Privacy Policy  
Last updated: 22 July 2024  
At du Pay, your privacy is extremely important to us and we are committed to keeping all your  
personal data secure. This Privacy Policy explains how we use the personal data that we collect or  
generate, both in relation to our app and website and in the course of carrying on our commercial  
activities and providing you with our products and services. For the purpose of this Privacy  
Policy, “we” means EITC Financial Services LLC (EITC FS), doing business as du Pay.  
The products and services we provide:  
This Privacy Policy concerns the information we collect and process about you:  
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to deliver our products and services to you;  
to improve our products and services and develop new ones; and  
to help us operate our business.  
The types of personal data we collect:  
Many of the products and services we offer require us to obtain personal data about you in order  
to perform the services we have been engaged to provide.  
Please note that we need to collect certain information due to requirements of applicable law or  
regulation and if such information is not shared with us, you may be unable to access our app,  
website or receive our products or services.  
Information that you provide to us:  
This includes information about you that you provide when you sign up as or enquire about  
becoming a du Pay customer. It may also include information you provide if you get in touch with  
us to ask something or take part in any surveys, promotions, competitions or prize draws.  
Such information may include:  
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Basic personal data about who you are, such as your name, address, gender, age, email  
address, and postal address; Please note that should any of this information about you  
change, you must inform us immediately. Depending on the circumstances, we may be  
required to verify your identity again.  
We will also request that you provide a “real-time” video recording of yourself which you will  
prompted to provide in the App. Please note that to record the “real-time” video, we will  
require access to the camera on your device. If we cannot access such functions, we cannot  
verify your identity and therefore cannot provide you with an Account.  
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Any relevant identification documentation required due to applicable law or regulation or for  
credit verification purposes;  
How you pay for your services, including your debit or credit card details, bank details and  
other payment information;  
Your interests and preferences.  
Information that we collect or generate about you:  
This includes information derived from your use of our services, or any other du Pay products  
and services, including Data related to your transactions.  
When you use our Services to either make purchases from merchants, send or receive money,  
pay bills, or add value to your Account, or for any other transactional purpose related to the  
Services, we collect information about the transaction, as well as other information associated  
with the transaction such as amount sent or requested, amount paid for products or services,  
merchant information.  
Specifically:  
- Add value to, or remove money from, your Account: if you use our Services to add or remove  
value to or from your Account, we will collect personal data from you to facilitate the request. For  
example, if you use our Services to add value to your Account, we may collect personal data and  
other information including your Account ID and the amount added.  
Further, to add or withdraw value to or from your Account, you must do so by linking an account  
of yours that is separate from your du Pay Account that has the ability to transfer funds into  
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your du Pay Account. We will ask if you would like to store this account information to make it  
simpler in the future to add value to your du Pay Account but you are not required to do so. We  
will not store such information if you do not provide your consent.  
- Send or receive money: when you send or receive money through the Services, we collect  
personal data such as your du Pay Account ID and the du Pay Account ID of the other Services  
user who is a party to the transaction.  
- Pay for items from our listed merchants: when you purchase items, such as a coffee, from one  
of our listed merchants (which can be found in the App), we will collect personal data about your  
transaction including your name and the merchant. The merchant may also provide us with  
certain other data related to the transaction.  
- Pay or request someone else to pay a bill: if you use our Services to pay a bill you are due to  
pay, or a bill for the benefit of someone else, or if you request another user pay a bill for you, we  
collect your Account number and certain personal data about the account holder to whom the bill  
is being paid to, such as name and account number.  
- Withdraw money: you can, depending on merchant capabilities, withdraw money from your  
Account at a merchant’s premises. If you choose to do this, we will collect personal data about  
your transaction including your name and the merchant. The merchant may also provide us with  
certain other data related to the transaction.  
Additionally, we can collect data such as:  
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Service usage details, including your call, text, browsing and billing records.  
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Your network location when you make or receive phone calls, and messages or use the  
internet.  
Your IP address from which you access the internet, the date and time you access a website,  
and the web pages you visit.  
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Your background location, based on your device’s Global Positioning System (GPS).  
Your use of your du or Virgin Mobile account(s), including things such as when and how much  
you top up and pay your bill, or how often and why you access your account with us.  
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Information that we obtain from other sources:  
We also collect information from other third-party service providers, agencies or other publicly  
available sources where applicable, including credit reference and fraud prevention agencies.  
How we use your information:  
Your personal data may be stored and processed by us in a number of ways, although most  
commonly we use your information to:  
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Assess your application for du Pay products and services, where applicable.  
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Process your order and set you up as a customer of du Pay.  
Understand your needs and interests.  
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Keep in touch with you about the products and services you have purchased.  
Supply and improve our products and services and to develop new ones.  
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Provided you’ve given us your consent, tell you about products, services, special offers or  
competitions that we think may be of interest to you, whether by phone, email, text, or other  
ways.  
Keep our records up to date.  
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Manage your du Pay accounts and help you manage your du Pay profile.  
Sort out a payment, put your order through our system or deliver a product or service to you.  
Keep things secure and conduct analysis to detect malicious data and attacks on devices and  
systems.  
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Prevent crime, fraud and money laundering. Should we believe you have breached our Terms  
of Use, or are acting suspiciously, we may conduct an investigation to ensure you are not  
breaching the Terms of Use or breaking the law.  
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Understand feedback on our products and services.  
Look into any complaints or questions you may raise.  
Recover any money you might owe us, assign your debt to permitted third parties and look  
after any credit you might have.  
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Manage and administer our business.  
Manage and administer our app and website.  
Understand the accuracy and performance of our services.  
Carry out statistical monitoring and analysis to help us improve our website and services.  
Comply with and assess compliance with applicable laws, rules and regulations, as well as  
internal policies and procedures.  
Whenever we use your personal data, we comply with applicable law. We use your information in  
the ways described above and share the information as described below because:  
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We need to so that we can provide you with products and services and manage your account  
with us.  
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We need to use some of your information to comply with legal and regulatory obligations  
(such as legal obligations to keep details of calls made by customers for a certain period of  
time).  
Some of our use of your information is necessary for our legitimate business interests (such  
as effectively and efficiently managing the operation of our business, conducting market  
research and preventing fraud and money laundering to minimise our credit and fraud risks  
and protect our business).  
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You have given your consent to us using your data in relation to some forms of use. For  
example, in relation to using your information to send you marketing messages. You can opt  
in and out of this at any time, as explained below.  
Marketing communications  
If you are a du Pay customer and you would like to stop receiving information about our  
promotional offers and deals, you can opt-out or unsubscribe by sending 'B AD-duPay' SMS  
to 7726, completely free of charge.  
If you would like to subscribe back to receiving promotional offers and deals, you can always SMS  
‘U AD-duPay’ to 7726, completely free of charge.  
Requests will be processed as soon as possible, after which no further information about our  
offers, deals and promotions will be received. When you subscribe to one of our products or  
services, we will also tell you upfront about your options to unsubscribe from any future  
communications from us, so you don’t have to keep referring back to this page. Your opt-out  
requests are automatically collected and recorded on our system for us and you to refer back to.  
Please note that if you choose to opt out or unsubscribe from receiving information on offers and  
promotions from us, you will continue to receive important account-related information, such as  
bill payment reminders, etc.  
Disclosure of your personal data to third parties  
We may share your personal data within the EITC group of companies for the purposes  
described above. We will take steps to ensure that access to personal data is restricted to  
employees who have a legitimate interest in the purposes described in this Privacy Policy.  
We may also share your personal data with others outside of du Pay in connection with the  
purposes described above. This might mean sharing that information with:  
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Our partner companies or agencies and their sub-contractors or prospective partners who  
help us run our services.  
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Provided you’ve given us your consent, select third parties whose products and services we  
think you’d be interested in.  
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Third-Party agents and contractors for the purposes of providing services to us and helping  
us improve our services (for example, reputable third parties who help process your order and  
for credit verification purposes).  
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With our partners and contractors for market and other research.  
Credit reference and fraud prevention agencies when we exchange information on payment  
performance and your financial situation to check your credit score.  
These third parties will be required to take all reasonable and appropriate data protection  
measures to protect the confidentiality of your personal data.  
We might also share your information:  
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With any public authority or law enforcement agency (if they ask for it).  
To comply with law or regulations or for possible legal proceedings.  
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If you give us wrong personal information or we find out (or think) you're responsible for  
fraud. In these circumstances, we might share your information with third parties such as law  
enforcement agencies, credit reference agencies and other affected third parties.  
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If there's an emergency and we think you or other people are at risk.  
We will not publish your personal data on any public telecommunications directories and  
databases without your prior consent. You can contact our Customer Care department at  
customercare@dupay.ae or by contacting us via du Pay App to change or remove your  
information from any such database if you wish.  
How long do we keep your personal data:  
There are certain reasons we have to keep hold of your personal data and how long we will hold it  
will vary and will be determined by the following cumulative criteria:  
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the purpose for which we are using it – we will need to keep your personal data while you're  
our customer or after you've left us, but only in accordance with our data retention policies;  
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legal obligations – laws or regulations may set a minimum period for which we have to keep  
your personal data.  
How we safeguard your personal data:  
We ensure the safe processing and storage of your information at all times by operating and  
maintaining physical, electronic and procedural safeguards and we restrict access only to  
authorised personnel. The effectiveness of these safeguards is periodically tested.  
We have extensive controls and mechanisms in place designed to detect, respond and recover in  
case of adverse events that may arise.  
Your rights:  
In some circumstances, you may have certain rights in relation to the information that we hold  
about you, including:  
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The right to request details of the information we have about you.  
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The right to withdraw your consent to the use of your information where we are relying on  
that consent (for example, you can opt out of receiving marketing messages from us). Please  
note that we may still be entitled to process your information if we have another legitimate  
reason (other than consent) for doing so.  
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The right to ask that we update your information if it is inaccurate or incomplete.  
The right to request that we restrict the processing of your information in certain  
circumstances. Again, there may be circumstances where you ask us to restrict the  
processing of your information, but we are legally entitled or required to refuse that request.  
If you wish to exercise any of the rights set out above, please contact us using the details  
provided below.  
You can also check and update some of your account information whenever you like by  
visiting your profile on the du Pay app and logging in to your du Pay account.  
Other important information  
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This Privacy Policy applies to how we use your information in relation to our website and  
products and services generally. If you are signing up for our products and services, there may  
be extra terms and conditions to look at. We will tell you about those when you sign up for the  
service or at another appropriate time.  
Communications disclaimer  
Please remember that any emails or other communications you send over the internet aren't  
entirely safe unless they've been encrypted.  
Please also note that communications over the internet may be monitored in accordance with the  
laws of the United Arab Emirates.  
Contact us  
If you want to know more about how we use your personal data or to raise any queries or  
concerns with us in relation to your personal data, you can contact our Customer Care  
department at customercare@dupay.ae or by contacting us via the du Pay App.  
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