Privacy Policy of Alyf

Preamble

Alyf is owned by Paymob SARL, a Moroccan limited liability company with capital of ninety thousand dirhams (90,000 dhs), headquartered at Casablanca, 259 Lotissement Lina, 1st floor Sidi Maarouf, registered under number 392123 with the Casablanca Trade and Companies Register. Paymob SARL respects your privacy and is committed to applying transparent privacy protection rules. This Privacy Policy explains how we collect, use and share your personal information in connection with your use of the Alyf application and explains your rights with respect to how we treat your personal information.

Protecting your personal data and privacy is one of our top priorities. That's why, at (hereinafter referred to as "Alyf" or "we" or "us" or "our"), we detail this Data Protection Policy explaining our practices regarding the collection, use and disclosure of the information we receive, when you use our Application (Alyf) and our services.

This Data Protection Policy applies only to the Services available on the Alyf Application. Paymob collects your personal data in order to comply with regulatory provisions and to ensure the best quality of service. This processing has been the subject of a request for authorization from the The National Commission for the Control of Personal Data Protection, which has been approved by authorization no. A-GC-667/2022 issued following decision no. 199-2023.

Personal data concerning the User may be subject to the exercise of the right of access, rectification, and opposition in accordance with the provisions of Law 09-08. This can be done by sending an email to support@paymob.ma or by sending a written letter with acknowledgment of receipt to Customer Service at the following address: Paymob, 259 Lotissement Lina, 1st floor, Sidi Maarouf, Casablanca, mentioning "Paymob Complaint" in the subject line.

1. Purpose of this Data Protection Policy

The personal data protection policy applies to all users and prospects for the provision of products and services defined in Alyf's General Terms of Use. It is regularly updated to reflect changes in Alyf's practices as well as potential changes in the regulations applicable to personal data. Alyf encourages its users to consult it regularly to be aware of any modifications or updates made.

As a Moroccan company, Alyf complies with all regulations and recommendations issued by the National Commission for the Control of Personal Data Protection (CNDP).

In accordance with the provisions of Law No. 09-08 relating to the protection of individuals with regard to the processing of personal data, the User acknowledges and accepts that their personal data is intended for Alyf and is subject to processing operations for the management of their Account and the execution of the Contract, such as:

• collection;
• recording;
• storage in various forms and for any duration;
• any other processing in general, including all transfers by Alyf to its business partners, advisors, subcontractors, and judicial authorities.

The purposes of processing this data are: technical purposes, information on the subscribed Services, adaptation of the subscribed Services, and Account management.

2. Information Collected by Alyf                                                                                                    

2.1 Required Data During Alyf Application Operation

When you sign up on the Alyf application, we collect your language preferences and phone number. An automatic message with a verification code is sent to verify your phone number. We gather various data to enhance the service we provide, including:

• Device Information: Device type, OS version, Android or iOS identifier (Device ID), IP address, device model, software version, screen size, mobile operator name, time zone, download location of the application, and type of network used (e.g., WiFi).

• Usage and Connection Information: Time and date of app opening, pages visited within the app, time and date of app closure, duration of app usage, and transaction data (details below). Alyf also collects crash data or cookies.

• Transaction Data: Transaction times, dates, senders, recipients, amounts transferred, amounts received within the application, amounts funded via credit card, funds transferred from Alyf to a bank account, and funds withdrawn from an ATM. The transaction history, including sender/recipient names, times, dates, and amounts, is stored and accessible to users.

• Geolocation Information: Alyf may collect location information determined by data such as IP address or GPS of the mobile phone to provide a better user experience and enhance security (geolocation can, for example, serve as a control in case of suspected fraud). Most mobile phones allow users to control or disable location services in applications through the device settings menu. Note that your city and region can be inferred based on the IP address.

• Contacts Using Alyf: Users can link their contact directories to the application to see which of their contacts use Alyf. To link a contact from the user's address book to a newly registered user on the application, Alyf needs to collect phone numbers and email addresses from the user's address book. Alyf only requires a fingerprint of this data and not the raw data. Therefore, this information is transmitted and stored encrypted, using a one-way public key. This feature can be disabled by the user from the application's "settings" screen.

• Communications with Alyf Support: Alyf retains the history of communications that the user may have had with Alyf's support or customer service, such as email exchanges.

• Tracking of Actions by Alyf Employees: Alyf employees may be involved in managing an Account, and comments on these operations may be retained.

2.2 Information provided by Users

During registration, Alyf collects the following information directly from Users:

• Name (Required)
• First Name (Required)
• Phone Number (Required)
• Residential Address (Required for level 2 and above)
• Date of Birth (Required)
• Email Address (Optional)
• Gender / Sex (Required)

We use this data for marketing studies and targeted promotional campaigns within Alyf. We are committed to ensuring the protection of your personal data in accordance with our privacy policy. Your information is handled with utmost care and is only used in the provision of our services.

Your Benefits

Once your account is verified, you will enjoy:

• Enhanced protection of your personal data
• Personalized services and offers
• Priority access to our customer service

If you contact us through the designated form in the application for any complaints, we may collect data to identify you, such as your name, first name, or residential address. We will use this information to process your request.

We will retain your personal data for as long as you are registered on Alyf. If you choose to unsubscribe from Alyf, your data will be deleted one year after deactivating your account.

You can withdraw your consent for further storage and processing of your data at any time. Any processing of your data before your withdrawal will not be affected and will be covered by your prior consent.

Specific Case of National Identity Card (CIN): When upgrading to a Level 2 account (N2, as described in the "Terms and Conditions"), the User is required to share a photo of their CIN and a photo of themselves as "proof of life." Alyf utilizes technology developed by a third party, "Indatacore," which has provided its SDK for these operations. The CIN data will be processed by Lana Cash and Alyf teams for the purpose of customer relationship management.

2.3 Banking data

IBAN / Bank Card Details: These details are necessary for transferring funds to a bank account or for funding your Alyf account via credit card. All credit card funding operations for your Alyf account are managed by our partner, the Centre Monétique Interbancaire (CMI). Alyf only receives transaction success or failure data. However, Alyf must retain the IBAN and account holder's name for fund transfers from your Alyf account to your bank account.

Regarding funding your Alyf account via credit card, Alyf does not directly collect card information. This process is handled by our partners CMI, Lanacash, and CIH. The card transactions are processed through CMI, ensuring the security and confidentiality of your banking data.

3. Use of Information

3.1. Purposes of Processing

The information we collect is used for the following purposes:

• Providing our services: Processing transactions, managing User accounts, responding to support requests, and improving the functionality of the Application.
• Improving our services: Analyzing the usage of our Application to better understand User needs, developing new features and services, and enhancing the User experience.
• Securing our services: Detecting and preventing fraudulent activities, protecting the security of our systems and User information.
• Communicating with you: Sending important notifications, updates on your transactions, information about our services, promotions, and special offers, subject to your consent.

3.2. Legal Basis of Processing

We process your personal data on the following legal bases:

• Contractual Necessity: The collection and processing of your personal data are necessary for the performance of our contract with you.
• Legitimate Interest: We may process your personal data to serve our legitimate interests, such as improving our services, securing our Application, and preventing fraud.
• Consent: Where required by law, we collect your consent before processing your personal data.

4. Sharing of Information

4.1. Sharing with Third Parties

We may share your personal data with:

• Our Partners: Mievic, Celio, and the Fédération Royale Marocaine des Jeux Électroniques (FRMJE). If you subscribe to a loyalty program specific to any of these partners, it will be governed by specific Terms of Use (CGU) for each partner.
• Our Subcontractors: Who process data on our behalf according to our instructions and in compliance with this Policy.
• Competent Authorities: When required by law or to protect our rights and interests.

5. Data Security

We take appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. However, no method of transmission or electronic storage is completely secure, and we cannot guarantee the absolute security of your information.

6. Your Rights

You have certain rights regarding your personal data, including:

• Access: You have the right to request access to your personal data that we hold.
• Rectification: You can request the correction of your inaccurate or incomplete personal data.
• Deletion: You can request the deletion of your personal data, subject to certain conditions.
• Objection: You can object to the processing of your personal data in certain circumstances.
• Portability: You can request the portability of your personal data in a structured, commonly used, and machine-readable format.

To exercise your rights, you can contact us at the following address: support@paymob.ma

7. Modifications to the Privacy Policy

We may update this Privacy Policy from time to time. We will inform you of any substantial changes by posting the new Policy on our Application and updating the "Last Updated" date at the top of this page. We encourage you to check this page regularly to stay informed about our data protection practices.

8. Contact

For any questions regarding this Privacy Policy or our data protection practices, please contact us at:

Paymob, 259 Lotissement Lina, 1st Floor, Sidi Maarouf, Casablanca, or by email at support@paymob.ma