Inizio Global is committed to responsible data stewardship. We process personal data in accordance with applicable UAE data protection law, including Federal Decree-Law No. 45 of 2021 on Personal Data Protection.
Data is collected for specific, explicit purposes and not processed beyond those purposes.
We collect only data that is adequate, relevant, and limited to what is necessary.
We take reasonable steps to ensure data is accurate and kept up to date.
Appropriate technical and organisational measures protect data at all times.
Data is retained only for as long as necessary and then securely deleted.
We maintain records of processing activities and are responsible for demonstrating compliance.
Inizio Global DMCC is the data controller for personal data processed through the Platform. We determine the purposes and means of processing and are responsible for compliance with applicable data protection law.
Where partner agencies use the Platform to manage their agents, they may act as independent data controllers in respect of their agents' personal data. Each party is responsible for its own compliance obligations.
We rely on the following lawful bases for processing personal data:
Where we rely on consent, you have the right to withdraw consent at any time without affecting the lawfulness of prior processing.
The Platform involves submission of customer personal data by agents as part of financial product referrals. The following standards apply:
Agents must obtain explicit informed consent from customers before submitting their data to the Platform. Consent records must be retained and may be audited by Inizio Global or the relevant bank.
Agents are responsible for the accuracy of data submitted. Inizio Global will pass referral data to banks and FIs as submitted. Correction of inaccurate referral data must be requested promptly.
Customers whose data has been submitted may exercise rights directly with Inizio Global by contacting privacy@inizioglobal.com. We will liaise with the relevant agent and bank to fulfil such requests.
Inizio Global operates primarily within the UAE. Where data is processed or stored outside the UAE, we ensure appropriate safeguards are in place including:
We engage trusted sub-processors to support Platform operations. All sub-processors are bound by data processing agreements and may only process data as instructed by Inizio Global.
A current list of sub-processors is available on request. We will provide 30 days' notice of any material changes to our sub-processor arrangements.
In the event of a personal data breach, Inizio Global will:
To report a suspected data breach, contact security@inizioglobal.com immediately.
We conduct Data Protection Impact Assessments (DPIAs) for new or changed processing activities that are likely to result in high risk to individuals, including large-scale processing of sensitive financial data. DPIAs are reviewed annually and updated as needed.
Inizio Global's data practices are designed to comply with:
We conduct annual compliance reviews and maintain a register of processing activities as required by applicable law.
For data policy enquiries, to exercise your rights, or to report a concern:
Data Protection Officer
Inizio Global DMCC
DIFC, Dubai, United Arab Emirates
Email: privacy@inizioglobal.com
Security incidents: security@inizioglobal.com