Effective from September 25, 2024.

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

The following privacy policy discloses existing features and announcing new services and features within the “Application” Mobimal such as: money transfer across Libyan banks via IBANs, NFC payment for contactless safe and fast payment, ability to generate and scan QR codes to ease the user’s journey as we are constantly working on improving our products.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Application refers to Mobimal mobile application, the software program provided by the Company.
• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Masarat for IT and financial services, Tripoli, Libya.
• Country refers to: Libya
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Application.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Add friend refers to a feature allowing users to scan QR code to add a beneficiary to preform money transfer transactions to National Commercial bank account holders and to other bank account holders in Libya.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

The application may require to read external storage in order to assure creation, display and save of PDF files within the app features such as (transfer receipts, statements, .etc. )

We do not store or transmit any data nor access external device storage.

We take your security seriously and we shall not access device storage or misuse your data

When You access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device You use, your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

• Information regarding your location
• Location access permission per session only.
• WebView Integration.
• Camera Access (payment via QR)
• Network Access
• SMS Autofill

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company’s servers and/or a Service Provider’s server or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

By using this secure process, we can verify your identity while safeguarding your privacy.

Money Transfer Service using IBAN to other banks

This section of the privacy policy explains how we collect, use, and disclose information related to our money transfer service using IBAN for bank account holders other than National Commercial bank accounts.

Information We Collect:

• Personal Information: In order to facilitate money transfers, we collect some personal information including:
  • Your name, address, phone number, and email address.
  • The recipient’s name and IBAN.
  • Transaction details such as amount, currency, and reference (if provided).
• Identification Verification: To comply with regulations and prevent fraud, we may in the future collect identification documents (verified ID).
• Device Information: We may collect basic device information (device type, operating system) to ensure secure transactions and improve service functionality.

How We Use Your Information:

• Process Money Transfers: We use your information to process your money transfer requests accurately and efficiently.
• Verify Identity and Prevent Fraud: We use your information to verify your identity and prevent fraudulent activity on our platform.
• Customer Support: We may use your information to respond to your inquiries and provide customer support.
• Compliance with Law: We may disclose your information if required by law or regulation, or in response to a valid legal request.

Information Sharing:

• Third-Party Service Providers: We may share your information with third-party service providers who assist us in operating the money transfer service (e.g., payment processors, fraud screening services). These providers are obligated to handle your information securely and in accordance with our privacy standards.
• Regulatory Authorities: We may share your information with regulatory authorities if necessary to comply with anti-money laundering (AML) and know-your-customer (KYC) laws.

Data Security:

• We take data security seriously and implement various safeguards to protect your information, including encryption, access controls, and regular security audits.

Disclaimer:

We are committed to protecting your privacy and using your information responsibly. Here’s how we ensure your trust:

• No Data Misuse: We strictly prohibit the use of your personal information for any purpose other than facilitating your money transfers, verifying your identity, preventing fraud, complying with the law, and providing customer support.
• No External Storage: Your money transfer data, including IBANs, transaction details, and identification documents, is never stored on servers outside our secure infrastructure controlled by us.

Permissions and access control:

Features and Permissions

MobiMal app offers a variety of features to make managing your finances easier. To provide these features, we may request certain permissions from you. These permissions allow the app to access specific functionalities on your device, but we do not collect any unnecessary personal information.

• Find Nearby ATMs/Branches (Optional):  Enable location services to see ATMs and branches conveniently displayed within the app.
• Mobile Check Deposit: With camera access, you can securely deposit checks using your phone’s camera.
• Secure Login and Performance: To make logging in faster and the app run smoother, we may store some limited information on your device with your permission. This information is securely encrypted and never shared with anyone.
• Send/Request Money (Optional): Easily send or request money directly through the app.
• Stay Informed (Optional): Keep track of your finances with helpful notifications. We can send you alerts about your account activity, including transaction confirmations, security notifications, and balance updates. You can choose to enable or disable notifications at any time.

• Camera Access

Our mobile banking app may request permission to access your device’s camera. This permission is solely for features that allow you to take pictures within the app, such as:

• QR code scan for payment.

We do not collect or store any camera data, including images or videos, on our servers. The images captured using the camera are used only for the specific functionality within the app and are not retained once the function is complete.

Granting Camera Permission

You are not required to grant camera permission to use the core functionalities of our mobile banking app. However, certain features may be unavailable without camera access. You can manage camera permissions for our app through your device settings.

Remember: You can always revoke permission later through your device’s settings.

Use of Your Personal Data

We may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

While no online system is completely impenetrable, we implement robust security measures to protect your personal data. These measures include:

• Encryption: We encrypt your personal data in transit and at rest using industry-standard encryption protocols.
• Access Controls: We restrict access to your personal data to authorized personnel only.
• Regular Security Audits: We conduct regular security audits to identify and address any potential vulnerabilities.

In the unlikely event of a data breach, we will notify you promptly and take appropriate steps to mitigate the risk. We will also transparently communicate the nature of the breach and any recommended actions for you to take.

We are committed to transparency and user control. You have the right to access, update, or delete your personal data (subject to applicable laws). Please refer to the “Your Rights” section of this Privacy Policy for details.

Children’s Privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Your Rights

We respect your control over your personal data. Depending on your location and applicable data protection laws, you may have certain rights regarding your personal data. These rights may include:

• Right to Access: You have the right to request a copy of the personal data we hold about you. This will allow you to know what data we have collected, why we have it, and with whom we share.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data. This means we can store your data but not use it further.
• Right to Data Portability: You have the right to request that we transfer your personal data to another organization, or to you, in a machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data for certain purposes, such as direct marketing.

If you wish to exercise any of these rights, please contact us using the information provided in the “Contact Us” section below. We will respond to your request within a reasonable timeframe.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: support@masarat.ly
• By phone number: 0900300900