Privacy Policy

Last updated: 9 June 2026

PolyPay FZC ("PolyPay", "we", "us", or "our") operates the PolyPay platform in compliance with the United Arab Emirates federal laws, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "UAE Data Protection Law") and CBUAE Payment Token Services Regulation (PTSR). This Privacy Policy explains how we collect, use, store, and share your personal data when you use our services.

1. Information We Collect

Account Information. When you register, we collect your name, email address, phone number, and business details (if applicable).

KYC / AML Data. To comply with CBUAE regulations, we collect government-issued ID, passport information, proof of address, and beneficial ownership details.

Transaction Data. We record payment amounts, sender/receiver wallet addresses, timestamps, device information, and IP addresses for every transaction processed through our platform.

Usage Data. We collect analytics on how you interact with the platform, including page views, feature usage, session duration, and error logs.

2. How We Use Your Data

Process and settle payments on the Polygon blockchain
Verify identity under CBUAE KYC/AML requirements
Detect and prevent fraud, money laundering, and terrorist financing
Improve platform performance and user experience
Comply with legal obligations and regulatory reporting
Send service-related communications (receipts, security alerts)

3. Legal Basis for Processing

We process your data based on: (a) your consent, (b) performance of a contract (the Terms of Service), and (c) compliance with legal and regulatory obligations under UAE law.

4. Data Sharing

We may share your data with:

Regulators: CBUAE, UAE Central Bank, and other competent authorities as required by law
Service Providers: Polygon blockchain infrastructure, cloud hosting (within UAE), identity verification partners
Payment Partners: Stablecoin issuers (Circle USDC) and settlement networks

We do not sell your personal data to third parties.

5. Data Retention

We retain your data for the duration of your account plus five (5) years thereafter to comply with UAE financial record-keeping regulations. Transaction records are retained for a minimum of ten (10) years.

6. Your Rights

Under UAE data protection law, you have the right to:

Access the personal data we hold about you
Request correction of inaccurate data
Request deletion of data (subject to regulatory retention requirements)
Object to or restrict certain processing activities
Data portability

7. Data Security

We implement industry-standard security measures including AES-256 encryption at rest, TLS 1.3 in transit, multi-factor authentication, and regular security audits. Our infrastructure is hosted within UAE data centres certified for financial services.

8. International Transfers

Your data is primarily stored within the UAE. If transfer outside the UAE is necessary (e.g., for blockchain settlement), we ensure adequate safeguards are in place under UAE data protection law.

9. Contact

For privacy-related inquiries, please contact our Data Protection Officer at dpo@polypay.ae or write to: PolyPay FZC, Building H1, Sharjah Research Technology and Innovation Park, Sharjah, UAE.