- 1. About this notice
- 2. Who we are and how to contact us
- 3. Scope
- 4. The personal data we collect
- 4.1 From UAE PASS, when you sign in
- 4.2 Information you enter
- 4.3 Documents you upload
- 4.4 Information we create
- 4.5 Communications
- 4.6 Technical information
- 4.7 What we do not collect
- 5. Sensitive personal data
- 6. Where your data comes from
- 7. Why we use your data and our legal basis
- 8. Automated comparison and the Ninja Score
- 9. Who receives your data
- 10. Where we store your data and international transfers
- 11. How long we keep your data
- 12. Cookies
- 13. Minimum age
- 14. How we protect your data
- 15. Your rights
- 16. Contact us and complaints
- 17. Changes to this notice
- 18. Governing law
1. About this notice
NinjaCompares helps you compare personal loans, credit cards, auto finance and home finance from banks in the UAE, and send an application to the bank you choose. We are a licensed finance broker. We do not lend money and we do not make credit decisions. The bank you choose reviews your application and decides.
This notice explains what personal data we collect, why we use it, who receives it, where we store it, how long we keep it and what your rights are. It applies when you visit ninjacompares.com, sign in with UAE PASS, compare products, upload documents, apply to a bank or contact us.
It is issued under Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the UAE PDPL) and its implementing regulations. It forms part of our Terms and Conditions, which refer to it in clauses 5.3, 6.4 and 16.
2. Who we are and how to contact us
| Item | Details |
|---|---|
| Legal entity (data controller) | Contento Finance Brokers L.L.C |
| Trading name | NinjaCompares |
| Licence | Finance broker licensed by the Department of Economy and Tourism, Dubai (DET). Licence No. 1553278 |
| Registered address | Warehouse P2, Block T, Saih Shuaib 3, 13-0, Dubai, UAE |
| General contact | hello@ninjacompares.com |
| Privacy contact | privacy@ninjacompares.com |
| Data Protection Officer | Lisandra Peterson |
For the purposes of the UAE PDPL, Contento Finance Brokers is the controller of the personal data described in this notice.
3. Scope
This notice covers personal data about:
- Customers and prospective customers: people who sign in, compare products or apply through NinjaCompares.
- Website visitors: people who browse ninjacompares.com.
- People who contact us: by email, phone or WhatsApp.
Once we send your application to a bank at your request, that bank becomes an independent controller of what it receives. It processes your data under its own privacy notice, which we recommend you read. This notice does not cover third-party websites linked from our site.
4. The personal data we collect
We collect the personal data described in sections 4.1 to 4.6. Section 4.7 lists what we do not collect.
4.1 From UAE PASS, when you sign in
When you sign in with UAE PASS, the UAE's national digital identity, we receive:
- your UAE PASS unique user ID
- Emirates ID number
- full name in English and Arabic, first name and last name
- nationality, date of birth and gender
- email address and mobile number
- account type (citizen, resident or visitor)
We never receive your UAE PASS password or PIN, or any face or fingerprint data.
We use your date of birth to check your age for the products you compare, including the longest finance term your age allows. Your gender comes with your UAE PASS profile; we do not use it to compare products or to prepare your application.
4.2 Information you enter
- Income: income type (salaried or business owner), monthly income, other monthly income and existing monthly commitments.
- Employment and eligibility answers: for example, employer category, whether your salary is transferred to a bank, time in your current job, Golden Visa status and whether your employer is on a bank's list.
- What you want: finance amount and term, property or vehicle value, down payment, property type and emirate, vehicle model year and condition, and credit card preferences.
4.3 Documents you upload
- The documents the bank requires for the product, for example Emirates ID, passport, visa, salary certificate, bank statements, driving licence, employment contract and proof of home-country address.
- Any additional document a bank asks for during its review.
4.4 Information we create
- Comparison results: the offers you are likely to be eligible for, ranked, with indicative rates and instalments.
- Your application: its status history and our staff's review notes.
- Ninja Score: a guide from 0 to 100 to how strong your profile looks for the finance you are comparing, worked out from your salary, your existing commitments, the instalment of the new finance and your age. It is not a credit score.
- Consent records: the consent you gave, the policy version, the date and time, and your IP address.
4.5 Communications
- Emails between us and the bank about your application, including attachments and any reference numbers the bank issues.
- Emails we send you about your application, for example document requests, bank decisions and reminders.
- Our staff's notes from phone and email contact with you.
- WhatsApp chats you start with us from the button on our website. These take place on WhatsApp, a service of Meta.
4.6 Technical information
- Sign-in session cookies and browser storage the site needs to work.
- Analytics and marketing cookies, only if you accept them in the cookie banner. See our Cookie Policy.
- Error reports and server logs. These are designed to exclude personal data, and sensitive fields are removed automatically.
4.7 What we do not collect
- We do not connect to your bank accounts. We do not use open banking at launch. If we offer it in future, we will update this notice before it goes live and ask for your separate consent.
- We do not collect payment card details.
5. Sensitive personal data
We do not set out to collect sensitive personal data, such as health, biometric, religious or criminal-record data. UAE PASS verifies your identity on its own systems, and we receive no biometric data from it.
Some documents you upload, such as a passport, may show details like religion or a photo. We use these documents only to prepare your application, we protect them with extra access controls, and we send them only to the bank you choose.
6. Where your data comes from
- From you: what you enter, upload, or tell us by email, phone or WhatsApp.
- From UAE PASS: the verified identity details listed in section 4.1.
- From the bank you apply to: its requests, reference numbers and decision on your application.
- From your device: cookies and technical data, as described in section 4.6 and our Cookie Policy.
7. Why we use your data and our legal basis
| Purpose | Legal basis under the UAE PDPL |
|---|---|
| Signing you in and keeping your account secure, through UAE PASS | Steps you ask us to take before a contract; our legitimate interest in security |
| Comparing products and showing offers you are likely to be eligible for | Steps you ask us to take before a contract |
| Preparing your application, reviewing your documents and sending them to the bank you choose | Your consent to share your documents with the banks you apply to, which you give once and can withdraw at any time from your profile |
| Following up with the bank and passing its requests and decision to you | Performance of our service to you; your consent |
| Emailing you about your application, including reminders about missing documents | Performance of our service to you |
| Marketing by email, SMS or WhatsApp | Your consent, which you can withdraw at any time |
| Website analytics and campaign measurement | Your consent through the cookie banner |
| Preventing fraud and misuse of the platform | Legitimate interests; legal obligation |
| Meeting legal and regulatory duties, including anti-money-laundering (AML) record keeping | Legal obligation |
| Handling complaints and defending legal claims | Legitimate interests; legal obligation |
8. Automated comparison and the Ninja Score
Our comparison is automated. It filters and ranks bank products using the information you enter, to show the offers you are likely to be eligible for. The Ninja Score is also automated.
Neither of these is a credit decision. The bank you apply to decides whether to approve your application, and on what terms, using its own process. Under the UAE PDPL, you can object to decisions based solely on automated processing that significantly affect you. If you want a person on our team to review your comparison results or your Ninja Score, contact us (section 2).
The AI tool that reads bank replies is switched off at launch. If we switch it on, we will update this notice first.
9. Who receives your data
We send your application only to the bank you choose, and only after you have agreed to share your documents with the banks you apply to. We never share it with banks you have not chosen. We do not sell your personal data.
| Recipient | What they receive | Why | Location |
|---|---|---|---|
| The bank you choose | The application details and documents you agreed to send | To assess your application. The bank is an independent controller once it receives them | UAE |
| Microsoft Azure | All platform data: servers, document storage, encryption keys | Hosting the platform | UAE (UAE North) |
| MongoDB Atlas | All platform data (database) | Database, over a private network connection | UAE (UAE North) |
| Email provider: Microsoft 365 (Exchange Online) | Emails with banks and with you, including attachments | Sending and receiving email | UAE |
| UAE PASS (UAE Government) | Sign-in | Verifying your identity | UAE |
| Google (Analytics, Tag Manager) | Cookie data, only if you accept | Website analytics and advertising measurement | May be outside the UAE |
| Cookiebot (Usercentrics A/S, Denmark) | Your cookie choice | Running the cookie banner | EU |
| WhatsApp (Meta) | Chats you start with us | Customer support | Outside the UAE |
We may also disclose personal data where the law requires it, for example to the Central Bank of the UAE, the UAE Data Office, the Department of Economy and Tourism, courts, or police. We may also share it with our auditors and lawyers under duties of confidentiality. If our business is sold or restructured, data may pass to the new owner under the same protections.
Our service providers act only on our instructions, under contractual data protection terms.
10. Where we store your data and international transfers
All platform data, including your profile, your application and your documents, is stored in the UAE, on Microsoft Azure UAE North and MongoDB Atlas in the same region.
Some data is handled outside the UAE:
- Google Analytics / Tag Manager and Cookiebot: cookie data, only if you accept non-essential cookies.
- WhatsApp: chats you choose to start with us.
We transfer personal data outside the UAE only as the UAE PDPL allows (Articles 22 and 23). That means the destination has adequate protection, or the transfer is covered by contractual safeguards with the provider, or it is needed to provide the service you asked for, or you have given your consent. You can ask us about the safeguards for any transfer.
11. How long we keep your data
We keep personal data only as long as we need it for the purposes in this notice, or as long as the law requires. After that, we delete it securely or anonymise it.
| Data | Retention period | Reason |
|---|---|---|
| Records we must keep for anti-money-laundering purposes (identity, application, documents sent to a bank, communications) | 5 years after your last application closes | Legal obligation |
| Consent records | For as long as the related records are kept, including after you withdraw consent | Proving consent |
| Documents not under AML retention (for example, an uploaded file never sent to a bank) | 12 months after your last application closes | No longer needed |
| Account and profile data, with no application ever sent | 12 months after your last sign-in | No longer needed |
| Marketing preferences | Until you withdraw consent | Your consent |
| Cookie data | As set out in our Cookie Policy | Your consent |
13. Minimum age
NinjaCompares is for people aged 18 or over. We check your date of birth from UAE PASS, and we do not accept applications from anyone under 18. If you believe someone under 18 has given us their data, contact us and we will delete it.
14. How we protect your data
- Encryption in transit (HTTPS) and at rest (database and document storage).
- Extra field-level encryption for the most sensitive data: Emirates ID number, email, mobile number, income, commitments, loan figures and quotes, bank reference numbers and staff notes.
- Private document storage. Documents are never shared by public links, and every time a staff member views a document, it is logged.
- Role-based staff access (super admin, operations, rates manager), with a separate staff sign-in.
- Logs are designed to exclude personal data.
No system is completely secure. If a breach of personal data is likely to put your rights at risk, we will notify the UAE Data Office and the people affected, as the PDPL requires.
15. Your rights
Under the UAE PDPL, and subject to its conditions, you have these rights:
| Right | What it means | How to use it |
|---|---|---|
| Information | To know how we use your data. This notice is how we tell you | Read this notice |
| Access | To get a copy of the personal data we hold about you | Email the privacy contact |
| Correction | To fix data that is wrong or incomplete | Update your profile, or email us |
| Deletion | To ask us to delete data we no longer have a reason to keep. Data we must keep by law, for example AML records, cannot be deleted until its retention period ends | Email us |
| Restriction | To ask us to limit how we use your data in certain cases | Email us |
| Portability | To receive data you gave us in a common machine-readable format | Email us |
| Objection and withdrawal | To object to marketing or processing based on our legitimate interests, and to withdraw any consent | Email us |
| Automated processing | To object to decisions based solely on automated processing, and to ask for human review (see section 8) | Email us |
| Complaint | To complain to the UAE Data Office | See section 16 |
We may need to verify your identity before we act on a request. We will reply within the time the PDPL and its regulations set, and in any case within 30 days. There is normally no charge.
16. Contact us and complaints
For any question about this notice or your data, or to use your rights, contact:
- Email: privacy@ninjacompares.com
- Post: Privacy, Contento Finance Brokers L.L.C, Warehouse P2, Block T, Saih Shuaib 3, 13-0, Dubai, UAE
If you are not satisfied with our response, you can complain to the UAE Data Office. We would appreciate the chance to resolve your concern first.
17. Changes to this notice
We may update this notice when our services, the law or regulatory guidance change. We will post the new version on this page with a new "Last updated" date and version number. If a change is significant, we will tell you before it applies, and ask for your consent again where needed.
18. Governing law
This notice is governed by the laws of the United Arab Emirates, including the UAE PDPL and its implementing regulations. If the English and Arabic versions differ, the Arabic version prevails, as in our Terms and Conditions.
NinjaCompares is a trading name of Contento Finance Brokers L.L.C, Dubai, UAE.
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