Seen Tarbi Privacy Statement

Overview

Seen Tarbi for Financial Technology (X^2) takes privacy and data security very seriously. Seen Tarbi for Financial Technology (X^2) believes in our users\’ right of privacy; this includes the right to have knowledge of which data are collected and for which use(s).

Seen Tarbi for Financial Technology (X^2) also believes in the right of their users to controlling their information and modifying/removing such information at any time.

Seen Tarbi for Financial Technology (X^2) makes their utmost to ensure security and transparency of the methods via which your information is processed and how Seen Tarbi for Financial Technology (X^2) ensures such information is secured and kept confidential.

Seen Tarbi for Financial Technology (X^2) values our users\’ privacy and will at no time sell or share our users\’ personal information.

Description

This policy outlines Seen Tarbi for Financial Technology (X^2)’s methodology and processes to collect, process and store end user data in a consistent method. Our privacy policy is aligned with the principles and standards of international standards and compliant with the KSA management and data protection framework and interim regulations issued by NDMO (the regulatory arm of SDAIA) and compliant with SAMA’s regulations and SAMA’s Cybersecurity framework and the Capital Market Authority Institutions Regulations.

Introduction

Seen Tarbi for Financial Technology (X^2) and/or affiliates currently offer a xxxxx xxxxx (“collectively, the ‘Services\’”), through Seen Tarbi for Financial Technology (X^2)’s website, www.xxx.xxx (“Site”) and our mobile applications (“App”). This Privacy Policy describes how Seen Tarbi for Financial Technology (X^2) treats our users\’ personal information when they are using and/or evaluating our Site, App and/or Services.

For the purposes of this Privacy Policy, a “User” is an individual who creates an account on our Site or App to use our free financial planning software and/or open an investment account and/or to understand or evaluate our Services. Our Privacy Policy, Terms and Conditions, collectively govern our users\’ use and/or evaluation of our Site, App, and Services.

 

Information Collection

Information Categories

Current versus former Users

The categories of information we collect depend on whether you are a current or a former User. Examples of instances when we collect Personal Information include:

  • When you register to open an account as a User.
    • when you contact our client service organization with questions, or
    • when you connect your bank account(s) with us
    • when you go through our Know Your Customer (KYC) process
    • when you open an investment account(s) with us

Wherever Seen Tarbi for Financial Technology (X^2) collects Personal Information, we endeavor to provide a link to this Privacy Policy and other relevant terms.

Collected Personal Information

  • name, e-mail address, telephone number, zip code, Internet Protocol address, birth date;
  • Fund information and other financial planning associated with those accounts you choose to link to our Services, any challenge and/or security questions associated with those accounts and any information contained in those accounts. Note: The section labeled “Information we collect when acting as a user’s authorized agent” provides additional details regarding how we use and protect this information alongside Seen Tarbi for Financial Technology (X^2)’s internal data operations processes in compliance with the KSA management and data protection framework and regulation.

Seen Tarbi for Financial Technology (X^2) collects Personal Information from Users, including but not limited to:

While Acting As A User’s Authorized Agent

Seen Tarbi for Financial Technology (X^2) users may opt to aggregate information from accounts at other financial institutions onto their dashboard on our Site or in our App, despite being not required to do so. Enabling this functionality, allows retrieval of the User account information maintained by such third-party financial institutions with which the User or Customer has an existing customer relationship (“Account Information”), as described in this section.

By linking your accounts, you provide Seen Tarbi for Financial Technology (X^2) access to your Account Information, which may include, your prior and current account balances, your transaction history, and holdings from these linked financial institutions. Segments of these information will be displayed on your Seen Tarbi for Financial Technology (X^2) dashboard.

Seen Tarbi for Financial Technology (X^2) may use the Account Information we retrieve to formulate your financial projections, in connection with purposes consistent with this Privacy Policy and the Services we provide to you. Seen Tarbi for Financial Technology (X^2) may also use aggregated Account Information from our Users for purposes of deciding which products and services to build in the future.


By choosing to use our Services to aggregate and analyze your Account Information, you explicitly authorize and direct Seen Tarbi for Financial Technology (X^2), on your behalf, to electronically retrieve some/all Account Information, associated with, or available via consent that you create through the financial institution’s portal to link such accounts, and to periodically refresh your consent to this retrieved Account Information for so long as the link remains active in alignment with the open banking guidelines issued by the Saudi Central Bank.

Seen Tarbi for Financial Technology (X^2) works with the financial institutions in the collection, use, storage, and handling of data in connection with our account aggregation services. Seen Tarbi for Financial Technology (X^2) works with other third party entities such as the National Information Center to verify your identity and collect KYC data. Seen Tarbi for Financial Technology (X^2) does not have access to the login credentials used to link your third party accounts and retrieve Account Information after the credentials have been transmitted to the financial institutions portal or the National Information Center portals and/or other entities portals.

Any Account Information that Seen Tarbi for Financial Technology (X^2) have access to is read-only, and the Account Information maintained by your third-party institution cannot be altered by Seen Tarbi for Financial Technology (X^2). Seen Tarbi for Financial Technology (X^2) retains Account Information collected via consent based account linking service in accordance with our regulatory record-keeping requirements, as permitted by law and as described elsewhere in this Privacy Policy, and as required in connection with the maintenance of your account and the Services we provide to you.

Seen Tarbi for Financial Technology (X^2) will not share your Account Information with outside parties except in limited cases relating to fraud investigations, pursuant to which we may share limited Account Information with your linked third-party institution, although we also reserve the right to share Account Information with third parties where required by law.

If you choose to remove or revoke a link to an account with a third-party institution you have previously linked, we will not retrieve any new Account Information for that account unless you re-link that account in the future.

Information related to minors

Due to the nature of our business, our Services are not made available to minors. Except for beneficiary information as described above, Seen Tarbi for Financial Technology (X^2) does not knowingly solicit Personal Information directly from or about persons under the age of 18 years old.

If you are under the age of 18 years old, please do not submit any Personal Information to Seen Tarbi for Financial Technology (X^2). If a parent or a guardian becomes aware that his/her child under the age of 18 years old has directly provided us with Personal Information without the guardian’s prior consent, the guardian should contact us at compliance@xxxxx.xxx and we will delete such information from our files unless regulatory obligations, explicitly, prevent us from doing so.

Personal Information Collection

  • Automatic Data Collection. Seen Tarbi for Financial Technology (X^2) may collect certain information when you use our Services. This information may include your Internet protocol (“IP”) address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visited before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
  • Anonymized or Aggregated Information. Seen Tarbi for Financial Technology (X^2)’s Site and App record certain anonymized or aggregated information about your use or evaluation of our Services. Anonymized or aggregated information is used for a variety of functions, including measurement of Users’ interest in and use of various portions or features of the Site and/or App. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including internal analysis and research. We may share this information with third-parties for our purposes in an anonymized or aggregated form that is designed to prevent other parties from identifying you.
  • Cookies and Pixels. Seen Tarbi for Financial Technology (X^2) uses cookies; a small piece of computer code that enables our Web servers to “identify” Users, each time they initiate a session on our Site. A cookie is set in order to identify you and tailor the Site to you. Cookies do not store any of the Personal Information that you provided to us; they are simply identifiers. You may delete cookie files from your local device at any time through your browser settings. However, cookies may be necessary to provide access to much of the content and many of the features of the Site.
  • Pixel Tags. Along with cookies, we may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Sites. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server.
  • Site and App Activity. Seen Tarbi for Financial Technology (X^2) may also use third-party tracking technology, such as Google Analytics, to record similar information regarding you and your activity on our Site and App.
  • “Do Not Track” Technology. Seen Tarbi for Financial Technology (X^2) does not collect Personal Information about your online activities over time and across different websites or online services. Therefore, our Site does not respond to Do Not Track (“DNT”) signals. We do not knowingly authorize third-parties to collect Personal Information about your online activities over time and across different websites or online services. Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.
  • Surveys. Seen Tarbi for Financial Technology (X^2) may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.

How Seen Tarbi uses information

User personal information

Seen Tarbi for Financial Technology (X^2) may use your Personal Information for a variety of business purposes, such as to help you evaluate our Services, offer you new products or services, enhance our Services, and for research and internal analysis.

Identity verification

Seen Tarbi for Financial Technology (X^2) may use third-party vendors to verify your identity as part of the regulatory requirement to verify our user’s identity. Seen Tarbi for Financial Technology (X^2) may access your personal information with the National Information Center.

Cross-device tracking

Your browsing activity may be tracked across different websites and different devices or apps. For example, Seen Tarbi for Financial Technology (X^2) may attempt to match your browsing activity on your mobile device with your browsing activity on your computer. To do this, Seen Tarbi for Financial Technology (X^2) may analyze your browsing patterns, geo-location and device identifiers to match the information of the browser and devices that appear to be used by the same person.

Social media

This Privacy Policy and these terms apply only to Seen Tarbi for Financial Technology (X^2) Services and applications. Please note that our Site and Apps may contain links to other websites, applications, social media accounts, and information for your convenience that are not operated or controlled by Seen Tarbi for Financial Technology (X^2).

Seen Tarbi for Financial Technology (X^2) does not control these linked third-party websites or their privacy practices, which may differ from those set out in this Privacy Policy. Any Personal Information you choose to give to linked third-parties is not covered by this Privacy Policy. We encourage you to review the privacy policy of any company or website before submitting your Personal Information. Some third-parties may choose to share their users’ Personal Information with us; that sharing is governed by that company’s privacy policy, not this Privacy Policy.

Disclosure of Personal Information

We will not share or disclose your Personal Information (current or former User) to any nonaffiliated third-parties except:

  • To protect ourselves or others. We may share your Personal Information as required by law, such as when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the personal safety of other person/people, if we believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process; such as a court order, to protect your; our or others’ rights, property, or safety; enforce our policies or contracts; or collect amounts owed to us.
  • Disclosure in the event of merger, sale, or other asset transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, purchase or sale of assets, or transition of service to another provider, then your Personal Information may be transferred as part of such transaction(s), as permitted by law and/or contract.
  • Service providers. There are certain circumstances in which we may share your Personal Information with non-affiliated third-party service providers, including to perform certain business and technology related functions and to support the provision of the Services. We may share your personal Information with non-affiliated third-party service providers for the provision of the Services, which includes but is not limited to:
    • Customer support
    • Data processing and storage
    • Identification and verification of fraud detection
    • Mailing information
    • Marketing

 

Data Subject Rights

General. Seen Tarbi for Financial Technology (X^2) may provide you with several self-service features to assist in complying with its obligations under Personal Data Protection Law(s) with respect to responding to requests from data subjects at no additional cost.
You have the following rights:

              Personal Identifiable Information

Seen Tarbi for Financial Technology (X^2) may use your Personal Information for a variety of business purposes, such as to help you evaluate our Services, offer you new products or services, enhance our Services, and for research and internal analysis.

              Identity verification

Seen Tarbi for Financial Technology (X^2) may use third-party vendors to verify your identity as part of the regulatory requirement to verify our users’ identity. We may access your personal information with the National Information Center.

  • Access: the right to ask Seen Tarbi for Financial Technology (X^2) to provide you with copies of your personal information, verify its accuracy and update it as necessary in accordance with the applicable laws
    • Anonymization: the right to request anonymization of your personal information
    • Complaints: the right to file a complaint to the designated data authority if you believe that your data protection rights may have been breached
    • Withdraw consent: when personal information is processed on consent basis, You may withdraw consent at any time. In the event that you no longer want to receive any marketing material from Seen Tarbi for Financial Technology (X^2), you can unsubscribe through the unsubscribe option (included in all marketing communications to You) or contact us on the details below.

              Opting-out

You may decline to provide Personal Information to Seen Tarbi for Financial Technology (X^2). Declining to provide Personal Information may disqualify you from using Seen Tarbi for Financial Technology (X^2) Services, Site, and App features that require certain Personal Information.

Obtaining and withdrawing consent

Where you have consented to Seen Tarbi for Financial Technology (X^2)’s use of your Personal Information, you may withdraw that consent (revoke consent) at any time and opt-out by contacting us by email indicated under the “Contacting us” section blow.

Users cannot opt-out of providing Seen Tarbi for Financial Technology (X^2) Personal Information and continue to use the Services. Users must close their account(s) in order to opt-out of further providing us with Personal Information. Additionally, before we use Personal Information for any new purpose. Even if you opt-out, we may still collect and use non-personal information regarding your activities on our Services and for other legal and regulatory purposes as described above.

Electronic Communications

Seen Tarbi for Financial Technology (X^2) may use your Personal Information to communicate with you regarding our Services or to tell you about blog posts or Services that we believe will be of interest to you.

If you decide at any time that you no longer wish to receive marketing communications from us, please follow the “unsubscribe” instructions provided in the communications or contact us at compliance@xxxxx.xxx.

Please note that you cannot opt-out of administrative communications such as regulatory, billing or service notifications, or updates to our Terms or this Privacy Policy. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law(s).

Mobile devices

Seen Tarbi for Financial Technology (X^2) may send you push notifications through our mobile application(s). You may opt-out, at any time, from receiving these types of communications by changing the settings on your mobile device. Seen Tarbi for Financial Technology (X^2) may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

How long do we keep your data

Seen Tarbi for Financial Technology (X^2) only retains your Personal Information for as long as reasonably necessary to fulfill the purposes we collected it for, that includes retaining your data to satisfy any legal, regulatory, tax, accounting or reporting requirementsOn certain occasions, we may retain your Personal Information for a longer period, and even after you stop using our Services, in order to:

  • Respond to inquiries and complains
    • To comply with laws and regulations

Changes to this Privacy Statement

Seen Tarbi for Financial Technology (X^2) may update this Privacy Policy from time to time as deemed necessary at its sole discretion. If there are any material changes to this Privacy Policy, Seen Tarbi for Financial Technology (X^2) may notify you as required by applicable law.

Seen Tarbi for Financial Technology (X^2) encourages you to review this Privacy Policy periodically to be informed regarding how Seen Tarbi for Financial Technology (X^2) is using and protecting your information and to be aware of any policy changes. Your continued relationship with Seen Tarbi for Financial Technology (X^2) after the posting or notice of any amended Privacy Policy shall constitute your explicit agreement to be bound by any such changes.

Any changes to this Privacy Policy will take effect immediately after being posted or otherwise provided by us. Each version of this Privacy Policy will be identified on relevant pages by its effective date.

This document constitutes Seen Tarbi for Financial Technology (X^2)’s complete Privacy Policy for Seen Tarbi for Financial Technology (X^2) and its affiliates and the Services, Site and App.

Contact Information

If after reviewing this Privacy Policy, you would like to submit a request, opt-out or you have any questions or privacy concerns, please contact us by email at privacy@xsquare.sa or via physical mail at:


4024 Ghosn Al-Salam, Al-Roubs District 6377

P.O. Box 2313, Jeddah 6655
Kingdom of Saudi Arabia