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PRIVACY POLICY

1. Introduction

At GrowX Global FZ-LLC (“GrowX Global”, “we”, “our”, “us”), we are committed to protecting your privacy and ensuring that your personal and financial data is handled responsibly, transparently, and securely.

This Privacy Policy explains how we collect, use, store, share, and protect your data when you use our mobile application, web platform, APIs, or other services that connect you with licensed financial institutions under the Central Bank of the UAE (CBUAE) Open Finance Framework.

Our Privacy Policy complies with:

By using our services, you acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree, please stop using our services immediately.

2. About GrowX Global

GrowX Global FZ-LLC is a UAE-registered financial technology company (Trade License No. [Insert]) operating as a Third Party Provider (TPP) under the CBUAE Open Finance Framework.

We provide the following regulated open finance services:

We act as a data controller when collecting your personal data directly and as a data processor when handling data obtained from your bank under your explicit consent.

3. What Data We Collect

3.1. Personal Information

3.2. Financial Information (with Consent)

3.3. Technical Data

3.4. Communication Data

4. How We Use Your Data

We process your data lawfully and transparently for the following purposes:

PurposeExampleLegal Basis
Providing open finance servicesDisplaying aggregated bank account dataExplicit consent
Payment initiationExecuting user-authorized transfersExplicit consent
Fund confirmationVerifying available balanceExplicit consent
ComplianceAudit, AML/CFT, and reporting to CBUAELegal obligation
Service improvementSecurity, diagnostics, and analyticsLegitimate interest
Customer supportResponding to inquiriesContractual necessity

We never use your data for advertising or resale, and we will never access your bank credentials.

5. How We Obtain and Manage Your Consent

You will be asked to explicitly authorize GrowX Global before any access to your financial data is made. Consent is collected digitally via the GrowX Global app or portal, where you will see:

You may revoke consent at any time by:

Upon revocation, all tokens and access permissions are immediately invalidated.

6. Data Sharing and Disclosure

We do not sell, lease, or trade your personal or financial information. Data is shared only under the following circumstances:

  1. With Your Authorized Bank(s) – to access data, initiate payments, or confirm funds via CBUAE-certified APIs.
  2. With Regulators or Law Enforcement – to comply with legal or regulatory obligations.
  3. With Approved Service Providers – all bound by PDPL-compliant data processing agreements.

We ensure all third-party processors maintain the same or higher level of data protection.

7. Data Retention and Deletion

We retain your data only as long as required to fulfill the purposes described in this Policy or as mandated by law.

Data CategoryRetention PeriodPost-Period Action
Consent records5 years (CBUAE requirement)Archived or anonymized
Transaction data5 yearsDeleted or anonymized
Technical logs12 monthsDeleted automatically
Customer support data2 yearsSecurely deleted
Analytics dataNon-identifiableRetained indefinitely

After expiration, data is securely erased using AES-256 deletion protocols or anonymized.

8. Data Storage and Cross-Border Transfers

9. Data Security

In case of a data breach, we will notify both you and the CBUAE within 24 hours, as required by regulation.

10. Your Rights Under the PDPL

Contact privacy@growx.global — response within 30 days as per PDPL Article 13.

11. Cookies and Tracking

No third-party marketing cookies are used.

12. Data of Minors

Services are intended for users aged 18+. Data from minors is deleted upon discovery.

13. Data Breach Notification

14. Third-Party Links

Our app or website may link to third-party sites. We are not responsible for their privacy practices.

15. Changes to This Policy

16. Contact Information

17. Acknowledgment

By using GrowX Global’s services, you confirm that you have read and understood this Privacy Policy and consent to the collection and processing of your data.

GrowX Global FZ-LLC
Empowering Open Finance in the UAE securely and responsibly.