FLUENCE PAY PRIVACY POLICY

Last Updated: [1st Feb 2026]

Fluence Pay FZ-LLC ("Fluence Pay," "we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use:

  • Our mobile application "Fluence Pay"
  • Our website www.fluencepay.com
  • Any related products, services, cards, wallets, or features (collectively, the "Platform" or "Services").

This Policy should be read together with our Terms & Conditions.

1. Who We Are

Fluence Pay FZ-LLC is a company incorporated in Dubai, United Arab Emirates, with its registered office at in5 Tech, Dubai Internet City, Dubai, UAE.

We operate a MarTech–FinTech platform that enables users to earn rewards, cashback, and other benefits by making purchases and sharing authentic experiences on social media.

2. Applicability

This Privacy Policy applies to:

  • Users of the Fluence Pay Platform
  • Applicants for Fluence Pay cards or financial products
  • Creators, influencers, and advocates using our services
  • Visitors to our website

By using our Services, you consent to the practices described in this Privacy Policy.

3. Information We Collect

3.1 Information You Provide Directly

We may collect:

Identity & Contact Data

  • Full name
  • Email address
  • Phone number
  • Date of birth
  • Residential address

Profile & Demographic Data

  • Employment type and workplace
  • Income range
  • Preferences and interests
  • Other demographic data you choose to provide

Account & KYC Data

  • Identification documents (where required)
  • Selfies or verification images
  • Information required by regulated financial partners

3.2 Social Media Data

With your permission, we collect and process data from linked social accounts (e.g., Instagram, TikTok), including:

  • Public profile data
  • Posts, captions, and engagement metrics
  • Follower counts and audience insights
  • Content performance data

We only access data necessary to provide Services and in line with platform permissions.

3.3 Device & Technical Data

We may collect:

  • Device type and OS
  • IP address
  • App usage logs
  • Crash reports
  • Location data (if enabled)
  • Installed applications data (where required for fraud prevention or eligibility checks)

3.4 Financial & Transaction Data

When you use cards, wallets, or redemption services via partners:

  • Transaction history
  • Merchant information
  • Cashback and reward records
  • Wallet balances

Sensitive financial data is primarily processed by regulated partners.

3.5 Communications

  • Emails
  • Chat support messages
  • Customer service interactions
  • Survey responses

4. How We Use Your Information

We use your data to:

Service Delivery

  • Create and manage accounts
  • Process cashback, points, and rewards
  • Enable redemptions and financial features
  • Facilitate brand collaborations

Verification & Compliance

  • Identity verification
  • Fraud detection and prevention
  • Regulatory compliance (KYC/AML where applicable)

Platform Improvement

  • Analytics and research
  • Performance tracking
  • Feature development

Personalization

  • Tailored offers and brand campaigns
  • Relevant rewards and merchant deals

Communications

  • Service updates
  • Security alerts
  • Promotional messages (where permitted)

5. Legal Basis for Processing (UAE PDPL aligned)

We process personal data based on:

  • Your consent
  • Performance of a contract
  • Legal and regulatory obligations
  • Legitimate business interests (e.g., fraud prevention, platform security)

6. Sharing of Information

We may share data with:

6.1 Financial & Service Partners

  • Banks
  • Card issuers
  • Wallet providers
  • Redemption partners
  • Payment processors

6.2 Technology & Analytics Providers

  • Cloud hosting providers
  • Analytics tools
  • Customer support tools

6.3 Legal & Regulatory Authorities

Where required by law, court order, or government request.

6.4 Brands & Merchants

Limited data necessary for campaigns, reward validation, and reporting.

We do not sell personal data to third parties.

7. Aggregated & Anonymized Data

We may use anonymized, aggregated data for:

  • Market insights
  • Benchmarking
  • Research
  • Industry reporting

Such data does not identify individuals.

8. Data Retention

We retain data only as long as necessary for:

  • Service delivery
  • Legal and regulatory compliance
  • Dispute resolution
  • Fraud prevention

When no longer required, data is securely deleted or anonymized.

9. Data Security

We implement reasonable safeguards including:

  • Encryption
  • Access controls
  • Secure servers
  • Monitoring systems

However, no internet transmission is fully secure. Users are responsible for safeguarding credentials and OTPs.

10. International Data Transfers

Your data may be processed outside the UAE where our partners operate. We ensure appropriate safeguards are in place for cross-border transfers.

11. Your Rights

Subject to applicable law, you may have the right to:

  • Access your data
  • Correct inaccurate data
  • Withdraw consent
  • Request deletion
  • Restrict or object to processing
  • Request data portability

Requests can be sent to: contact@fluencepay.com

12. Children's Privacy

Our Services are intended for users 18 years and above. We do not knowingly collect data from minors.

13. Cookies & Tracking

Our website and app may use:

  • Cookies
  • SDKs
  • Analytics tools

to improve user experience and measure performance.

You can manage cookies via browser settings.

14. Third-Party Links

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

15. Account Deactivation

Users may request deactivation by emailing:

contact@fluencepay.com

Some data may be retained for legal or compliance reasons.

16. Updates to This Policy

We may update this Privacy Policy periodically. Material updates will be notified via app, email, or website notice.

17. Contact Us

For privacy concerns or requests:

Fluence Pay FZ-LLC
in5 Tech, Dubai Internet City
Dubai, UAE

📧 contact@fluencepay.com