SalimPay Privacy Policy

At SalimPay, your privacy and data security are fundamental to us. We are committed to complying with applicable laws, including those of the United Arab Emirates (UAE). The purpose of this privacy policy is to explain how SalimPay will process your personal data as a data controller. Your personal data will be treated confidentially and only for the purposes to which you have consented or which are necessary to provide you with our services. This Privacy Policy explains how we are handling your data when you use SalimPay.

By using SalimPay, you acknowledge that you have read and understood this Privacy Policy and agree to the manner in which we collect, use, and protect your data.

Data Controller

SalimPay is developed and operated by Lemonilab FZCO, a software development company based in Dubai, UAE, under license number: 12303.

For inquiries about your data or this Privacy Policy, you can contact us at [email protected] or by sending a letter to our UAE office - Dubai silicon oasis, Dubai Digital park, A5, Office 2017.

Data We Collect

When you use SalimPay, we collect information from two primary sources:

  • A. Data you provide directly in the app
  • B. Data shared through your linked bank account(s) via Lean Technologies

We collect this information to provide you with secure money transfer services, improve your experience, and comply with applicable regulations.

1. Information You Provide to Us

1.1. Personal Information

  • First and Last Name
  • Email Address
  • Mobile Phone Number

1.2. Device Information

  • Device Manufacturer, Model, and Operating System

1.3. Contacts Information

  • Your contact list (name and phone number) is temporarily stored to check if they are SalimPay users.
  • After the check, we retain only the contacts you choose to connect with inside SalimPay (with your consent).
  • IBAN Contacts, any contacts you add to your SalimPay account using an IBAN.

2. Data Collected via Lean Technologies (Open Banking Provider)

When you connect your bank account via Lean, and after your explicit consent, SalimPay receives and stores:

2.1. Identity Information (if provided by your bank)

  • Full Name
  • Mobile Number
  • Gender
  • National Identity Number
  • Date of Birth
  • Address
  • Email Address
  • Account Information:
  • Bank Name
  • Account Name
  • Currency
  • Account Type
  • Account Number
  • Account Balance
  • IBAN
  • Beneficiaries

2.2. Transaction Information

  • Sender and Recipient Details (Name, IBAN, Account Number)
  • Bank Transaction Reference
  • Amount and Currency
  • Initiation Timestamp
  • Transaction Reason
  • Transaction Status

Note: SalimPay is a non-custodial service, we do not hold your funds. All transfers are processed directly between bank accounts via Lean’s secure API. The data we receive from Lean is used solely to display balances, facilitate payments, and improve your app experience.

C. Analytics and Performance Data

We use Google Analytics to understand how our app is used and to improve performance. This includes:

  • Device identifiers
  • IP addresses
  • Pages/screens viewed in the app
  • Session duration and interaction

Why We Collect Your Data

  • Facilitate Transactions: Enable peer-to-peer financial transfers
  • User Experience: Improve and personalize your app experience.
  • Security: Maintain the security and integrity of our services.
  • Analytics: Analyze usage trends through Google Analytics to enhance app performance and features.

We collect and process your personal information for the following purposes. In some cases, these purposes are carried out directly by SalimPay, while in others, they are handled by trusted third-party partners to ensure compliance with applicable laws and deliver our services effectively.

  • Facilitate Peer-to-Peer Transfers: to enable execution of transactions between users in accordance with our contract with you.
  • User Experience Enhancement: to improve and personalize your app experience, provide spending insights, and suggest relevant features, based on our legitimate interests.
  • To communicate with you: send important updates, notifications, reminders, or other relevant information about your account, services, or transactions.
  • Security and Fraud Prevention: detect, investigate, and prevent fraudulent activities, unauthorized access, or abuse of the platform, based on legitimate interests and legal obligations.

Analytics

We use Google Analytics (Firebase SDK) to collect anonymized data on how users interact with SalimPay. This includes device identifiers, IP addresses (anonymized), and behavioral data such as screens viewed. Data is sampled and aggregated to improve our services. No financial, transaction, or KYC-related information is sent to Google Analytics.

Google may process this data according to their Privacy Policy. We use Google Analytics to collect data on how users interact with SalimPay. This includes device identifiers, IP addresses, and behavioral data (such as screens viewed). This information is aggregated and used to improve our services. Google may process this data in accordance with their policies.

Data Retention

We keep your personal data, transaction records, and analytics information only as long as needed to provide our services and comply with UAE laws.

  • We retain all personal and transaction data for at least five (5) years.
  • For users with an active account, the retention period starts when your account is closed or your relationship with SalimPay ends.
  • For users who make a one-time transaction without creating ongoing transactions, the retention period starts from the date of that transaction.
  • After this period, your data will be securely deleted if it’s no longer needed.

The data we collect is securely stored, with encrypted backups kept in separate secure locations. We use strict technical and organizational measures to protect your data from unauthorized access, loss, or misuse. Users have the right to request deletion of their data by sending a request to [email protected].

Data Sharing

We do not sell or rent your personal data to any third party. Your data may be shared only with trusted third-party service providers strictly for the purpose of delivering SalimPay services and under their privacy policy, fulfilling legal or regulatory requirements, or supporting our operations. These parties are bound by strict contractual obligations to act only on our instructions, protect your data, and not use it for any other purpose.

Specifically, SalimPay engages the following categories of third-party service providers:

  • Hosting (Processor): Your data is securely stored, with encrypted backups kept in separate secure locations. We use strict technical and organizational measures to protect your data from unauthorized access, loss, or misuse. Hosted by a trusted provider within the applicable legal jurisdiction.
  • Payment Initiation (Processor): Lean Technologies also facilitates secure payment initiation services.
  • SMS/OTP Delivery (Processor): OTPs are sent via a licensed SMS gateway provider.
  • App Performance Monitoring (Processor): We use analytics tools to ensure app stability and improve the user experience.

We determine the purposes and means of processing your personal data.

Protection of SalimPay and Others: We may release Personal Data when we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request; (ii) to exercise or defend our legal rights; (iii) to protect our or our customers' or the public rights or property, or the security or integrity of our Services from harm, fraud, or potentially prohibited or illegal activities or otherwise; or (iv) for an investigation of suspected or actual illegal activity.

Internal Sharing

Your personal data may be shared with restricted reasons and domains as per governing laws internally within SalimPay (including with our parent or affiliate companies) for operational, compliance, and service optimization purposes, always under strict confidentiality and access control.

Data Security

We take the protection of your information seriously. We implement industry-standard security measures, including encryption, access control, and regular security reviews, to safeguard your personal data from unauthorized access, use, or disclosure. Your data is stored in secure facilities within jurisdictions that comply with applicable data protection regulations. We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Limitation of Liability

SalimPay's responsibilities and liabilities are limited as follows:

  • Third-Party Services: SalimPay uses trusted third-party providers, such as Lean Technologies and SMS/OTP providers, to support our operations and enable features like payment initiation, banking connections, and notifications. While we conduct due diligence and impose certain procedures to ensure these services are reliable and secure, SalimPay is not liable for any technical issues, service interruptions, or errors caused by these third-party providers.
  • Data Handling by Third Parties: Each third-party provider is contractually obligated to handle your data responsibly and in accordance with applicable laws. SalimPay’s liability for data-related events arising from third-party services is limited to technical issues within our control.
  • Data Security Events: SalimPay is committed to protecting your data and will take reasonable measures to secure it. However, SalimPay shall not be liable for any data security events or breaches that are beyond its reasonable control. Additionally, SalimPay uses services provided by Lean Technologies ("Lean"). For any data security events covered under Lean’s agreement, SalimPay will only be liable to the extent Lean is liable under its agreement. If Lean is not responsible for certain data security events, SalimPay will not be liable to users for those events either.

Entire Agreement

This Privacy Policy constitutes the entire agreement between you (the user) and SalimPay, superseding any prior discussions or agreements.

Changes to this Policy

We may update this Privacy Policy from time to time. We will notify users of significant changes through in-app notifications or pop-ups whenever the application is updated.

User Complaints

You, as a user, have the right to submit complaints to SalimPay regarding your personal data. If the issue is not resolved, you also have the right to escalate the complaint to the relevant governing legal entities.

Contact Information

Lemonilab FZCO - UAE office - Dubai silicon oasis, Dubai Digital park, A5, Office 2017.

[email protected]

Agreement

By using SalimPay, you agree to this Privacy Policy and how we handle your data.