks, for fraud prevention and detection of crime purposes; or (v) anyone we consider necessary in order to provide services in connection with myZoi Services.

Your Privacy Choices

• 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 Mobile App and myZoi Services. However, please note that by applying for myZoi Services and accepting the myZoi Terms and Conditions you are under a contractual obligation to provide such information to us so that we can provide myZoi Services to you. You may update, correct, or delete your User Data and preferences at any time by accessing your Account settings page on the Mobile App. If you wish to delete, access or amend any User Data that you have shared with us, you may contact us at support@myzoi.life. If you wish to withdraw consent that you have given to this Privacy Notice or to the myZoi Terms and Conditions, you may contact us at support@myzoi.life or request for a call back through the Mobile App. 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.
• 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 communication. You may also opt out from receiving commercial emails from us by sending your request to us by email at support@myzoi.life. 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 settings page on the Mobile App or Website.
• 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 emails from us, you will continue to receive administrative messages from us regarding myZoi Services you have applied or opted for.
• You may choose to opt out of SMS promotional services as well. To opt out, visit Account settings on the Mobile App and disable offers and discounts notifications. We will aim to process such requests without undue delay and within ten business days. 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.

Data Security

• myZoi 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.
• 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. In the event we become aware of any such unauthorized activity, we shall notify you without undue delay, in accordance with the notification procedures set out the applicable laws and regulations.

Data Transfers

• Personal Data including your SPD may be transferred to, or stored at, a location outside of the ADGM, 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 myZoi as well as have in place necessary technical and organizational security measures to safeguard your Personal Data.

Data Subject Rights

Subject to applicable law and regulations and/or applicable banking or financial industry guidelines, you may have the right to invoke a data subject right in relation to your Personal Data being processed by myZoi. 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 myZoi 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.
• 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:
  • the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • you withdraw your consent on which the processing is based and there is no other legal ground for the processing;
  • you object to the processing and there are no overriding legitimate grounds for the processing;
  • the Personal Data have been unlawfully processed; or
  • the Personal Data have to be erased for compliance with a legal obligation to which myZoi is subject.
• Right to Restriction of Processing. Except in very specific cases, where provided by applicable law, you have the right to obtain from myZoi restriction of processing where one of the following applies:
  • you contest the accuracy of your Personal Data (in such a case, the restriction will be for a period enabling myZoi to verify the accuracy of said data); or the processing is unlawful;
  • myZoi 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 defense of legal claims; or
  • you object to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.
• 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.
• 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:
  • if the processing is for direct marketing purposes, including profiling related to direct marketing;
  • if the processing is for the purposes of conducting statistical surveys, unless the results of such surveys are used for the interest of the public; or
  • 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.
• 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:
  • if the automated processing is included in the terms of the contract entered into between you and myZoi;
  • if the automated processing is necessary according to other legislation in force in the country where myZoi Services are provided; or
  • if you have given prior consent to the automated processing in accordance applicable law.
• To invoke your data subject rights, please send an email to support@myzoi.life.

Confidentiality of Login ID and Password

• 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 change your password immediately or contact us immediately via the Mobile App or by calling the myZoi call center at the number located on our Website. We are not responsible if a third party accesses your Account through the login credentials they have obtained from you or through a violation by you of this Notice or myZoi Terms and Conditions.

Changes and Updates to this Notice

• 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 myZoi 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 myZoi Services. We encourage you to periodically review our Mobile App and the Website 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 myZoi Services, Mobile App and the Website.

Complaints

• myZoi is committed to providing the highest level of care to all our Users. 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.
• Please send us an email at support@myzoi.life 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. You may also raise a call back request from the mobile app and lodge a complaint with our customer service.
• You may also have the right to complain to the ADGM Commissioner of Data Protection. Should you wish to submit a complaint to the ADGM Commissioner of Data Protection, please do so at the link: https://www.adgm.com/registration-authority/complaints/submit-a-complaint.

Data Protection Officer

If you have any concerns or questions in relation to this Notice, you may address them to our Data Protection Officer, Syed Muhammad Ali at dpo@myzoi.life.