UDBK e-Banking Privacy Clause

Last Updated: August 12, 2025

1. Introduction and Scope

Thank you for choosing UDBK e-Banking (hereinafter referred to as “we,” “us,” or “UDBK”). We understand the importance of your personal information and are committed to protecting it in accordance with applicable laws and regulations.

This Privacy Clause is designed to clearly and transparently explain how we collect, use, store, share, transfer, and protect your personal information when you access or use our website, mobile applications, and any other online or offline services (collectively, the “Services”), and to inform you of your privacy rights.

Please read and understand this entire clause before using our Services. By using our Services, you indicate that you fully understand and agree to the processing of your information as described herein.

2. How We Collect Information

We only collect and use your personal information for the purposes stated in this policy. We collect information through the following channels:

Information You Provide Directly: When you register for an account, conduct transactions, participate in promotions, or contact us.

Information Collected Automatically: Information collected through technical means during your use of our Services.

Information from Third-Party Sources: Information we obtain from credit bureaus, identity verification services, government agencies, and other third parties, where permitted by law.

The categories of information we collect include:

(a) Personal Identifiable Information: Such as name, government-issued identification number, passport number, contact details (phone, email), address, biometric data (e.g., facial features for identity verification), photograph, etc.

(b) Financial Information: Account numbers, account balances, transaction history, credit records, income status, investment preferences, tax information, etc.

(c) Technical and Log Information: IP address, device unique identifiers (e.g., IMEI/UDID), device model, operating system, browser type and version, clickstream data, page visit duration, crash reports, etc.

(d) Cookies and Similar Technologies: We use Cookies, pixel tags, and local storage to remember your preferences, analyze website traffic, evaluate advertising effectiveness, and provide more secure login verification (e.g., session cookies). You can refuse or manage Cookies through your browser settings, but this may affect the functionality of some core features of our Services.

(e) Location Information: Subject to your authorization, we may collect approximate or precise location information via your IP address or your mobile device’s GPS to assist in fraud detection and provide localized services.

3. How We Use Your Information

We use your information for the following business purposes:

(a) To Provide and Maintain Our Services

This includes using your information to process transactions, operate, maintain, and provide all features of our Services, including customer support.

(b) To Improve and Develop New Services

We use your information for data analysis, identifying usage trends, and evaluating and improving our Services, products, marketing, and your overall experience.

(c) To Communicate With You

We use your information to send you service-related messages (e.g., account verification, transaction alerts, changes/updates to our features), and to respond to your comments and questions.

(d) For Security and Fraud Prevention

We use your information to monitor and protect the security of our Services, authenticate users, investigate suspicious activity, and protect against fraudulent transactions.

(e) For Compliance and Legal Obligations

We use your information to comply with applicable laws, regulations, legal processes, and governmental requests (e.g., Anti-Money Laundering and Know Your Customer regulations).

(f) For Marketing and Advertising (With Your Consent)

Subject to your consent where required by law, we may use your information to develop and deliver marketing and advertising tailored to your interests.

(g) For Other Purposes With Your Consent

We may use your information for other purposes for which we have obtained your prior consent.

4. How We Share and Disclose Information

We will never sell your personal information. We only share your information with explicitly listed categories of third parties under the following circumstances:

Affiliates and Service Providers: Third parties who provide us with services such as infrastructure, technology, payment processing, data analytics, customer service, auditing, and marketing (e.g., [List types of vendors, e.g., “Amazon Web Services (AWS)”, “SAP”, “a specific credit bureau”]). These entities are only permitted to process your information to the extent necessary to provide services to us and are bound by contract to implement equivalent security measures.

Our Banking and Financial Partners: Necessary sharing with partner financial institutions when you apply for specific products (e.g., co-branded credit cards, loans).

Business Transfers: In the event of a merger, acquisition, or sale of our assets, your personal information may be transferred. We will ensure the transferee is bound by the terms of this policy.

Law & Public Safety: When required by law, litigation, or compulsory requests from public or governmental authorities.

Protecting Rights & Safety: When necessary to protect the rights, property, or safety of UDBK, our customers, or others.

Regarding Cross-Border Data Transfer: As our services are global, your information may be transferred to and processed in jurisdictions outside your country of residence. In such cases, we will ensure appropriate safeguards compliant with applicable laws are in place, such as signing EU Standard Contractual Clauses (SCCs), and require the recipient to provide adequate protection.

5. Data Security and Retention

We implement industry-standard administrative, technical, and physical security measures (e.g., SSL/TLS encryption, anonymization, access controls, security audits) to protect your information against unauthorized access, disclosure, alteration, or destruction.

Data Retention Periods: We retain your personal information only for as long as necessary to fulfill the purposes outlined in this policy and to comply with applicable legal or regulatory requirements (e.g., AML laws often require transaction records to be kept for at least 5 years). After the retention period expires, we will securely delete or anonymize your personal information.

6. Your Rights (Data Subject Rights)

Depending on your jurisdiction, you may have the following rights. You can exercise these rights by contacting us via the details in Section 9. We will respond to your request within the timeframe required by law (typically 30 days):

Right of Access & Data Portability: To access and receive a copy of the personal information we hold about you and to receive your data in a structured, commonly used format.

Right to Rectification: To request correction of inaccurate or incomplete personal information.

Right to Erasure (Right to Be Forgotten): To request deletion of your personal information under specific circumstances (e.g., where the information is no longer necessary for the purpose it was collected).

Right to Restriction of Processing: To request that we suspend the processing of your personal information in certain scenarios.

Right to Object: To object to the processing of your personal information based on our legitimate interests or for direct marketing purposes.

Right to Withdraw Consent: To withdraw your consent at any time where processing is based on consent. This does not affect the lawfulness of processing based on consent before its withdrawal.

Right to Lodge a Complaint: To file a complaint with your local data protection supervisory authority (e.g., the Office of the Privacy Commissioner in your region).

7. Automated Decision-Making & Profiling

We may use automated processes (e.g., algorithms) based on your transaction behavior and credit history to assess your creditworthiness or for fraud analysis. You have the right to request human intervention, express your views, and contest decisions based solely on automated processing. Please see our separate Automated Decision-Making Statement for detailed rules.

8. Children’s Privacy

Our Services are not directed at individuals under the age of 16 (or a higher age specified in your jurisdiction), and we do not knowingly collect their personal information. If you are a parent or guardian and believe we might have information regarding a child, please contact us immediately for deletion.

9. Updates and Notification

We may update this Privacy Clause from time to time to reflect changes in laws, technology, or our business practices. When we update it, we will notify you of the changes through a prominent notice on our website, email, or SMS, and will indicate the new effective date. Your continued use of our Services after the updated policy takes effect constitutes your acceptance of the revised terms.

10. Contact Us

If you have any questions, comments, or suggestions regarding this Privacy Clause, or wish to exercise your rights, please contact us via:

Email: support@udbki.com

Phone: 2129608058