Last updated: [04/12/2025]
Important: This Privacy Policy is a draft designed for TipTip FZ-LLC operating in the UAE. It must be reviewed and adapted by qualified privacy/legal counsel before use.
1. Introduction
1.1 This Privacy Policy (“Policy”) explains how TipTip FZ-LLC (“TipTip”, “we”, “us”, or “our”) collects, uses, shares, and protects personal data when you use the TipTip mobile application, website, and related services (collectively, the “Service”).
1.2 By using TipTip, you acknowledge that we process your personal data as described in this Policy and in accordance with applicable data protection and privacy laws in the United Arab Emirates, as well as any other laws that may apply based on your location and our activities.
1.3 This Policy applies to Tippers / Senders, Recipients / Creators / Merchants / Teams, visitors to our website, and any other individual whose personal data we process in connection with TipTip.
1.4 This Policy forms part of our Terms & Conditions. Capitalised terms used but not defined here have the meaning given to them in the Terms.
2. Data Controller & Contact
2.1 The controller responsible for your personal data is: TipTip FZ-LLC, free zone limited liability company, commercial licence number 107274, with registered office at Premises No. DMC-BLD05-VD-G00-199, Ground Floor, Building DMC5, Dubai Media City, Dubai, United Arab Emirates.
2.2 You can contact us regarding privacy matters at [hello@tiptip.app] or through in-app support.
2.3 If required by law, we may appoint a Data Protection Officer (DPO). Where appointed, DPO contact details will be published in the app or on our website.
3. Personal Data We Collect
We may collect and process the following categories of personal data:
Identification and contact data: name, email address, mobile number, country of residence, and date of birth (where required).
Account and profile data: username, profile display name, profile photo or avatar, biography, role or position, business/venue details, and team or organisation memberships.
KYC and verification data: government-issued IDs, business documents, proof of address, selfie or liveness data (where required and permitted by law), and screening and verification results.
Financial and transaction data: limited payment card information (e.g. token or last four digits), Wallet Balances and payout history, transaction details, linked Bank Details (such as IBAN and account-holder name), and chargeback or refund information.
Technical and usage data: device information, IP address and approximate location, log data and usage events, in-app interactions, performance, and crash data.
Communication data: content of messages or requests you send to our support team, feedback, survey responses, ratings, and marketing preferences.
Data from third parties: data from PSPs, banks, KYC/AML providers, fraud-prevention services, public sources, and third-party services you choose to link (subject to their privacy policies).
4. How We Use Your Personal Data
4.1 To provide and operate TipTip: creating and managing your Account, enabling Tips and Payouts, and providing customer support. Legal bases: contract performance and our legitimate interests to operate an efficient and secure Service.
4.2 To fulfil legal and regulatory obligations: conducting KYC, AML/CTF, and sanctions screening; monitoring transactions for suspicious activity; keeping records; and responding to lawful requests from authorities and PSPs. Legal bases: legal obligations, public interest, and legitimate interests.
4.3 To prevent fraud and ensure security: detecting and investigating fraud, abuse, or suspicious activity; enforcing our Terms and policies; and protecting the integrity and security of our systems and users. Legal bases: legitimate interests and legal obligations.
4.4 To communicate with you: sending service-related notifications such as security alerts and transactional confirmations, and responding to queries and support requests. Legal bases: contract performance, legitimate interests, and legal obligations.
4.5 To improve and develop TipTip: analysing usage and performance, testing and deploying new features, and generating aggregated or anonymised statistics for internal reporting and product decisions. Legal bases: our legitimate interests to develop and improve the Service.
4.6 For marketing and promotions (where permitted): sending news, promotions, and offers, running referral programmes and incentives, and measuring campaign effectiveness.
Legal bases: your consent where required or our legitimate interests where permitted by law. You can opt out at any time.
5. How We Share Your Personal Data
We may share your personal data with payment service providers and banks that process Tip payments and Payouts; KYC/AML and fraud-prevention providers; cloud hosting, analytics, communications, customer-support, and other service providers that act as processors; business partners where we offer integrated or jointly branded services; authorities and regulators where required by law or for the protection of our rights or users; and potential or actual purchasers, investors, and advisers in connection with corporate transactions.
We do not sell your personal data in exchange for money. If local laws define “sale” or “sharing” more broadly, we will comply with any additional requirements, including providing opt-out options where applicable.
6. International Data Transfers
6.1 Your personal data may be stored and processed in the United Arab Emirates and in other countries where we, our group companies, or our service providers operate, which may have different data-protection laws from those in your country.
6.2 Where we transfer personal data outside the UAE or your country, we will take appropriate measures as required by applicable law, which may include contractual safeguards, ensuring recipients are located in jurisdictions deemed adequate by regulators, and implementing technical and organisational protections.
7. Data Retention
7.1 We keep personal data only for as long as necessary for the purposes described in this Policy, including to provide and maintain the Service, comply with legal and regulatory obligations, and resolve disputes and enforce our rights.
7.2 Retention periods vary depending on the type of data and applicable law. For example, KYC and transaction data may be retained for at least [5–10] years from the date of the transaction or account closure, and basic account data may be retained for a period necessary to defend legal claims or respond to regulatory queries.
7.3 When personal data is no longer required, we will delete it or anonymise it so it can no longer be linked to you.
8. Security
8.1 We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, or disclosure, including encryption in transit, access controls and authentication, secure development and logging, and regular monitoring for vulnerabilities and security incidents.
8.2 No system is entirely secure. If we become aware of a personal-data breach likely to result in a high risk to your rights and freedoms, we will notify you and relevant authorities as required by law.
9. Your Rights
Depending on your jurisdiction, you may have rights to access, rectify, erase, restrict, or object to the processing of your personal data; to data portability; and to withdraw consent where processing is based on consent. To exercise these rights, contact us at [hello@tiptip.app] or via in-app support. We may need to verify your identity and may decline or limit requests in accordance with applicable law.
You also have the right to lodge a complaint with your local data-protection authority, where available.
10. Cookies & Similar Technologies
10.1 Our website and app may use cookies, SDKs, and similar technologies to enable core functionality and security, remember your preferences, generate analytics and usage statistics, and support marketing and promotions where permitted.
10.2 Where required by law, we will obtain your consent for non-essential cookies and provide options to manage your preferences via a cookie banner or settings. Further details may be provided in a separate Cookie Policy or in-app notice.
11. Children’s Data
11.1 TipTip is not intended for children under 18 years of age (or the minimum age required by applicable law). We do not knowingly collect personal data from such individuals.
11.2 If you believe that a child under the relevant age has provided personal data to us, please contact us so that we can take appropriate steps to delete it or obtain necessary parental consent, as required by law.
12. Changes to This Privacy Policy
12.1 We may update this Policy from time to time to reflect changes in our processing activities, legal obligations, or Service features.
12.2 When we make changes, we will update the “Last updated” date and, where appropriate, notify you through the app, email, or other reasonable means.
12.3 Your continued use of TipTip after the updated Policy becomes effective means you acknowledge the changes. If you do not agree, you should stop using TipTip and may request closure of your Account.
13. Contact
If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal data, you can contact us at:
Company: TipTip FZ-LLC
Licence number: 107274
Registered office: Premises No. DMC-BLD05-VD-G00-199, Ground Floor, Building DMC5, Dubai Media City, Dubai, United Arab Emirates
Email (privacy): [hello@tiptip.app]
In-app support: via the “Help” or “Support” section in the TipTip app.