Privacy Policy
This Privacy Notice (“Notice”) sets out how we at CreditPool Technologies Limited (“CreditPool”, “we”, “our” or “us”) use, protect and share the personal information that we collect from you when you use our website, our payment-splitting technology, or when you interact with us or contact us in any other way.
Our activities regarding the collection, use, sharing, and processing of your personal information are set out in this Notice.
WHO ARE WE?
WHAT INFORMATION DO WE COLLECT FROM YOU?
HOW AND WHY DO WE USE YOUR PERSONAL INFORMATION?
HOW CAN YOU MANAGE YOUR MARKETING PREFERENCES?
WHAT ABOUT COOKIES?
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
WHAT HAPPENS IF WE SHARE YOUR INFORMATION WITH ORGANISATIONS OUTSIDE OF THE UAE?
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
WHAT ARE YOUR RIGHTS IN RELATION TO THE PERSONAL INFORMATION WE HOLD?
CONTACT US IF YOU HAVE A QUESTION OR A COMPLAINT
UPDATES TO THIS PRIVACY NOTICE
THIRD PARTY LINKS
WHO ARE WE?
CreditPool Technologies Limited is the data controller responsible for your personal information. This means that we are responsible under Data Protection Laws for ensuring that your personal information is protected and properly processed.
Our full company details are:
Legal entity name: CreditPool Technologies Limited.
Company registration: A private company limited by Shares, organised and existing under the laws of Dubai International Financial Centre with license number CL9422.
Registered office: Unit GA-00-SZ-L1-RT-208, Level 1, Gate Avenue – South Zone, Dubai International Financial Centre.
Email address: support@creditpool.io
You can contact us at the above address should you have any questions about this Notice, or if you would like to exercise any of your rights under Data Protection Laws, which we set out below.
As a DIFC-incorporated entity, we are subject to the DIFC Data Protection Law (DIFC Law No. 5 of 2020) and the DIFC Data Protection Regulations.
WHAT TYPES OF INFORMATION DO WE COLLECT FROM YOU?
We may collect, use, store and transfer different kinds of personal information (including personal data as defined under applicable laws such as the DIFC Data Protection Law (DPL 2020) and DIFC Data Protection Regulation) about you such as:
• Identity and Contact Information about you including first name, last name, any previous names, title, date of birth, nationality, email addresses, phone numbers and addresses.
• Payment and Transaction Information including your bank account and payment card details, details about payments to and from you and other details of services you have purchased from us, transaction timestamp, transaction amount, merchant name / merchant ID, cart or order reference ID, Telr transaction ID / payment reference, internal user ID linking transaction to user, payment method identifiers (e.g., tokenized references, last 4 digits), split allocations (amount charged to each card), transaction status (success, failure, refund), registered payment method references
• Technical and Usage Information including a device collection session ID used solely for transaction processing purposes (collected and managed by our payment service provider, Telr). IP addresses, browser type, operating system, and device details are not stored by CreditPool directly.
• Marketing and Communications Information including your preferences in receiving marketing from us and our third parties and your communication preferences.
• Interactions Information including emails, chat requests, support requests and associated metadata.
Guest Checkout: If you use our guest checkout feature, we collect only the information necessary to process your payment (such as your name, email address, and payment details required for the transaction). No account is created and your information is not retained beyond the period necessary to complete and record the transaction, subject to our legal retention obligations.
We also collect, use and share Aggregated Information such as statistical or demographic data for any purpose. Aggregated Information could be derived from your personal information but is not considered personal information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Technical and Usage Information to calculate the percentage of users accessing a specific feature, behavioural indicators etc. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Notice.
We do not intentionally collect Special Categories of Personal Data as defined under Article 10 of the DIFC Data Protection Law.
HOW AND WHY DO WE USE YOUR PERSONAL INFORMATION?
How your information is collected:
• When you interact with us: you may share your personal information with us when you provide information using any online form on our website or when you correspond with us by email, post, telephone or any other means.
• Automated Technologies and Cookies: as you interact with our website, we will automatically collect Technical and Usage Information about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies. Please see our full Cookies Notice creditpool.io/cookies for further details.
• From third parties: we may obtain your personal information from available third parties (which, when combined with other personal information we may have of yours, may also constitute personal information) including Site and platform providers and marketing providers, and Telr.
How your information is used:
Data Protection Laws require us to have a legal basis for everything that we do with your personal information falling under one of the following categories:
- Performance of a contract with you: Where we need to perform a contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal information where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and/or enable us to give you the best user experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Legal obligation: We may use your personal information where it is necessary for compliance with a legal obligation that we are subject to.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal information for a specified purpose, in relation to receiving marketing emails from us.
- Vital Interests: We may process your personal information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
We use your personal information in a number of different ways and for different reasons – the tables below set out what we do and why:
Identity and Contact Information
| What do we do? | Why do we do it? | What is the Legal Basis? |
| Collect and store your name, email, phone number, date of birth, and address details; | To create and manage your account, verify your identity, and communicate with you. | Performance of a contract with you. |
| Use your contact details to send service-related communications. | To notify you about transactions, account activity, and security events. | Performance of a contract with you. Legitimate interests: to ensure users receive essential service and security notifications. |
| Use your contact details for customer support interactions. | To respond to queries, resolve issues, and provide assistance. | Performance of a contract with you. Legitimate interests: to maintain high-quality customer support. |
| Identify you when you visit our website or you contact us for any reason. | So we can identify you. | Legitimate interests: necessary for us to be able to communicate with you. |
| To send you information about our company. | So we can let you know about new products and services that we offer that you might be interested in. | Consent. Legitimate interests: necessary to promote our business. |
| To send you surveys and to ask for feedback. | To offer you the opportunity to let us know how we are doing, or to let us know your views on another subject. | Legitimate interests: necessary to ensure we are providing the best service and to identify any areas of potential improvement. |
| Retain contact records for compliance and support. | To meet regulatory and operational requirements. | Legal obligation. |
Payment and Transaction Information
| What do we do? | Why do we do it? | What is the Legal Basis? |
| Process transaction amounts, timestamps, merchant details, and order references. | To facilitate and complete your multi-card payment. | Performance of a contract with you. |
| Receive tokenised payment method identifiers and split allocations. | To execute your chosen payment split and route charges to each card. | Performance of a contract with you. |
| Record transaction status (success, failure, refund) and payment references. | To maintain accurate transaction records and support dispute resolution. | Performance of a contract with you. Legal obligation. |
| Store internal user IDs linking transactions to your account. | To ensure accurate attribution of payments and prevent fraud. | Legitimate interests: fraud prevention and accurate transaction reconciliation. |
| To keep a record of our transactions with you. | For accounting purposes. | Legal obligation. |
| Generate or receive fraud-screening indicators and risk flags. | To prevent fraud, protect users, and safeguard the platform. | Legitimate interests: fraud detection and prevention. |
| Retain records required for financial, audit, or regulatory compliance. | To comply with DIFC and financial services obligations. | Legal obligation. |
| Monitor for suspicious or prohibited activity. | To ensure platform safety and meet regulatory expectations. | Legal obligation. Legitimate interests: protecting the business and users from misuse. |
Technical and Usage Information
| What do we do? | Why do we do it? | What is the Legal Basis? |
| Identify you when you visit our websites. | To provide you with the best possible user experience. | Legitimate interests: necessary to provide the best user experience. |
| Monitor visitors to our websites and analyse their use of the websites and perform tests on our IT systems. | To protect our websites and our IT systems from fraud or cyberattacks and to improve our websites and our services and our IT security. | Legitimate interests: necessary to ensure our systems are secure and to protect against IT security incidents. Legal obligation. |
| Administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | For running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise. | Legitimate interests: necessary to run our business and to provide effective and secure administration and IT services, network security and to prevent fraud. Necessary to comply with a legal obligation. |
| Deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. | To study how customers use our services, to develop them, to grow our business and to inform our marketing strategy. | Legitimate interests: necessary to optimise our marketing efforts and deliver targeted advertisements. |
| Use data analytics to improve our website, services, marketing, customer relationships and experiences. | To define types of customers for our services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy. | Legitimate interests: necessary to enhance our business strategies and improve customer satisfaction. |
| Collect IP address, device type, browser information, and session metadata. | To secure the platform, detect suspicious activity, and troubleshoot issues. | Legitimate interests: ensuring platform security and preventing fraudulent or abusive use. |
| Log login activity and technical events. | To protect user accounts and maintain system integrity. | Legitimate interests: detecting unauthorised access and maintaining service reliability. |
| Use technical metadata during transactions. | To ensure the service functions correctly and reliably. | Performance of a contract with you. Legitimate interests: diagnosing and resolving technical issues. |
Marketing and Communications Information
| What do we do? | Why do we do it? | What is the Legal Basis? |
| We keep a record of your communication preferences (your “opt ins” and “opt outs”). | So we can make sure that you only receive the communications from us that you would like to receive and so we can update our records if you change your mind. | Legitimate interests: necessary to promote our business. Legal obligation. |
| Send you electronic and text marketing. | To inform you about offers, events, and updates that may interest you. | Consent. Legitimate interests: soft opt-in where applicable. |
Interactions Information
| What do we do? | Why do we do it? | What is the Legal Basis? |
| We use your data to provide the services and to continually improve and develop them. | So we can make sure our services continue to be fit for purpose and to develop their commercial offering. | Performance of a contract with you. Legitimate interests: necessary to improve our services. |
| Enable customer support and feedback messaging. | To assist with queries and ensure services quality. | Legitimate interests: to maintain operational efficiency. Performance of a contract with you. |
| Store communication metadata (timestamps, channels). | To maintain service quality and audit trails. | Legitimate interests: quality assurance and dispute resolution. |
| Use communication history to improve support processes. | To train support workflows and enhance user experience. | Legitimate interests: improving customer service and operational efficiency. |
All Personal Information
| What do we do? | Why do we do it? | What is the Legal Basis? |
| We may transfer your personal information in part or whole in connection with any merger, sale, transfer of our assets, restructure, investment, acquisition, bankruptcy, or similar event or corporate transaction | So we can ensure the continued service and function and to ensure we can protect and grow our business. | Legitimate interests: to ensure we can protect and grow our business. |
| Comply with legal and regulatory obligations. | So we can meet our legal responsibilities. | Legal obligation. |
| Retain your personal information to establish, exercise, or defend legal claims. | So we can protect our, or third parties’, interests. | Legitimate interests: to seek legal advice, protect ourselves, or others in legal proceedings. |
In limited circumstances we may process any of the personal information we hold to the extent necessary to defend, establish and exercise legal claims or to comply with legal or regulatory obligations.
Where we need to collect personal information due to a legal or regulatory obligation, or for performance of a contract, and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). We will notify you of this at the time.
HOW CAN YOU MANAGE YOUR MARKETING PREFERENCES?
We will provide you with the opportunity to “unsubscribe” via a link at the bottom of any marketing communication that we send to you, or you can contact us at support@creditpool.io
Please note that if you “unsubscribe” from receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.
WHAT ABOUT COOKIES?
For more information about the cookies we use and how to change your cookie preferences, please see our Cookies Notice here [creditpool.io/cookies].
We store an authentication token in your browser’s local storage to keep you logged in to your account. We do not use tracking cookies, analytics cookies, or advertising cookies.
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We do not sell your personal information, nor share it with third parties outside of the reasons outlined below, except as permitted or required by applicable law.
We may share your personal information with third parties who provide services to us, including Telr (our payment service provider, acting as a separate data controller for payment processing, tokenisation, and settlement) and Amazon Web Services (AWS) (our cloud hosting provider, acting as a data processor). We do not use CRM, email marketing automation, or analytics tools at this time. We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
We may share your personal information with third parties in the following circumstances:
- We will share your personal information internally between Creditpool and our investors to the extent required for internal administrative purposes, management purposes or other business-related purposes;
- When we engage third party service providers to provide services to us (for instance, IT & website hosting, email providers, CRM, communications and analytics service providers, who are contractually obligated to protect your data and use it only for the purposes we specify;
- With professional advisors such as tax or legal advisors (for example, as necessary for the establishment, exercise or defence of legal claims or to protect the rights or safety of the websites, our services or us;
- With consultants, insurance companies/claim managers and accountants;
- With agents, suppliers or sub-contractors and other associated organisations where they are engaged by us to help deliver a service that we have instructed them on;
- In order to operate the website, including hosting, maintenance, and analytics;
- We also disclose your personal information with third parties if disclosure is required by law or in the context of an investigation, regulatory requirement, judicial proceeding, court order or legal process (including to law enforcement or competent authorities like the police/tax authorities);
- In order to protect against our liability and ensure safety, including fraud prevention and security measures;
- With third parties in case of a corporate transaction. In addition, information about our customers and users, including personal information, may be disclosed as part of any merger, sale, transfer of our assets, investment, acquisition, bankruptcy, or similar event, including while engaging with our actual or potential investors;
- To fulfil the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information; and
- With your consent.
Required by law. We may be required to disclose personal information as part of a legal process. We may also be required to disclose personal information in response to lawful requests by government authorities, including requests from national security agencies or law enforcement. Some of these requests may be by regulatory oversight agencies investigating a complaint, while others may be by law enforcement seeking information. We will comply with such requests only to the extent required by law and will seek to limit disclosure where possible.
We may provide anonymous information to analytics and search engine providers to help us improve and optimise our services. We will only share this information in a form that does not directly identify you.
WHAT HAPPENS IF WE SHARE YOUR INFORMATION WITH ORGANISATIONS OUTSIDE OF THE UAE?
Whenever we transfer your personal information outside of the UAE to service providers or any other third party, we ensure a similar degree of protection is afforded to it by ensuring that the necessary safeguards are in place, for example:
• We will only transfer your personal information to countries that have been deemed by regulators in the UAE to provide an adequate level of protection for personal information; or
• We may use specific standard contractual terms approved for use in the UAE which give the transferred personal information the same protection as it has in the UAE.
For more information about these safeguards, please contact us at support@creditpool.io
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We are committed to protecting individuals’ personal information. We put in place appropriate technical and organisational measures to help protect the security of your personal information. However, be aware that no system is ever completely secure.
We have put various safeguards in place to guard against unauthorised access and unnecessary retention of personal information in our systems. These include pseudonymisation, encryption, access, and retention policies.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. For further information about specific retention periods, please contact us at privacy@creditpool.io
Our standard retention periods are as follows: transaction and payment data is retained for 6 years from the date of the transaction; active user account data is retained for as long as your account remains active; deactivated account data is moved to a restricted archive within 30 days of your deletion request and permanently deleted after 6 years and 30 days from that request; authentication tokens are stored only for the duration of your session and not persisted; marketing preferences are retained until you withdraw your consent.
WHAT ARE YOUR RIGHTS IN RELATION TO THE PERSONAL INFORMATION WE HOLD?
You have a number of rights under data protection laws in relation to your personal information.
You have the right to:
• Request access to your personal information (commonly known as a “subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal information in certain circumstances. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal information for direct marketing purposes.
• Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in one of the following scenarios:
• If you want us to establish the data’s accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us at
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
CONTACT US IF YOU HAVE A QUESTION OR A COMPLAINT
You have the right to make a complaint at any time to the the DIFC Commissioner of Data Protection (the data protection regulator for DIFC-incorporated entities). We would, however, appreciate the chance to deal with your concerns before you approach any regulator, so in the first instance please contact us at support@creditpool.io
UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time and we keep it under regular review. This version was last updated on 04 February 2026.
THIRD-PARTY LINKS
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.