2. INFORMATION WE COLLECT

2.1 Information Collected from Customers

• Full name (as per Passport/Emirates ID)
• Mobile number, email address, and UAE residential address
• Emirates ID (Front & Back), Passport copy, and Residency Visa
• Income details, Salary Certificates, and Labor Contract (MOL)
• Trade License and MOA (for Business Finance/Self-Employed)
• Bank statements and IBAN details
• Credit profile and AECB (Al Etihad Credit Bureau) reports

2.2 Information Collected from BDPs / Sub-BDPs

• Name, contact details, and professional credentials
• Emirates ID and bank account details for commission payouts
• VAT Registration details (if applicable)
• CRM login credentials and activity logs
• Referral hierarchy, performance, and incentive data

2.3 Automatically Collected Information

• IP address and device/browser type
• UAE PASS authentication logs (where used)
• CRM usage timestamps and activity records
• Cookies and tracking data for platform optimization

3. PURPOSE OF DATA COLLECTION

We conduct CDD (Customer Due Diligence) and process information for the following purposes:

• To process finance referrals and applications to UAE banks.
• To verify identity and perform mandatory CDD
• To coordinate with Financial Institutions for credit assessment.
• To manage lead tracking and CRM operations.
• To calculate and process commission payouts via IBAN.
• To comply with CBUAE, Anti-Money Laundering (AML), and CFT
• To prevent financial fraud, identity theft, and mis-selling.

4. CONSENT & AUTHORIZATION

By submitting your details on EFB platforms, you expressly authorize:

• EFB and its employees to contact you via call, SMS, WhatsApp, and email.
• The sharing of your information with Banks, Finance Houses, AECB, and authorized service providers.
• The processing of your data even if your number is registered under the DNCR (Do Not Call Registry) in the UAE.
• Consent remains valid unless explicitly withdrawn in writing to our Compliance Officer.
  

  5. SHARING OF INFORMATION

   

  We share your information only with:

  • Banks and Finance Houses for application processing.
  • AECB for credit eligibility checks.
  • Technology and CRM providers hosted on secure, local servers.
  • UAE Regulatory Authorities (CBUAE, Dubai Police, or Courts) when legally required.
  • ❌ We do not sell personal data to third parties for marketing purposes.

6. DATA STORAGE & RETENTION

• Data is stored on secure, encrypted servers with strict access controls.
• Personal data is retained only as long as required for:
  • Fulfilling the finance application process.
  • CBUAE regulatory audits and compliance.
  • Legal dispute resolution.
• Data retention periods follow UAE AML (Anti-Money Laundering) laws, typically requiring records to be kept for at least 5 years post-transaction.

7. DATA SECURITY MEASURES

We implement industry-standard safeguards including:

• Role-Based Access Control (RBAC): Only authorized personnel can view sensitive files.
• End-to-End Encryption: For all document uploads and data transfers.
• Multi-Factor Authentication (MFA): Including UAE PASS integration for secure logins.
• Internal Risk Control (IRC): Periodic audits to ensure data integrity.

Key UAE Localization Summary:

• CDD: UAE AML standards.
• AECB: Al Etihad Credit Bureau.
• DNCR: Do Not Call Registry.
• Federal Law No. 45: Integrated the specific UAE data protection legal framework.
• L.C: Updated the entity type to the standard UAE business structure.
• Emirates ID/Visa: Updated the required documentation list to reflect UAE residency.
• Audit logs and monitoring: Real-time tracking of all data access within the CRM.
• Restricted internal access: Data visibility is limited strictly to the assigned Account Manager and Compliance Team.
• Periodic security reviews: Regular vulnerability assessments to ensure alignment with UAE cybersecurity standards.
• Disclaimer: Despite our rigorous safeguards, no digital system is 100% secure. Users provide data acknowledging the inherent risks of digital transmission.
  

  8. CONFIDENTIALITY OBLIGATIONS (BDPs)

   

  BDPs and Sub-BDPs must:

  • Use customer data strictly for Excellence Financing Broker (EFB) business purposes.
  • Maintain strict confidentiality of all Personal Identifiable Information (PII).
  • Not store, reuse, sell, or share customer data with third parties or other brokers.
  • Not collect OTPs, PINs, or passwords under any circumstances.
  • Violation: Non-compliance results in immediate termination, forfeiture of all payouts, and potential reporting to the Dubai Police Cybercrime Department.

  9. COOKIES & TRACKING

   

  We use cookies and similar technologies to:

  • Improve website functionality and user interface.
  • Analyze usage patterns to optimize the CRM experience.
  • Enhance security and prevent unauthorized access.
  • Note: You may disable cookies in your browser; however, this may limit your access to certain secure sections of the EFB portal.

  10. USER RIGHTS (DATA SUBJECT RIGHTS)

   

  In accordance with UAE Federal Law, you have the right to:

  • Access your personal data held by us.
  • Request correction or updates to inaccurate information.
  • Withdraw consent for promotional and marketing communications via the DNCR (Do Not Call Registry)
  • Request deletion (The “Right to be Forgotten”), subject to CBUAE regulatory data retention requirements.
  • Requests: All data-related requests can be raised via support@efb.ae.
    

     

    11. CHILDREN’S PRIVACY

     

    Excellence Financing Broker does not knowingly collect or process data from individuals below 18 years of age. If such data is identified, it will be purged immediately from our servers.

    12. THIRD-PARTY LINKS

     

    Our platforms may contain links to bank portals or third-party websites. EFB is not responsible for the privacy practices, terms of use, or content of these external sites.

    13. CHANGES TO THIS POLICY

     

    EFB reserves the right to modify this Privacy Policy to reflect changes in UAE Federal Law or Central Bank regulations. The latest version will be updated on the EFB website and CRM. Continued use of the platform constitutes your acceptance of the revised terms.

    14. GRIEVANCE & COMPLIANCE OFFICE

     

    For privacy concerns, data issues, or regulatory grievances: Data Protection & Compliance Officer Excellence Financing Broker

    📧 support@efb.ae

     📍 Bur Dubai, Dubai, United Arab Emirates

     📞 +971 559857863

    We aim to acknowledge and resolve privacy-related complaints within 15 to 30 working days.

    15. GOVERNING LAW & JURISDICTION

     

    This Privacy Policy is governed by the Federal Laws of the United Arab Emirates and the local laws of the Emirate of Dubai. The Courts of Dubai shall have exclusive jurisdiction over any disputes arising from this policy.

    Key UAE Localization Summary:

     

    • CDD / CDD Documents: Integrated throughout
    • CBUAE.
    • Federal Decree-Law No. 45: Referenced for Data Protection.
    • Dubai / Bur Dubai.
    • DNCR
    • L.C