ANJALI DIGITAL PRECIOUS METALS LLC
1. Introduction
Anjali Digital Precious Metals LLC, operating under the app name Anjali Digital Metals (ADM) ("ADM," "Company," "we," "our," or "us"), registered and operating in the United Arab Emirates with offices at Shop No. 1, Al Souq Al Kabeer, Meena Bazar, Bur Dubai 3406, Dubai, UAE, is committed to protecting the privacy and confidentiality of all personal information we collect, process, and store in connection with the delivery of our digital precious metals services.
This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.anjalidigitalmetals.com, use the ADM app, or interact with us through any of our communication channels. By accessing our website or using ADM, you acknowledge that you have read, understood, and agree to the practices described in this Policy.
This Policy is prepared in compliance with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and any applicable regulations issued thereunder, as well as applicable AML/CFT/CPF laws and regulatory requirements in the UAE applicable to precious metals dealers.
2. Information We Collect
We may collect the following categories of personal and business information:
2.1 Information You Provide Directly
Full name, job title, and company or business name
Email address, phone number, and billing address
Billing and payment information processed securely through Lean Technologies, our authorised Open Banking payment services provider
Information required for AML compliance, know-your-customer (KYC) procedures, risk assessments, and regulatory screening where applicable
Details shared through our website contact form, email communications, or during account onboarding
2.2 Information Collected Automatically
When you visit www.anjalidigitalmetals.com or use the ADM app, we may automatically collect:
- IP address, browser type and version, and device identifiers
- Operating system and device information
- Pages visited, time spent on pages, and clickstream data
- Referring URLs and search engine queries
- App usage patterns, crash reports, and performance diagnostics via Firebase (Google LLC)
- Push notification interaction data (opens, dismissals) where you have granted notification permission
- Cookie identifiers and session data (see our Cookies section below)
2.3 App Device Permissions
The ADM app may request the following device permissions to enable full functionality. Each permission is requested only when relevant features are used and may be revoked at any time through your device settings:
Used for document scanning during KYC/onboarding verification
Used where voice-assisted features or video verification are available
Used to enable easy sharing of referral links or account details with your contacts
Used to upload identity documents, save transaction receipts, or export portfolio reports
Used to verify your region for regulatory compliance and to display localised precious metals pricing
Used to deliver real-time price alerts, transaction confirmations, and important account updates
Used for secure app login via fingerprint or face recognition where supported by your device
Required for all live price feeds, account sync, and payment processing
2.4 Information from Third Parties
In the course of providing our services and meeting our regulatory obligations, we may also receive information from publicly available databases, sanctions lists, PEP lists, and watchlists, as well as from regulatory authorities and government bodies in the UAE. We may also receive account and payment data from Lean Technologies in connection with Open Banking transactions you authorise.
3. How We Use Your Information
We use your personal information for the following lawful purposes:
Providing, maintaining, and improving the ADM app and our digital precious metals services
Fulfilling obligations under UAE AML/CFT/CPF laws, DNFBP regulations, and applicable precious metals dealer regulations, including customer due diligence (CDD) and enhanced due diligence (EDD) where required
Screening individuals and entities against international sanctions lists, PEP lists, and adverse media databases as required by applicable law
Processing and responding to your service enquiries, scheduling consultations, and managing your account
Sending real-time price alerts, transaction updates, and important account notifications via push notification, where you have granted permission
Processing payments and Open Banking transactions through Lean Technologies and generating invoices for services rendered
Using Firebase Analytics and Crashlytics to monitor app performance, diagnose crashes, and improve user experience
Monitoring usage patterns, improving website and app functionality, and enhancing user experience
Sending relevant updates on market changes, new services, and company news where you have opted in or where permitted by law
Ensuring the security of our platform, detecting and preventing fraud, and protecting users
Maintaining internal records, conducting audits, and managing business operations
4. Legal Basis for Processing
Under applicable UAE data protection law, we process your personal data on the following bases:
Processing is necessary to perform the services you have contracted with us, including payment processing via Lean Technologies and delivery of the ADM app
Processing is required to comply with UAE AML/CFT/CPF laws, precious metals dealer regulations, tax laws, and applicable regulatory obligations
Processing is necessary for our legitimate interests in operating and improving our business, including app analytics via Firebase, provided such interests do not override your rights
Where required for specific activities such as push notifications and marketing communications, we rely on your explicit consent, which you may withdraw at any time
5. Third-Party Services and SDKs
ADM integrates with the following third-party services and software development kits (SDKs). Each provider operates under its own privacy policy and data processing terms:
5.1 Firebase (Google LLC)
We use Firebase, a platform operated by Google LLC, for the following functions within the ADM app:
Collects anonymised app usage data including screen views, events, and user engagement metrics to help us understand how users interact with ADM
Collects crash reports and diagnostic data to help us identify and fix app stability issues
Powers push notification delivery for price alerts and account updates
Supports secure user authentication and session management within the app
5.2 Lean Technologies
We use Lean Technologies, a UAE-based licensed Open Banking fintech provider, to facilitate secure bank account linking and payment initiation. When you authorise a payment or connect your bank account through ADM, Lean Technologies processes your banking credentials and transaction data on our behalf under strict security and data protection obligations. Lean Technologies is subject to UAE Central Bank regulations and its own privacy policy available at leantech.me.
7. Sharing Your Information
We do not sell, rent, or trade your personal information. We may share your information in the following limited circumstances:
Your payment and banking data is shared with Lean Technologies solely for the purpose of processing Open Banking transactions you have explicitly authorised
Identity verification and KYC/AML data, including identity documents, selfies, and screening results, are shared with Sumsub, our third-party identity verification provider, solely for the purpose of conducting customer due diligence as required by UAE AML/CFT/CPF law. Sumsub processes this data on our behalf under strict data processing agreements. Sumsub is subject to its own privacy policy available at sumsub.com/privacy-notice
App usage, crash, and notification data is processed by Firebase under Google's data processing terms
Trusted third-party service providers who assist in delivering our services (e.g., cloud hosting, IT support), bound by strict confidentiality and data protection obligations
UAE regulatory and supervisory authorities (including relevant government bodies and law enforcement) where legally required or in response to lawful requests
A successor entity in the event of a merger, acquisition, or transfer of business assets, subject to equivalent privacy protections
8. Data Security
We implement appropriate technical and organisational security measures to protect your personal information against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:
- Encryption of data in transit and at rest using industry-standard protocols
- Access controls and role-based permissions to limit data access to authorised personnel only
- Biometric and multi-factor authentication options within the ADM app
- Crash monitoring and anomaly detection via Firebase Crashlytics
- Regular security assessments and staff training on data protection best practices
- Secure payment processing via Lean Technologies' regulated Open Banking infrastructure
While we take all reasonable precautions to safeguard your data, no method of electronic transmission or storage is completely secure. We encourage you to use caution when sharing sensitive information online.
9. Data Retention
We retain your personal information for as long as necessary to fulfil the purposes outlined in this Policy and to comply with our legal and regulatory obligations. Specifically:
- AML/KYC client data is retained for a minimum of five (5) years from the end of the business relationship, as required under UAE AML/CFT/CPF regulations
- Website and app usage analytics processed by Firebase is retained in accordance with Google's default retention settings, configurable by us within the Firebase console
- Payment and Open Banking transaction records via Lean Technologies are retained in accordance with UAE Central Bank and commercial law requirements
- General enquiry and correspondence records are retained for up to two (2) years
- Financial and billing records are retained in accordance with UAE commercial and tax law requirements
Upon expiry of the applicable retention period, your personal information will be securely deleted or anonymised in accordance with our data disposal procedures.
10. Your Data Protection Rights
Subject to applicable UAE law and regulatory limitations (including those applicable to AML/CFT/CPF compliance obligations), you have the following rights with respect to your personal data:
The right to request confirmation of whether we hold personal data about you and to obtain a copy
The right to request correction of inaccurate or incomplete personal data
The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations
The right to request that we limit processing of your data in certain circumstances
The right to object to processing of your data for marketing purposes or push notifications at any time
Where processing is based on consent (including push notifications and marketing), the right to withdraw consent at any time — withdrawing consent does not affect the lawfulness of prior processing
You may opt out of Firebase Analytics data collection through your device settings (iOS: Settings > Privacy > Tracking; Android: Settings > Google > Ads)
If you are not satisfied with our response, you have the right to lodge a complaint with the UAE Data Office or the relevant supervisory authority in your jurisdiction.
11. Push Notifications
The ADM app uses Firebase Cloud Messaging (FCM) to deliver push notifications including real-time gold and silver price alerts, transaction confirmations, account updates, and important security notices.
Push notifications require your explicit permission, which will be requested when you first use the relevant features of the ADM app. You may manage or revoke push notification permissions at any time through your device settings:
- iOS: Settings > Notifications > ADM
- Android: Settings > Apps > ADM > Notifications
Disabling push notifications will not affect your ability to use ADM but you will not receive real-time price alerts.
12. Third-Party Links
Our website and app may contain links to external websites, partner portals, or regulatory authority websites. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review the privacy policies of any third-party website or service you use, including Google / Firebase and Lean Technologies.
13. International Data Transfers
If you are accessing our services from outside the United Arab Emirates, your information may be transferred to and processed in the UAE or other countries where our service providers operate. Specifically, data processed by Firebase is transferred to Google LLC infrastructure in the United States. These transfers are governed by Google's standard contractual clauses and data processing agreements in accordance with applicable data protection law.
Where any cross-border transfers occur, we implement appropriate safeguards to ensure your data is protected in accordance with this Policy and the UAE PDPL.
14. Children's Privacy
The ADM app and our services are directed exclusively to adults aged 18 and above. We do not knowingly collect personal information from individuals under the age of 18. If you believe we have inadvertently collected such information, please contact us immediately at hello@anjalidigitalmetals.com and we will take prompt steps to delete it.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, services, third-party integrations, or applicable law. When we make material changes, we will update the 'Last Updated' date at the top of this Policy and, where appropriate, notify you by email or through a prominent in-app notice. We encourage you to review this Policy periodically to stay informed of how we protect your information.
16. Contact Us & Complaints
If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, or if you wish to exercise any of your data subject rights, please contact our Privacy team: