Privacy Policy
This policy explains how BytesWave LLC ("Dayn", "we", "us") collects, uses, stores, and protects personal data when you use our debt instrument documentation platform.
Who We Are
BytesWave LLC is a technology company incorporated in Abu Dhabi, United Arab Emirates. We operate the Dayn platform, accessible at getdayn.com, which enables individuals and businesses to issue, verify, and manage legally binding debt instruments across multiple jurisdictions.
For the purposes of applicable data protection laws (including UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection, and the EU General Data Protection Regulation where applicable), BytesWave LLC is the data controller.
Data Protection Officer: [email protected]
Data We Collect
We collect data in three ways: information you provide directly, information generated through platform usage, and information we receive from third parties.
| Category | Examples | Why Collected |
|---|---|---|
| Identity | Full name, national ID number, photo | legal document issuance |
| Contact | Email address, phone number, mailing address | Account management, OTP delivery, notifications |
| Organization | Company name, commercial registration, authorized signatories | Business instrument issuance |
| Financial | Debt amounts, currencies, payment records, bank details (billing only) | Instrument documentation, subscription billing |
| Usage | Pages visited, features used, session duration, IP address | Platform improvement, fraud detection |
| Device | Browser type, OS, device ID, time zone | Security, session management |
| Communications | Support tickets, chat messages, emails to us | Customer support |
We do not collect: social media passwords, genetic or biometric data, or data about minors under 18.
How We Use Your Data
- Platform services: Creating, storing and verifying debt instruments; sending OTP confirmations to debtors; generating PDF instrument documents.
- Identity: AML checks as required by UAE law and the jurisdictions in which instruments are issued.
- Communications: Transactional emails (document status, payment alerts, due-date reminders, security notices). You can opt out of non-essential notifications in your account settings.
- Billing: Processing subscription payments via our payment provider. We do not store raw card data.
- Security & fraud prevention: Monitoring for suspicious login activity, rate-limiting, IP reputation checks.
- Legal compliance: Responding to lawful requests from courts, regulators, and enforcement authorities.
- Platform improvement: Aggregated, anonymised analytics to improve features and performance. We never use identifiable data for marketing profiling.
Legal Basis for Processing
Under GDPR and the UAE Personal Data Protection Law, we process your data under one or more of the following lawful bases:
- Contract performance — processing necessary to deliver the services you signed up for.
- Legal obligation — AML requirements, court orders, regulatory requests.
- Legitimate interests — fraud prevention, platform security, aggregated analytics.
- Consent — marketing communications and optional cookies (you can withdraw consent at any time).
Data Sharing & Third Parties
We share data only where strictly necessary, with the following categories of recipients:
- Cloud infrastructure — AWS hosts our platform data in the eu-west-1 and me-south-1 regions.
- Payment processing — Stripe, Inc. processes subscription billing. Stripe is PCI-DSS Level 1 certified.
- SMS delivery — Twilio sends OTP verification codes. Only the recipient's phone number is shared.
- Email delivery — Amazon SES transmits transactional emails.
- Error monitoring — Sentry receives anonymised crash reports with no personally identifiable data.
- Legal authorities — Courts, regulators, and enforcement bodies where we are legally required to disclose.
All third parties are bound by data processing agreements and are prohibited from using your data for their own purposes.
International Data Transfers
Your data may be transferred to and processed in countries outside the UAE or EEA. When this occurs, we ensure appropriate safeguards are in place:
- Standard Contractual Clauses (SCCs) approved by the European Commission.
- Adequacy decisions where applicable.
- AWS regions chosen to minimise cross-border transfers where possible (Ireland for EU users, Bahrain for GCC users).
Data Retention
| Data Type | Retention Period | Reason |
|---|---|---|
| Account data | Duration of account + 3 years | Contractual obligations |
| Debt instrument records | 7 years from instrument creation | Legal / audit requirements (UAE Commercial Transactions Law) |
| Payment records | 7 years | Tax and accounting regulations |
| Identity documents | 5 years after last transaction | AML compliance |
| Support communications | 3 years | Dispute resolution |
| Security logs | 12 months | Fraud investigation |
| Anonymised analytics | Indefinitely (no personal data) | Platform improvement |
When you delete your account, we initiate deletion of your personal data within 30 days, except where retention is required by law.
Security Measures
- All data encrypted in transit (TLS 1.3) and at rest (AES-256).
- Amazon Aurora with automated backups and point-in-time recovery.
- Multi-factor authentication (SMS OTP & TOTP) available for all accounts.
- Role-based access control — staff access is least-privilege and audit-logged.
- Regular penetration testing and vulnerability scanning.
- SOC 2-compliant hosting infrastructure via AWS.
In the event of a data breach that poses a risk to your rights, we will notify you and relevant supervisory authorities within 72 hours of discovery.
Your Rights
Depending on your location, you have the following rights regarding your personal data:
- Access — request a copy of all personal data we hold about you.
- Rectification — correct inaccurate or incomplete data.
- Erasure — request deletion of your data ("right to be forgotten"), subject to legal retention requirements.
- Restriction — request we limit processing while a dispute is resolved.
- Portability — receive your data in a structured, machine-readable format (JSON or CSV).
- Object — object to processing based on legitimate interests or for direct marketing.
- Withdraw consent — for consent-based processing, withdraw at any time without penalty.
You also have the right to lodge a complaint with your local data protection authority. For UAE residents, this is the UAE Data Office For EU residents, this is your national supervisory authority.
Cookies & Tracking
We use strictly necessary cookies to operate the platform (session tokens, CSRF tokens, language and theme preferences). We do not use advertising cookies or third-party tracking pixels.
| Cookie | Purpose | Duration |
|---|---|---|
dayn_session | Authenticated session token (HttpOnly, Secure, SameSite=Strict) | Session / 30 days if "Remember me" |
dayn_csrf | Cross-site request forgery protection | Session |
dayn_theme | Light/dark mode preference (localStorage) | Persistent |
dayn_lang | Interface language preference (localStorage) | Persistent |
Contact & Data Protection Officer
For any privacy-related questions, data requests, or complaints, contact our Data Protection Officer:
[email protected]
Within 30 calendar days
BytesWave LLC, Abu Dhabi, UAE
app.getdayn.com/support