1. Introduction

DECODE LLC ("DECODE," "we," "us," or "our") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website and use our services.

DECODE operates in accordance with the laws of the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data and its amendments.

By accessing or using our website and services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use our services.

2. Information we collect

2.1 Information you provide to us

We collect information that you voluntarily provide to us when you:

• Register for an account
• Use our services or platform
• Contact us for support or inquiries
• Subscribe to our newsletter or marketing communications
• Participate in surveys or promotions

This information may include:

• Personal identification information (name, email address, phone number)
• Business information (company name, business address, tax identification number)
• Payment information (credit card details, billing address)
• Payout account information (bank account number, IBAN, routing codes, bank name, or PayPal account details) for processing payouts to your business
• Bank verification documents (bank statements or verification letters to confirm account ownership)
• Communication preferences and any other information you choose to provide

2.2 Information automatically collected

When you access our website, we may automatically collect certain technical information, including:

• Device information (device type, operating system, browser type)
• Connection information (IP address, internet service provider)
• Usage data (pages visited, time spent on pages, links clicked)
• Referral sources and exit pages

2.3 Cookies and tracking technologies

DECODE does not use cookies, web beacons, or similar tracking technologies on our website. We collect only essential technical information required for the operation and security of our services.

3. How we use your information

We use the information we collect for the following purposes:

• To provide, operate, and maintain our services
• To process transactions and send you related information
• To process payouts to your registered bank account or PayPal account
• To verify your bank account ownership and prevent fraud
• To communicate with you, including customer service and support
• To send you technical notices, updates, and security alerts
• To respond to your inquiries and provide customer support
• To improve our website and services
• To detect, prevent, and address technical issues and fraud
• To comply with legal obligations and enforce our Terms of Service
• With your consent, to send you marketing and promotional communications

4. Legal basis for processing

We process your personal information based on the following legal grounds:

• Contractual necessity: Processing is necessary to perform our contract with you or to take steps at your request before entering into a contract
• Consent: You have given us explicit consent to process your personal information for specific purposes
• Legitimate interests: Processing is necessary for our legitimate business interests, such as improving our services, fraud prevention, and ensuring security
• Legal obligations: Processing is necessary to comply with applicable laws and regulations in the UAE

5. Information sharing and disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following limited circumstances:

5.1 Service providers

We may share your information with trusted third-party service providers who assist us in operating our website, conducting our business, or servicing you. These service providers are contractually obligated to keep your information confidential and use it only for the purposes we specify.

Payment processing and payout services. We share your bank account information with our licensed payment service providers solely for the purpose of processing daily payouts to you. These providers include bank transfer processing services, PayPal, and other PCI DSS Level 1 compliant payment processors. All payment service providers are contractually obligated to protect your financial information and use it only for authorized payout processing.

5.2 Business transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of that transaction.

5.3 Legal requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities, including to meet national security or law enforcement requirements in the UAE.

5.4 Protection of rights

We may disclose information when we believe it is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

6. Data security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Regular security assessments and audits
• Access controls and authentication procedures
• Secure backup and disaster recovery procedures

Additional security measures for financial information. We implement enhanced security measures for sensitive financial information, including bank account details:

• Bank account information is encrypted using AES-256 encryption
• Access to financial data is restricted to authorized finance personnel only
• We process all payouts through PCI DSS Level 1 compliant providers
• Regular security audits of payment processing systems

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security.

7. Data retention

We retain your personal information 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. The retention period depends on:

• The nature of the information collected
• The purpose for which it was collected
• Legal, regulatory, or operational requirements

We retain your bank account details for the duration of your active account and for 7 years following account closure to comply with UAE financial regulations, process any delayed transactions, handle refunds, or resolve chargebacks. Bank account information is securely deleted after this retention period expires.

When we no longer need your personal information, we will securely delete or anonymize it in accordance with UAE data protection laws.

8. Your rights and choices

Under UAE data protection laws, you have the following rights regarding your personal information:

• Right to access: You can request access to the personal information we hold about you
• Right to rectification: You can request correction of inaccurate or incomplete personal information
• Right to erasure: You can request deletion of your personal information, subject to legal and contractual obligations
• Right to restriction: You can request limitation of processing of your personal information
• Right to object: You can object to processing of your personal information for certain purposes
• Right to data portability: You can request to receive your personal information in a structured, commonly used format
• Right to withdraw consent: Where processing is based on consent, you can withdraw your consent at any time

To exercise any of these rights, please contact us using the information provided in Section 13. We will respond to your request within the timeframe required by UAE law.

While you have the right to request deletion of your personal information, UAE financial regulations require us to retain bank account details for 7 years following account closure. During this retention period, your bank account information will be securely stored with restricted access and will only be used if legally required (e.g., audit, dispute resolution). It will be permanently deleted after 7 years.

9. Marketing communications

If you have opted in to receive marketing communications from us, you may opt out at any time by:

• Clicking the "unsubscribe" link in any marketing email
• Contacting us directly using the information in Section 13
• Updating your communication preferences in your account settings

Please note that even if you opt out of marketing communications, we may still send you non-promotional messages related to your account and our services.

10. Third-party links and services

Our website may contain links to third-party websites or services that are not owned or controlled by DECODE. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review the privacy policies of any third-party websites you visit.

11. Children's privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information, we will take steps to delete such information. If you believe we have collected information from a child, please contact us immediately.

12. International data transfers

Your personal information may be transferred to and processed in countries other than the UAE. When we transfer personal information internationally, we ensure that appropriate safeguards are in place to protect your information in accordance with UAE data protection laws and international standards.

13. Contact us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We aim to respond to all legitimate requests within 30 days or as required by UAE law.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational, legal, or regulatory reasons. We will notify you of any material changes by:

• Posting the updated Privacy Policy on our website with a new effective date
• Sending you an email notification if you have provided us with your email address

Your continued use of our services after any changes indicates your acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically.

15. Governing law and jurisdiction

This Privacy Policy is governed by and construed in accordance with the laws of the United Arab Emirates.

16. Data protection compliance

We regularly review and update our data protection practices to ensure ongoing compliance with applicable laws and regulations.

17. Acknowledgment

By using our website and services, you acknowledge that:

• You have read and understood this Privacy Policy
• You consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy
• You understand your rights regarding your personal information
• You agree to comply with this Privacy Policy and our Terms of Service