PalPay Mahfazati – Privacy Policy

PalPay Mahfazati – Privacy Policy

Last updated: August 31, 2020

PalPay Mahfazati is an E-wallet app provided by PalPay Prepaid services, licensed and regulated by the Palestinian Monitory Authority (PMA) under the laws of Palestine. Adult Palestinians, having a valid Palestinian ID and a valid Palestinian mobile number can download, register and use PalPay Mahfazati app. According to the PMA regulations and laws, the registered client must provide specific list of information in order to be able to enroll and use PalPay Mahfazati.

When you download, register and use PalPay Mahfazati app, you’re trusting us with your information. We understand this is a big responsibility and work hard to protect your information by applying local and international Privacy Polices including the Palestine Monitory Authority Polices, and put you in control to decide whether to accept or decline. This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how it will be used. You can update, manage, export, and delete your information.

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 means the software program provided by the Company downloaded by You on any electronic device, named Mahfazati

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to PalPay Prepaid services Ltd., Palestine, Ramallah CCC 3.

Consumer, means any natural person who is using the services provided by the Company through the Application.

Country refers to: Palestinian Territories

Data Controller, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

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, these include any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

Service refers to the Application or the Website or both.

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).

Website refers to www.palpay.ps, accessible from https://mahfazatim.palpay.ps

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.

Pay To merchant means a wallet client performing a financial payment to one of the contracted merchants.

Pay to friend means a wallet client performing a fund transfer to another wallet client.

Cash out means a wallet client performing a cash withdrawal from a contracted agent.

Registration and enrollment means to download and fill all required information, and become a PalPay – Mahfazati client.

PMA means Palestine Monitory Authority, the wallet regulator in Palestine

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

As per the PMA regulations described above, you are requested to provide the following information in order to be able to register and use PalPay – Mahfazati app. This information will be used to identify you, and to send you relevant information about the transactions and activities you will be conducting using PalPay – Mahfazati app.

Data Required for Registration and Enrollment  

• Date of Birth
• National ID Number
• Photocopy of the National ID
• Personal Photo (selfie)
• Full name
• Gender
• Mobile Number
• Email Address
• Full Address
• Employment details

Usage Data and Transactions History

Usage Data is collected automatically when using the Service.

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.

Further, we shall collect and keep a record of all transactions which you perform while using the Application

Information Collected while Using the Application

While using PalPay Mahfazati app, and in order to provide additional features of our App, and make it easy for you while using the services listed below we shall ask your prior permission to access:

• Information from your Device’s phone book (contacts list)
• Pictures and other information from your Device’s camera.

We will display and explain which information we use from your contacts list? How it will be used? In addition, why we will use the camera?

We will ask your permission to access to your contact list only when performing the following transaction:

1. Pay to friend. Person to person money transfer.
2. Pay to merchant. Payment to merchants.
3. Cash out. Cash out from one of our registered agents.

We will ask you to accept or deny the access to your contacts after we display one of the following messages:

For Pay to Friend

“This method for using “Pay to Friend” requires access to your contact list and contact data; as to allow the application to complete these kind of Transactions using the “Mobile Number” of the receiving party. The contact list and contact data will be accessed by the application for “Pay to Merchant” and Cash Out” services as well. For your convenience, we do save the mobile numbers of the receiving parties of the latest “Pay to Friend”, “Pay to Merchant”, and “Cash Out” transactions you have made, in case you wanted to do the transactions for the same numbers again, but we do not use this information without your permission.”

For Pay to merchant:

This method for using “Pay to Merchant” requires access to your contact list and contact data; as to allow the application to complete these kind of Transactions using the “Mobile Number” of the receiving party. The contact list and contact data will be accessed by the application for “Pay to Friend” and Cash Out” services as well. For your convenience, we do save the mobile numbers of the receiving parties of the latest “Pay to Friend”, “Pay to Merchant”, and “Cash Out” transactions you have made, in case you wanted to do the transactions for the same numbers again, but we do not use this information without your permission.

For Cash out:

This method for using “Cash Out” requires access to your contact list and contact data; as to allow the application to complete these kind of Transactions using the “Mobile Number” of the receiving party. The contact list and contact data will be accessed by the application for “Pay to Merchant” and ‘Pay to Friend” services as well. For your convenience, we do save the mobile numbers of the receiving parties of the latest “Pay to Friend”, “Pay to Merchant”, and “Cash Out” transactions you have made, in case you wanted to do the transactions for the same numbers again, but we do not use this information without your permission.

You can enable or disable access to this information at any time, through Your Device settings, however, disabling such access would prevent you from using the Application’s associated features and the relevant services.

Pictures and other information from your Device’s camera.

We request your permission to access the camera in one of the following cases:

1. During the registration of an adult account. The registration process requires to capture the required by law Palestinian ID and picture.
2. To make it convenient for you and speed the process of Pay to friend, Pay to merchant, and Cash out, we use a quick method that requires to read a specific QR code generated by the receiving party, using your camera.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To comply with local laws.
• 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 inquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.

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 according to PMA law. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Transfer of Your Personal Data

Your information, including Personal Data, may be processed at the Company’s operating offices only.

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.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to us. While we strive to use commercially acceptable means to protect Your Personal Data, We are the best known security measures to protect your data.

Detailed Information on the Processing of Your Personal Data

Service Providers (Agents) have limited access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

Children’s Privacy

The PalPay-Mahfazati application does not target children, however PalPay offers a “minor” account, which allows parents to create a sub-wallet for their children, as part of their wallet. PalPay – Mahfazati does not collect any information from the child (minor) account. The required fields for children registering will be filled by the child’s parent when creating a minor sub-account. The child then will receive his relevant login information by SMS; download the app and enter received login information.

We are currently restricting the registration for the minors who are older than 13 and below 18 years old.

PalPay – Mahfazati app does not request the child (minor) to fill any data, there are no sections or services in the app that required the usage of any external API’s or SDK’s .

PalPay – Mahfazati app does not use any external link that should provide external identification for the client or the child; e.g. PalPay – Mahfazati will never ask the child or the client to use his social media account, Google account or any other account to get access to any of our service.

Information Collected from Children under the Age of 18

The Company does not collect any information from children under 18 years, the parent is the one who create a sub-account for his child by filling basic information required by the law and regulations. The required information is:

• Date of Birth
• Child reserved National ID Number
• Child Name
• Gender
• Mobile Number
• Email Address
• Parent’s or guardian’s mobile number

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: policy@palpay.ps