Privacy Policy
C3 Pay App
1. About this privacy policy
This privacy policy applies to the personal data processing of current customers.
2. Data controller
Edenred Prepaid Cards Management Service LLC (“Edenred UAE”) is a prepaid cards management Services provider,
offering its service to Corporate Clients across the UAE to process salary for their employees in compliance
with the WPS regulations.
Edenred UAE, whose head office is located at Floor 43, Single Business Tower, Business Bay, Dubai (UAE), is the
data controller of your personal data processed for the purpose(s) defined hereafter.
3. Origin of the data
We process the personal data that you provide directly to us when you contact us, fill out our forms, sign a
contract with us, and/or visit our website.
4. Purposes of the processing
Your personal data is processed by Edenred UAE for the purposes of:
Edenred’s AML/CFT, Sanction and Customer Due Diligence Policy
Satisfaction of Edenred’s Compliance Review process.
Compliance with Regulatory, such as AML regulations, or Contractual Obligations
Communications from Edenred regarding purchases, changes to our Privacy Policy and/or Terms and Conditions.
Internal administrative and accounting, auditing, data analysis, analytics, marketing and research purposes.
Data storage of users’ preference
User account management as well as user support
5. Categories of personal data concerned
Personal Details such as:
Personal details and civil status (First name, last name, birth date, nationality, gender)
Identification details (Passport Number and Expiry Date, Passport Copy, Emirates Identity Card Number and Expiry
Date, Emirates Identity Card Copy, Selfie verification)
Address details (an Identity Card with Proof of Address, or documents such as Title Deeds, Rental Agreement or
Water and Electricity bills)
Contact details (Mobile phone, email address)
Financial details (WPS Person ID, WPS Establishment, Balance)
6. Legal basis of the processing
Those personal data processing activities are respectively legally grounded on:
UAE Cabinet resolution Decision No. 58 of 2020 regulating Beneficial Owner Procedures
UAE Cabinet resolution Decision No. 10 of 2019 on the implementation of decree law 20 of 2018 on Anti- Money
Laundering and Combating the Financing of Terrorism and Illegal Organisations
UAE Cabinet resolution Decision No.74 of 2020 on the implementation of the Targeted Financial Sanctions of the
UNSC
Ministerial Resolution No. 598 of 2022 on exception Regarding Wages Protection System
Administrative Decision No. 23 of 2022
7. Mandatory fields
The fields that are marked with an Asterix (*) are mandatory. Therefore, if you do not provide the information
requested, we won’t be able to manage your request.
8. Recipients of the personal data
Your personal data will be accessible to the authorized personnel of Edenred UAE each of them with dedicated
access rights according to their scope of work.
Your personal data will not be disclosed to third parties except, as necessary. along with their own
subcontractors, which are expressly authorized by Edenred UAE for the performance of the service provider.
Moreover, your personal data may be disclosed to the following recipients:
Public Administration, Law enforcement agencies, Courts, and/or Tribunals as required by law or to defend
against claims.
Accounting audit companies for compliance with our legal obligations in matters of accounting.
Service providers that need access to your data in order to provide the services that we have contracted to
them. The required confidentiality and data processing contracts are signed between these providers and us in
order to protect your privacy.
Other third parties and their advisors in the context of any structural modification operation of our company,
or the contribution or transfer of any business or branch of business, as well as transmitting the same to said
third party in the case of execution of the operation. Said data disclosure will be carried out on the basis of
our legitimate interest consisting in the correct governance of the same.
9. Transfer of the personal data
Edenred UAE ensures that your personal data collected for the previously stated purposes will not be transferred
outside the UAE in the absence of the following:
The country to which the Personal Data is being transferred to has adequate controls, laws, provisions, rules
and measures to ensure the privacy and confidentiality of said Data, including your individual rights. (Personal
Data Protection Law)
Transfer of data must be in compliance with the conditions stated in the Federal Decree law 45 of 2021 on
personal data protection – Article. 23 about cross-border and sharing of personal data for processing purposes
In absence of an adequate level of protection.
The UAE has a bilateral or multilateral Agreement with regards to Data Protection. (Personal Data Protection
Law)
10. Retention of the personal data
Your personal data is retained by Edenred UAE for “at least 5 years” the time that is necessary for the
realization of the processing purposes. Following this event, your data will be sorted out and the remaining
data will only be retained for legal purposes, such as for compliance, in accordance with the local laws and
regulations,
11. Updates to this privacy policy
We may update this Privacy Policy from time to time and will notify you of said changes and updates as required
by the data protection legislation.
12. Exercise of rights for data subject
In accordance with the applicable regulation, you are entitled to access to, rectify but also erase your data
(unless your personal data is necessary to comply with a legal obligation). Under certain circumstances and the
conditions set forth in the applicable law, you also have a right to object to and to obtain restriction of the
data processing activity, to withdraw your consent where the processing of your personal data is based on your
consent, and a right to data portability.
You can exercise your rights, enclosing proof of identity where required, by sending an email to or by writing
to Edenred UAE – P.O. Box 34920, Dubai (UAE)
For any other type of requests or complaints, you can contact the Data Protection Correspondent by sending an
email to eae.dpo@edenred.com
If you want to exercise your rights, please click here.