Terms and Privacy Policy

Terms & Privacy Policy

سياسة الاستخدام والخصوصية

Data & Privacy Policy

1. Introduction

Xeer is a digital financial twin app to help individuals organize their personal finances and build financial security all within Sharia Compliance standards. We don’t track, collect, or have access to your financial or sensitive information such as credit card or bank account details. Xeer provides guidance and advice based on the user inputs about their expenses, debt, savings and wealth.

We describe Xeer’s “Financial Digital Twin” vision as creating a place to replicate the real world transactional records without actually having direct linking connection with the sensitive data sources itself. This way the data represents the actual state of your financial estate without Xeer having the ability to edit on any of the estate components.

2. Services

a. Financial Personality Assessment (FPA)

A carefully designed tool that simplifies the understanding of individual financial behaviour, preferences, and attitudes. It uses a series of questions to explore various financial aspects, providing a comprehensive view of a person's financial persona. The FPA is based on the understanding that personal traits and tendencies significantly influence financial decisions. It helps individuals understand their approach to money management, investment decisions, savings, and expenditure.

b. Jarida (Blog)

An open and free of charge resource of financial information knowledge, from our Website and Mobile App, to guide you to a healthier financial lifestyle with Sharia Compliance built in. Our Blog Posts and Chronicles prepared by our experts that tackles financial tools, products, tips, and frameworks that arms you to deal with financial situations of today’s financial challenges. Get personalized content specifically for you when you use Xeer app when backed by your FPA results, bookmark content to read later and keep it easily accessible, and more.

c. Financial Tools

A single request financial tools that each are focused towards solving one critical issue for you. Exchange Converter including Gold and Silver, Zakat Calculator, and more to come.

d. Almas Subscription

A full-fledged Budgeting and Expenses Tracking service that is designed to support you alongside your journey of Financial Security and Sustainability. Almas also is designed to further expand on the simple financial tools to make it actionable within you budget and decision making process.

3. User Conduct

Acceptable Uses

Using the app to securely manage your personal financial accounts, transactions, and data

Accessing financial planning tools, budgeting features, and spending analysis

Connecting third-party financial accounts and services to the digital twin platform

Utilizing the app's predictive analytics and scenario planning capabilities

Sharing your digital twin with authorized parties like financial advisors and/or family members.

Prohibited Uses

Using the app for any illegal activities such as fraud, money laundering, or financing of terrorism

Attempting to access or manipulate the digital twins or financial data of other users without permission

Reselling or redistributing the app's content, features, or functionality

Violating applicable laws, regulations, or third-party rights through use of the app

Interfering with or disrupting the app's servers, networks, or other infrastructure

User Conduct Rules

Providing accurate and up-to-date information when setting up your profile

Refraining from abusive, harassing, or discriminatory behaviour towards other users

Respecting the privacy and data rights of others when interacting with others is applicable

Promptly reporting any suspected security breaches or unauthorized access to your digital twin

4. Termination and Suspension

Freezing (Suspension) Period

Based on user choice, we provide a freezing account request feature for 2 weeks, 1 month, or 3 months. During this period your account data won’t be accessible or be used by any means including the in-app notification and marketing activities. After the freezing period is over, we have the right to notify the user however, If the user decides to freeze and does not log in after the selected period his data will be deleted within 1 year except for some essential information for research purposes.

The Account and Data Deletion

The user has the right to request his data and account deletion from Xeer. The process goes through 3 phases:

Phase 1: The user initiates the deletion request.

Phase 2: The account goes into a freezing period of 48 hours as a grace period before complete deletion to break the deletion process by signing in.

Phase 3: After 48 hours, the user receives an email notification confirming the data deletion entirely from Xeer's end except for some essential info for research purposes. Once the confirmation is sent, we can’t retrieve any data other than basic account details.

Forced Termination and Suspension: Xeer holds the right to terminate or suspend any user account in case of noticing any prohibited, illegal, or against-user conduct activity.

5. Pricing and Payment Terms

We provide a 2-level service:

The 1st level (Free) is totally free of charge to use with no subscription required. Basic access to a number of our Tools alongside having robust access to our Blog (Jarida) and our Financial Personality Assessment.

The 2nd level (Almas) is a subscription service that guides you on your day-to-day financial decision-making journey with deeper knowledge about your actual financial situation through spending tracking, setting a budget, net worth, asset management, zakat donations, and more.

A free trial period is available to test out (Almas) for 35 days for all Xeer App users. This testing period gets refreshed only after a full (1) year from the end of the trial period for the user to make another 35-day trial period. This way all free users get to try out Xeer’s Almas at least for a month each year.

6. Data Collection, Usage and Sharing

Xeer does not share, sell, and/or track the user data on behalf of or for the usage purpose of any 3rd party entity including all our partners. We also explicitly don’t track the user’s behaviour on other websites or apps.

We track behavioral activities over the app with flock-based preferences tagging to enhance the experience anonymously without being able to know any personal and/or financial information that you input in the app.

Our Privacy Stance

Provide the best experience possible without any privacy concession.
- When possible we will use indirect information e.g “Financial Personality Assessment” results rather than tracking your behavior over Xeer
- Behavioral frequency data will always be anonymous to Xeer, 3rd parties, and partners

When possible Xeer will show reasoning behind why you’re experiencing something differently in plain terms.

Data Sharing and Retention

We do not share your personal data with third parties for their own marketing purposes without your explicit consent. We retain your data only as long as necessary for the purposes outlined in this policy or as required by law.

Personal Information and Sensitive Data

Since we only use Apple/Google quick login, we collect only the user data that Apple/Google permits us to collect, and we also ask for more information such as the user's phone number, gender, and birthday then later if the user subscribes to Almas we use end to end encryption between the app and our servers to facilitate the extra feature

For a personalized experience, we scan SMS messages on device to automate transaction records of the users. However, the back-end at Xeer doesn’t copy the user-scanned data, it’s only reflected on our server transactions to be listed in the user account for his budgeting and expense tracking.

Device Data Access

Xeer requests a few access to enable the best feature functionality, we access notifications, storage for exporting reports, location while using the app, messages for sending SMS and scanning the expense messages all of which does not leave your device and does not get linked with the account or our servers.

Third-party Tracking and Online Advertising

We collaborate and partner with trusted and official entities for marketing purposes and use analytics and advertising services to enhance user experience and provide targeted relevant content. The following outlines how we handle your data in this context:

Use of Cookies and Tracking Technologies

We, along with our third-party partners, use pixels and other similar technologies to collect information about your use of the app. These technologies help us understand how you interact with our app, deliver personalized content, and improve our services.

3rd Party Advertising Partners

We partner with credible third-party entities to display user interest-based advertising and utilize third-party advertising services to deliver targeted ads tailored to your activities and interests in the app. This involves the collection of anonymous information over time which may include insights, common behaviours, and interaction with ads but NEVER your personal data.

Google Analytics and Advertising

We use Google Analytics, a web analytics service provided by Google, to analyze how users use our app. Google Analytics uses cookies and other tracking technologies to collect data on user behavior and device information. This data helps us understand usage patterns and improve our app.

We also use Google advertising services to display targeted advertisements. Google may use cookies and other identifiers to collect information about your usage of our app and other websites to provide personalized ads.

Information Collected by Google:

Device information (e.g., IP address, browser type, operating system)

Usage information (e.g., pages viewed, time spent on pages, clicks)

Location data (if location services are enabled)

Ad interaction information

For more information on how Google uses your data, please refer to Google Privacy Policy

Managing Your Preferences

You can manage your advertising preferences through the following methods:

Google Settings: Manage your ad settings and opt-out of personalized ads by visiting Google Ad Settings.

Apple Settings: If you are using an Apple device, you can opt out of interest-based ads by enabling the “Limit Ad Tracking” setting on your iPhone, iPad, or iPod Touch, or the “Opt out of Ads Personalization” setting on your Mac. For more information, visit Apple Advertising and Privacy.

7. Changes to This Policy

We may update this privacy policy section to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any significant changes and obtain your consent where required.

Issue date 20 July 2024

_________________________________________________________________________________

3. List any third parties the app relies on, like analytics tools, also comply with privacy requirements.

We collaborate and partner with trusted and official entities.

For marketing purposes, we use analytics apps to provide a better user experience and relevant content.

Who does the app share my data with and for what purposes?

>>> We may share a mobile number with the SMS provider to be able to finish the verification step (OTP).

>>> For marketing purposes, we will not share your data explicitly but we may share anonymous and overall conclusions of the data with credible partners to help you see relevant content. This data might be age range and common behavioural patterns.

How long does the app store my data and when will it be deleted?

>>> based on user choice. We provide a freezing account feature for 2 weeks, 1 month, and 3 months. If the user decides to freeze and does not log in after a specific period his data will be deleted within…. except for….. for research purposes.

How can users request deletion of their data and what happens to their data upon account closure?

>>> The user can do it from the app, export his data then close/delete the account and the data.

>>> Google Analytics and Firebase.

How does the app use the collected data internally?

For marketing purposes, we may send you notifications based on your actions, also other marketing activities are conducted to communicate with the user after his/her consent through email marketing, SMS, and all kinds of push notifications. The user can unsubscribe anytime.

With what third parties (e.g. service providers, partners, advertisers) is the data shared and for what purposes?

>>> SMS provider to send OTP, firebase to send customized in-app notifications.

We use Meta ads, Google, and Apple Store ads, and other social media ads.

Does the app sell or rent user data to third parties?

>>> No.

Access and Control

How does the app collect this data (e.g. directly from users, from linked accounts, from third parties)?

>>> From Apple/Google and directly from users.

How often do the apps access my financial account information?

>>> @Ahmed El Zoughby, please answer this one.

Can I prevent an app from accessing certain types of financial information?

>>> @Ahmed El Zoughby, please answer this one.

How do I stop a financial app from accessing my financial information?

>>> User can freeze/inactive the account.

Can I control which accounts and data types can be accessed by third-party apps?

>>> Yes following Apple/Google best practices on this.

What choices and controls do users have over their data (e.g. access, correction, deletion, export)?

>>> Full access (access, creation, correction, deletion, export)

For what marketing purposes is the data collected (e.g. targeted ads, email campaigns, analytics)?

>>> @Aya Eltarabishy @Ahmed El Zoughby

How can users opt-out of data collection or sharing for certain purposes like marketing?

>>> User can freeze/inactive the account and the marketing activities follow.

What rights do users have under data privacy laws like GDPR and CCPA?

>>> We may be following the GDPR.

Security and Breaches

How does the app keep my data secure?

>>> Since we are using one of the most popular Cloud providers, we are following the best practices they are providing to achieve the most secure approach to handling the data at rest and in transit.

What happens if the app has a security breach and my data is compromised?

>>> @Ahmed El Zoughby

What measures does the app take to secure user data and prevent unauthorized access, data breaches, or misuse?

>>> Since we are using one of the most popular Cloud providers, we are following the best practices they are providing to achieve the most secure approach to handling the data at rest and in transit.

How does the app protect sensitive financial information like payment details and account numbers?

>>> We don't save information like payment details in our app, such details are saved on Apple Pay or Google Pay.

If a data breach occurs, how will users be notified and what remediation steps will be taken?

>>> @Ahmed El Zoughby

Transparency and Trust

How transparent is the app about its data practices?

>>> Full transparent, @Aya Eltarabishy this should be a political answer.

Can I trust the app to protect my sensitive financial information?

>>> Yes. We follow the best practices of Google and

How will the app notify users of changes to the privacy policy or data practices?

>>> Campaigns, and in-app notifications.

Who can users contact with questions or concerns about the app's data practices?

>>> the customer support “email later on”

User Education

What should I do to keep my account safe and secure when using the app?

>>> We may add a blog page on this. @Aya Eltarabishy

How does the app work and what am I agreeing to in the terms and conditions?

>>> @Ahmed El Zoughby @Aya Eltarabishy

Limitation of Liability

Disclaimer of Certain Damages: In no event shall Xeer or any of its employees be liable for any indirect, incidental, special, consequential or punitive damages, or any loss of profits, revenue, data, goodwill or other intangible losses, arising out of or related to your use of or inability to use the App, whether based on warranty, contract, tort (including negligence), statute or any other legal theory, and whether or not [Company Name] has been informed of the possibility of such damage.

Caps on Liability: The total liability of [Company Name] for any claims arising from your use of the App shall not exceed the greater of: (a) the amount of fees paid by you to [Company Name] in the 12 months prior to the claim; or (b) $100. Multiple claims shall not enlarge this limit.

Exclusions: [Company Name] shall have no liability for any losses or damages arising from:a. Your own negligence, misuse or unauthorized access of the App;b. Inaccuracies or errors in the financial data or inputs you provide;c. Third-party services, systems, data or content that integrate with the App;d. Circumstances beyond [Company Name]'s reasonable control, such as internet outages, system failures or cyberattacks.

Disclaimers: The App is provided "as-is" without warranties of any kind, either express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, and non-infringement. [Company Name] makes no guarantee as to the accuracy, completeness or timeliness of the information and insights provided by the digital twin.

Not Financial Advice: The App is not a substitute for professional financial advice. [Company Name] does not provide any financial, investment, tax or legal advice. All financial decisions remain of your own responsibility.

Agree on the privacy policy and Terms & conditions, privacy policy

By downloading the application, registering your data, and using the services provided by Xeer application (“Services”), you agree to the terms and conditions, the privacy policy, any policies set by the company for Xeer application or what serves the application, and any modifications that have been made to it from time to time and in accordance with the items of these terms and conditions.

You should not register twice by the same email to phone num

Dispute Resolution

Governing Law: These Terms and Conditions and your use of the Xeer digital financial twin app shall be governed by and construed in accordance with the laws of the Hashemite Kingdom of Jordan.

Arbitration: Any dispute, controversy or claim arising out of or relating to these Terms and Conditions, or the breach, termination or invalidity thereof, shall be settled by arbitration in accordance with the Jordanian Arbitration Law.

Arbitration Procedures: The arbitration shall be conducted by a single arbitrator appointed by mutual agreement of the parties. If the parties fail to agree on the arbitrator within 30 days of a party's written request for arbitration, the arbitrator shall be appointed by the Amman Chamber of Commerce and Industry. The seat of the arbitration shall be Amman, Jordan.

Language: The language of the arbitration shall be Arabic. The arbitral award shall be final, binding on the parties and enforceable in any court of competent jurisdiction.

Exceptions: Notwithstanding the above, Xeer reserves the right to seek injunctive or other equitable relief in a court of competent jurisdiction in Jordan in order to protect its intellectual property rights, confidential information or other legal rights.

Miscellaneous Provisions

Severability: If any provision of these Terms and Conditions is held to be unenforceable or invalid, that provision will be limited or eliminated to the minimum extent necessary so that these Terms and Conditions will otherwise remain in full force and effect and enforceable.

Waiver: The failure of Xeer to exercise or enforce any right or provision of these Terms and Conditions shall not constitute a waiver of such right or provision. Any waiver of any provision of these Terms and Conditions will be effective only if in writing and signed by [Company Name].

Assignment: You may not assign or transfer these Terms and Conditions, by operation of law or otherwise, without Xeer's prior written consent. Xeer may assign these Terms and Conditions, in whole or in part, at any time to any entity. Any attempted assignment or transfer in violation of this section will be null and void.

Modifications: Xeer reserves the right, at its sole discretion, to modify or replace these Terms and Conditions at any time. If a revision is material, we will provide at least 30 days' notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion.

Entire Agreement: These Terms and Conditions constitute the entire agreement between you and Xeer regarding your use of the App, and supersede all prior and contemporaneous agreements, representations, warranties and understandings.

Notices: All notices under these Terms and Conditions will be in writing and will be deemed to have been duly given when received, if personally delivered or sent by certified or registered mail, return receipt requested; when receipt is electronically confirmed, if transmitted by email; or one day after it is sent, if sent by an internationally recognized overnight delivery service.

The key points on how mobile apps create a privacy policy:

Determine Applicable Laws

Identify which data privacy laws apply to your app based on the type of personal information collected and the locations of your users.

Identify Collected Data

Clearly outline what personal information your app collects, such as names, contact details, location data, IP addresses, etc.

Explain Collection and Use

Describe how and why you collect and use the personal data, including any third parties it may be shared with.

Provide Easy Access

Make your privacy policy easily accessible within your app, such as in the settings or legal menu.

Also, provide the policy link on your app's store listing on the App Store and Google Play.

Comply with App Store Policies

Apple requires a privacy policy link in your App Store listing and within the app itself for all iOS apps.

Google requires a privacy policy for almost all Android apps, with a link in the Play Console and within the app.

Keep it Updated

Maintain an accurate and up-to-date privacy policy that reflects your current data practices.

Provide notice to users when you make material changes to your privacy policy.

Consider User Trust

Having a clear and transparent privacy policy helps build trust with your app users.

It also allows you to comply with data privacy laws and app store requirements

The most frequently asked questions from users about fintech app privacy policies:

Access and Control

How does the app collect this data (e.g. directly from users, from linked accounts, from third parties)?

>>> From Apple/Google and directly from users.

How often do the apps access my financial account information?

>>> @Ahmed El Zoughby, please answer this one.

Can I prevent an app from accessing certain types of financial information?

>>> @Ahmed El Zoughby, please answer this one.

How do I stop a financial app from accessing my financial information?

>>> User can freeze/inactive the account.

Can I control which accounts and data types can be accessed by third-party apps?

>>> Yes following Apple/Google best practices on this.

What choices and controls do users have over their data (e.g. access, correction, deletion, export)?

>>> Full access (access, creation, correction, deletion, export)

For what marketing purposes is the data collected (e.g. targeted ads, email campaigns, analytics)?

>>> @Aya Eltarabishy @Ahmed El Zoughby

How can users opt-out of data collection or sharing for certain purposes like marketing?

>>> User can freeze/inactive the account and the marketing activities follow.

What rights do users have under data privacy laws like GDPR and CCPA?

>>> We may be following the GDPR.

Data Collection and Use

What information does the app collect and how is it used?

>>> @Ahmed El Zoughby

Who does the app share my data with and for what purposes?

>>> We may share a mobile number with the SMS provider to be able to finish the verification step (OTP).

How long does the app store my data and when will it be deleted?

How can users request deletion of their data and what happens to their data upon account closure?

>>> The user can do it from the app, export his data then close/delete the account and the data.

Security and Breaches

How does the app keep my data secure?

>>> Since we are using one of the most popular Cloud providers, we are following the best practices they are providing to achieve the most secure approach to handling the data at rest and in transit.

What happens if the app has a security breach and my data is compromised?

>>> @Ahmed El Zoughby

What measures does the app take to secure user data and prevent unauthorized access, data breaches, or misuse?

>>> Since we are using one of the most popular Cloud providers, we are following the best practices they are providing to achieve the most secure approach to handling the data at rest and in transit.

How does the app protect sensitive financial information like payment details and account numbers?

>>> We don't save information like payment details in our app, such details are saved on Apple Pay or Google Pay.

If a data breach occurs, how will users be notified and what remediation steps will be taken?

>>> @Ahmed El Zoughby

Transparency and Trust

How transparent is the app about its data practices?

>>> Full transparent, @Aya Eltarabishy this should be a political answer.

Can I trust the app to protect my sensitive financial information?

>>> Yes. We follow the best practices of Google and

How will the app notify users of changes to the privacy policy or data practices?

>>> Campaigns, and in-app notifications.

Who can users contact with questions or concerns about the app's data practices?

>>> the customer support “email later on”

User Education

What should I do to keep my account safe and secure when using the app?

>>> We may add a blog page on this. @Aya Eltarabishy

How does the app work and what am I agreeing to in the terms and conditions?

>>> @Ahmed El Zoughby @Aya Eltarabishy

References

Factorial: https://factorialhr.com/security

Thndr: https://thndr.app/privacy/

Engaging privacy page- Revolut: https://www.revolut.com/privacy-policy/

Buddy: https://buddy.download/privacypolicy/

Terms & Condition

The key areas typically covered in terms and conditions include:

Miscellaneous Provisions

Include standard legal clauses like severability, waiver, and assignment.

Specify how the terms and conditions can be modified or updated.