APS HOLD Advanced Payment Solutions Holding

Privacy policy

Last updated: March 2026

This policy explains how Advanced Payment Solutions Holding (“APS HOLD”, “we”, “us”) collects, uses and protects personal data when you visit apshold.com, contact us or use our services. We are established in Abu Dhabi Global Market (ADGM) and process personal data in line with the ADGM Data Protection Regulations 2021.

1. Who is responsible for your data

Advanced Payment Solutions Holding, Al Khatem Tower, ADGM Square, Al Maryah Island, Abu Dhabi, United Arab Emirates, is the controller of personal data collected through this website. Where a group company processes data under its own name, that company is the controller and its own notice will apply.

When we process payment data on behalf of merchants, payment service providers or other business clients, we act as a processor under their instructions. In that case, the client’s privacy notice explains how your data is used.

2. Personal data we collect

  • Information you give us: your name, work email, company, job title and the content of your enquiries.
  • Business verification data: details about directors, shareholders and beneficial owners that we must collect to onboard business clients.
  • Transaction data: payment amounts, dates, merchant details and tokenised payment method information.
  • Technical data: IP address, device and browser type, and how you use our website, collected through cookies and similar technologies.

3. How we use personal data

  • To respond to enquiries and provide the services you request.
  • To process payments and detect, prevent and investigate fraud.
  • To meet our legal obligations, including customer due diligence and transaction monitoring under UAE anti-money laundering laws.
  • To keep our systems secure and improve our website and services.
  • To send you updates you have agreed to receive. You can unsubscribe at any time.

4. Legal grounds for processing

We process personal data only where we have a lawful basis under the ADGM Data Protection Regulations 2021. Depending on the purpose, this is to perform a contract with you or your organisation, to comply with a legal obligation, for our legitimate interests (such as preventing fraud and securing our services) where these are not overridden by your rights, or with your consent.

5. Automated decisions and AI

Our services use AI models to assess payment risk and detect fraud in real time. These assessments help decide whether a payment is approved, declined or sent for further checks. Our models are governed by rules set and reviewed by people. Where a decision based solely on automated processing has a significant effect on you, you can ask for human review, express your point of view and contest the decision.

6. Who we share data with

We do not sell personal data. We share it only where necessary with:

  • other APS HOLD group companies that help provide our services;
  • banks, card networks, acquirers and payment partners involved in processing a transaction;
  • service providers such as hosting, security and identity verification providers, under contracts that protect your data;
  • regulators, law enforcement and other authorities, including the ADGM Financial Services Regulatory Authority and the UAE Financial Intelligence Unit, where the law requires it.

7. Transfers outside ADGM

Some recipients may be located outside ADGM. We transfer personal data only to jurisdictions recognised as providing adequate protection, or where appropriate safeguards are in place as required by the ADGM Data Protection Regulations 2021, such as approved contractual clauses.

8. How long we keep data

We keep personal data only as long as needed for the purposes above. Records required under UAE anti-money laundering laws are kept for the periods those laws set, which is at least five years after a business relationship ends or a transaction is completed. Enquiry data is deleted when it is no longer needed.

9. How we protect data

We use technical and organisational measures appropriate to the risk, including tokenisation of payment details, encryption in transit and at rest, strict access controls and continuous monitoring.

10. Your rights

Subject to the law, you have the right to access your personal data, have it corrected or erased, restrict or object to its processing, receive it in a portable format, and withdraw consent at any time. Some rights may be limited where we must keep data to meet legal obligations, such as anti-money laundering requirements.

To exercise your rights, email info@apshold.com. If you are not satisfied with our response, you can complain to the ADGM Office of Data Protection.

11. Cookies

We use cookies to run and improve our website. See our cookie policy for details and choices.

12. Changes to this policy

We may update this policy from time to time. The date at the top shows when it was last changed. Significant changes will be highlighted on this website.

13. Contact us

Data Protection, Advanced Payment Solutions Holding, Al Khatem Tower, ADGM Square, Al Maryah Island, Abu Dhabi, United Arab Emirates. Email: info@apshold.com.