INTRODUCTION
Cence Portal LLC and its subsidiaries and affiliates (collectively, "Cence," "Company," "we," "us," or "our") recognise the importance of protecting the privacy of all users ("you" or "user") who access and/or use our websites, or our mobile application that runs on smartphones, tablets, and other devices (collectively, our "Platform").
This Privacy Policy will inform you about our purposes for collecting and processing your personal information, our practices for collecting, using, maintaining, protecting, and disclosing your personal data when you visit our Platform and inform you about your privacy rights and how applicable law protects such rights.
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY POLICY
This Privacy Policy aims to give you information on how Cence collects and processes your personal data through your use of the Platform, including any data you may provide when you register for an account, add credit card information, access card benefits and rewards information, or use our location-based services.
We will only use your personal data to provide you with our services, for legitimate business purposes, and to fulfil legal obligations. It is important that you read this Privacy Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
CONTROLLER
Cence is the controller and responsible for your personal data. We have appointed a data protection officer ("DPO") who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
CONTACT DETAILS
Attention: Data Protection Officer
Email address: support@cencepay.com
Address: Dubai, UAE
You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues in the UAE. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.
Cence complies with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”). We are committed to protecting your personal data and ensuring its confidentiality, integrity, and availability in accordance with UAE laws.
CHANGES TO THE PRIVACY POLICY
This version was last updated on March 20, 2025. We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes either through the email address you have provided us or by placing a prominent notice on our Platform.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
The Platform may include links to third-party websites, plug-ins, and applications, including credit card issuers, merchants, and other service providers. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the privacy policy of every website you visit.
The Platform may contain links to third-party websites or services. We are not responsible for the privacy practices or content of these third parties. We encourage you to review their privacy policies before using their services.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
◉ Identity Data includes first name, last name, username or similar identifier, date of birth, and gender.
◉ Contact Data includes email address and telephone numbers.
◉ Financial Data includes types of credit cards you hold (we store only the card type and last four digits, not full card numbers), card expiry dates, and bank names.
◉ Transaction Data includes details about card usage patterns and preferences.
◉ Technical Data includes internet protocol (IP) address, your login data, browser type and version, device type, operating system and platform, and other technology on the devices you use to access the Platform.
◉ Profile Data includes your username and password, preferences, feedback, and survey responses.
◉ Usage Data includes information about how you use our Platform, including the viewing and selection of card benefits and rewards.
◉ Location Data includes your precise or approximate location when you opt in to location services to receive card recommendations based on your location.
◉ Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Platform feature or specific card benefit. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
By using the Platform, you explicitly consent to the collection, processing, and storage of your personal data, including financial and location data, for the purposes outlined in this Privacy Policy. You may withdraw your consent at any time by contacting us at hello@cencepay.com.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with card benefits information or location-based recommendations). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us. This includes personal data you provide when you:
◉ Create an account on our Platform
◉ Add credit card information to your profile
◉ Set your preferences for card benefits and rewards
◉ Request marketing to be sent to you
◉ Enter a promotion or survey
◉ Give us feedback
Automated technologies or interactions. As you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Location information. When you use our mobile application, we may collect and process information about your actual location if you give us specific permission to do so. We use various technologies to determine location, including IP address, GPS, and other sensors that may provide information on nearby devices, Wi-Fi access points, and cell towers.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
◉ Technical Data from analytics providers and advertising networks
◉ Identity and Contact Data from publicly available sources
◉ Credit card benefit information from publicly available sources or official credit card issuer websites
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
◉ Where we need to perform the contract we are about to enter into or have entered into with you
◉ Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
◉ Where we need to comply with a legal or regulatory obligation
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose/Activity
◉ To register you as a new user To provide card benefits and rewards information
◉ To provide location-based recommendations
◉ To manage our relationship with you including notifying you about changes to our terms or privacy policy
◉ To enable you to participate in a survey
◉ To administer and protect our business and the Platform
◉ To deliver relevant content and advertisements to you
◉ To use data analytics to improve our Platform
◉ To make suggestions and recommendations to you about features or card benefits that may be of interest to you
Type of data
◉ Identity, Contact, ProfileIdentity, Contact, Financial, Usage
◉ Identity, Contact, Financial, Location, Usage
◉ Identity, Contact, Profile, Marketing and Communications
◉ Identity, Contact, Profile, Usage, Marketing and Communications
◉ Identity, Contact, Technical
◉ Identity, Contact, Profile, Usage, Marketing and Communications, Technical
◉ Technical, Usage
◉ Identity, Contact, Technical, Usage, Profile, Location
Lawful basis for processing
◉ Performance of a contract with you
◉ Performance of a contract with you
◉ Performance of a contract with you; Necessary for our legitimate interests (to provide relevant service)
◉ Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated)
◉ Performance of a contract with you; Necessary for our legitimate interests (to study how users use our services)
◉ Necessary for our legitimate interests (running our business, provision of administration and IT services, network security); Necessary to comply with a legal obligation
◉ Necessary for our legitimate interests (to study how users use our services, to develop them, to grow our business)
◉ Necessary for our legitimate interests (to define types of users for our services, to keep our Platform updated and relevant)
◉ Necessary for our legitimate interests (to develop our services and grow our business)
MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us.
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or registered for our services and, in each case, you have not opted out of receiving that marketing.
Third-party marketing.
We will get your express opt-in consent before we share your personal data with any company outside Cence for marketing purposes.
Opting out.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the Platform and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you, or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience, or other transactions.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Platform may become inaccessible or not function properly.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 4 above:
◉ Service providers who provide IT and system administration services
◉ Professional advisers including lawyers, bankers, auditors, and insurers
◉ Regulators and other authorities who require reporting of processing activities in certain circumstances
◉ Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We may share your personal data within Cence. This may involve transferring your data outside the United Arab Emirates (UAE). We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. Many of our external third parties may be based outside the UAE, so their processing of your personal data will involve a transfer of data outside the UAE. Whenever we transfer your personal data out of the UAE, we ensure a similar degree of protection is afforded to it by implementing safeguards.
We may transfer your personal data outside the UAE, but only in compliance with the UAE PDPL. Such transfers will occur only with your explicit consent or under other lawful conditions, such as the implementation of appropriate safeguards.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
We retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy. Specifically:
- Financial data: Retained for 5 years from the date of last use.
- Location data: Retained for 1 year from the date of collection.
- Account information: Retained for 3 years after account closure.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
◉ Request access to your personal data
◉ Request correction of your personal data
◉ Request erasure of your personal data
◉ Object to processing of your personal data
◉ Request restriction of processing your personal data
◉ Request transfer of your personal data
◉ Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact us at
hello@cencepay.com.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. LOCATION INFORMATION
COLLECTION AND USE OF LOCATION DATA
When you use our mobile application, we may collect and process information about your actual location if you enable location services. We use this information to provide you with location-based card recommendations and to help you find nearby merchants offering benefits with your cards.
We collect and process your location data only with your explicit consent. This data is used solely to provide you with location-based card recommendations and offers. You can disable location services at any time through your device settings.
YOUR CHOICES REGARDING LOCATION INFORMATION
You can choose whether or not to allow the Platform to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of the Platform may then be inaccessible or not function properly, such as our location-based card recommendations feature.
11. FINANCIAL DISCLAIMER
The information provided through the Platform is for general informational purposes only and is not intended to be financial, investment, tax, or legal advice. Cence is not a financial advisor, and the use of the Platform does not create a financial advisor-client relationship.
The information we provide about credit cards, their benefits, rewards, and features is based on publicly available information and is subject to change at any time by the card issuers. While we strive to provide accurate and up-to-date information, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability of the information contained on our Platform.
12. UPDATES TO THIS PRIVACY POLICY
We may amend this Privacy Policy from time to time to keep it up to date with legal requirements and the way we operate our business. If we decide to change our Privacy Policy, we will place any updates on this webpage and notify you of any material changes.
13. LEGAL
Without prejudice to your rights under applicable laws, our Privacy Policy is not a contract and does not create any legal rights or obligations.
