Privacy Policy
Version 1.0 — effective 7 October 2026
1. Who is responsible for your data
The “controller” is the Dazway company that serves you: DazWay ApS · c/o LegalDesk.dk ApS, Njalsgade 21F, 2., 2300 København S, Denmark · CVR 46378385 for customers and resellers in the EU/EEA, and Dazway Portal L.L.C S.O.C · ALSAFI 1 - 204, Al Mararr, Deira, Dubai, United Arab Emirates · Trade licence 1605660 (Dubai Department of Economy and Tourism) · TRN 105400162100001 for the UAE and all other countries. Where both are involved they act as separate controllers for their own purposes and share data only as described here. Contact us at sales@dazway.com.
2. What we collect
| Category | Examples | Source |
|---|---|---|
| Account | Name, email, password (stored hashed), language, country | You |
| Orders and payments | Products bought, amount, currency, order history, payment status and a masked card or wallet reference (the payment provider holds full card data) | You / payment provider |
| Delivery | Email address; phone number for a direct top-up (only when you choose one); Code and delivery status | You / suppliers |
| Support | Messages, attachments, WhatsApp and call records | You |
| Device and usage | IP address, device and browser type, pages viewed, error logs, security signals | Automatically — see the Cookie Policy |
| Fraud and compliance | Risk scores; sanctions and anti-money-laundering screening results (resellers and, where required, customers) | Us / screening providers |
| Resellers (additional) | Business and owner identity, registration documents, address, tax ID, bank details, payout history | You / registries / verification providers |
We do not need special-category data (such as health or religion) and do not knowingly collect it. Please do not send it to us.
3. Why we use it, and our legal basis
| Purpose | EU/EEA legal basis (GDPR Art. 6) | UAE basis (PDPL) |
|---|---|---|
| Create and run your account; take payment; deliver your Code; give support; process refunds | Contract (Art. 6(1)(b)) | Necessary to perform the contract |
| Prevent fraud and secure the Platform; resolve disputes | Legitimate interests (Art. 6(1)(f)) | Legitimate interests / legal claims; consent where required |
| Accounting, tax invoices, tax reporting, anti-money-laundering and sanctions compliance, answering authorities | Legal obligation (Art. 6(1)(c)) | Legal obligation |
| Verify and onboard resellers; calculate and pay commission | Contract and legal obligation | Contract / legal obligation |
| Service emails (receipts, security, delivery) | Contract / legitimate interests | Contract |
| Non-essential cookies and analytics | Consent (Art. 6(1)(a); ePrivacy Art. 5(3)) | Consent |
| Marketing emails (only if you opt in) | Consent | Consent |
4. Who we share data with
- Payment providers and banks, to take payments and make payouts.
- Suppliers and operators — only what is needed to issue your Code or top-up (for example the phone number for a direct top-up).
- Service providers acting on our instructions: hosting and platform operation, email delivery, customer-support tools, fraud-prevention and identity-verification services.
- Resellers — a reseller sees orders made in their store only in the minimum form needed (for example an order reference and the Product). They do not receive your email address or payment details.
- Authorities — tax, financial-intelligence, regulators, law enforcement and courts, where the law requires; and other Dazway group companies for the purposes above.
- We do not sell your personal data.
5. International transfers
We operate across Denmark, the UAE and other countries. When we transfer personal data out of the EU/EEA to a country without an EU adequacy decision (including the UAE), we use the EU Standard Contractual Clauses, assess the risks of the transfer, and apply safeguards such as encryption. Transfers out of the UAE follow the cross-border conditions of the UAE Personal Data Protection Law (PDPL). You can ask for a copy of the safeguards at sales@dazway.com.
6. How long we keep it
| Data | Retention |
|---|---|
| Account data | While your account is open + 24 months, then deleted or anonymised |
| Orders, invoices and payment records | 5 years from the end of the financial year (Danish Bookkeeping Act; UAE VAT records at least 5 years; longer where UAE corporate-tax rules require) |
| Anti-money-laundering and reseller verification records | 5 years after the relationship ends, or longer if the law requires |
| Support records | 3 years after the case closes |
| Security and log data | 12 months |
| Cookie-consent records | 12 months |
7. Your rights
If you are in the EU/EEA you can: access your data; correct it; delete it; restrict or object to processing; receive a portable copy; withdraw consent at any time; and object to marketing. Under the UAE PDPL you have corresponding rights, including access, correction, erasure, restriction, objection to automated decisions and portability. Email sales@dazway.com — we respond within one month (extendable where the law allows). We may need to verify your identity, and some rights are limited where we must keep data by law.
8. Automated decisions and fraud checks
We use automated tools to spot fraud and abuse. These can delay or block an order. You are never subject to a decision with legal or similarly significant effect based solely on automation without the chance to have a person review it: write to sales@dazway.com and a member of staff will look at it.
9. Security
We use encryption in transit and at rest for sensitive data, role-based access, logging and regular testing. Codes and PINs have additional protection. If a breach is likely to put your rights at risk, we notify the supervisory authority (within 72 hours in the EU) and you, where required.
10. Children
Dazway is for adults. We do not knowingly collect children’s data; if we learn we have, we delete it.
11. Cookies
See the Cookie Policy. You can change your choices at any time under “Cookie settings”.
12. Complaints
Please contact sales@dazway.com first. You may also complain to your supervisory authority — in Denmark, Datatilsynet (datatilsynet.dk) — or the authority of your EU country of residence; in the UAE, the UAE Data Office.
13. Changes
We will update this policy when our practices change and tell you of material changes by email or on the Platform.
