ZApp

PRIVACY POLICY

Overview and the application of this Privacy Policy

Zahra App (ZApp) is a Super Mobile Application offering financial technology Services (fintech) and eCommerce Trading Platform. As a company, we are compliant to the laws and regulation of the Gambia, The Gambia Information and Communication Technology Act, 2019 and all treaties related to the data protection of our clientele.

When you use ZApp, you entrust us with your personal data. We care about your privacy and we are committed to keeping that trust by helping you understand our privacy practices. This Privacy Policy describes the personal data we collect when you use our applications and other services. Your data usage and sharing as well as your legal rights regarding your personal data protection.

This Privacy Notice applies to all users of our services including but not limited to:

Customers who use ZApp to send or receive money

Agents who provide services to customers

Merchants and other clients who accept payment using ZApp etc.

All individuals subject to this Privacy Policy are referred to as “users” in this Privacy Policy.

WHAT PERSONAL DATA DO WE COLLECT AND HOW DO WE COLLECT IT

We may collect Personal Data in these forms:

When you give it to us voluntarily including when you indicate that you would like to receive any of our Services

When you register with us

When you complete our forms online

When you speak to us over the telephone

When you speak to us in person

When you write to us via email or any other means and when you visit the Website

We will also collect details of transactions you carry out through the Website or the mobile App.

The types of Personal Data we collect will depend on the products or services you have requested from us. Any Personal Data collected is necessary for us to perform a contract and without such data we may not provide the desired Services.

We may collect and process the following Personal Data:

Personal details, such as data which may identify you and/or the beneficiary of your transaction with us. This may include name, title, residential and/or business address, email, telephone and/or fax numbers and other contact data, date of birth, sex, images, signature, I.D Card/passport/visa details;

Financial details, such as data relating to you and your beneficiary's payment data and bank account obtained for the purposes of money transfers;

and/or

Additional details requested by law enforcement or requested pursuant to our compliance procedures in connection with efforts to prevent money laundering, terrorist financing and criminal activity, such as relationship to the beneficiary of the transaction, the purpose of the transaction and proof of funds.

WHAT PERSONAL DATA DO WE COLLECT AND HOW DO WE COLLECT IT

We may collect Personal Data in these forms:

When you give it to us voluntarily including when you indicate that you would like to receive any of our Services

When you register with us

When you complete our forms online

When you speak to us over the telephone

When you speak to us in person

When you write to us via email or any other means and when you visit the Website

We will also collect details of transactions you carry out through the Website or the mobile App

We may collect and process the following Personal Data:

Financial details, such as data relating to you and your beneficiary's payment data and bank account obtained for the purposes of money transfers; and/or

COOKIES AND SIMILAR TECHNOLOGIES

When you use our website or mobile apps we collect information via cookies and similar technologies, including the IP address of visitors, browser type and version, time zone setting, screen resolution settings, browser plug-in types and versions, operating system and platform. We may use this data for the following purposes:

To measure the use of our Website and Services, including number of visits, average time spent on a website, pages viewed, page interaction data (such as scrolling, clicks, and mouse-overs) etc., and to improve the content we offer;

To administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and

As part of our efforts to keep the Website safe and secure;

Due to their core role of enhancing or enabling usability or site processes, disabling cookies may prevent you from using certain parts of our website. It will also mean that some features on our Website will not function if you do not allow cookies.

HOW WE USE PERSONAL DATA

ZApp uses personal data in order to provide and continually improve our services, and for sales and marketing purposes among other things as explained below:

To provide our services: We use data to provide, personalize and maintain our services. This includes using data to: create/update accounts; process payments and receipts of e-money; facilitate invoicing; troubleshoot software bugs and operational problems; and perform other operations necessary to maintaining our services.

Research and development: We may use personal data for ZApp internal testing, research, analysis, product development, and machine learning to improve the user experience.

User support: We use the personal data that we collect from users (which may include call recordings) to provide service support, including to investigate and address user concerns and to monitor and improve our support responses and processes.

Marketing communications: We may use personal data to market our services and our partner services to users. This includes sending users communications about services, features, promotions, studies, surveys, news, updates, and events. We may do so through various methods, including email, text messages, push notifications, in-app communications and ads, as well as ads on third party platforms. ZApp does not sell user personal data to third parties for their direct marketing, except with users' consent.

Transactional communications: We may use personal data to generate and provide users with receipts; inform them of changes to our terms, services, or policies; or send other communications that are necessary for the effective delivery of services.

Fraud prevention and compliance with law: We use personal data to prevent, detect and investigate fraud; and comply with applicable laws, regulations, and operating licenses.

Claims, disputes and legal proceedings: We may use personal data to investigate or address claims or disputes relating to use of our services, including in the context of legal proceedings.

WHO WE SHARE PERSONAL DATA WITH

ZApp services, operations, business transactions and legal obligations, may require that we share personal data with other users or third parties.

ZApp may share personal data with the following third parties:

Other users: We share personal data, including customer telephone number and names (redacted where possible), with other users when sending or receiving e-money or issuing statements containing information such as transaction history.

ZApp subsidiaries and affiliates: We share personal data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf.

Marketing Service Providers: We share personal data (including usage data and device data) with marketing agencies, research partners, social media and marketing platform providers, advertising networks and third-party data providers to reach or better understand our users, target advertising and measure advertising effectiveness.

Other vendors and business partners: We share personal data (including usage and device data) with vendors, consultants, and other service providers or business partners who we engage to perform certain functions on our behalf. These may include: payment processors and facilitators; background check and identity verification providers; cloud storage providers; software and digital security providers; insurance and financing partners; and professional service providers including consultants, lawyers, accountants.

The general public: Questions or comments from users submitted through public forums such as ZApp blogs and ZApp social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

Law enforcement and other government authorities: We may share personal data with law enforcement or other government authorities if we are issued with the appropriate lawful mandate and if the form and scope of the demand is compliant with the law.

The judiciary: We may share personal data with lawyers, the judiciary and other third parties for the purpose of enforcing ZApp terms and conditions, agreements, codes, policies and guidelines; or to protect ZApp’s rights or property or the rights, or property of others; or in the event of a claim or dispute relating to the use of our services.

Business transfers and transactions: As we continue to develop our business, we might restructure, refinance, merge or sell (all or parts of) our business or services. In connection with, or during negotiations of, such transfers and transactions, user personal data may be transferred, together with other business assets.

In the event of transfers of personal data to third parties, we shall require them to agree to measures necessary to protect the data, and continue to respect users legal rights pursuant to the terms of this Privacy and applicable laws in the user location.

INTERNATIONAL DATA TRANSFERS

We may transfer personal data internationally, where this is permissible pursuant to applicable laws in the user’s location.

In the event of international transfers of personal data, we shall put in place measures necessary to protect the data, and we shall continue to respect the user’s rights pursuant to the terms of this Privacy Policy and applicable laws in the user’s location.

DATA SECURITY

We have put in place appropriate security measures to prevent personal data from being accidentally lost, disclosed or used in an unauthorised way.

In addition, we limit access to personal data to those employees, contractors and other third parties who have a business need to know. They will only process personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify users and any applicable regulator of a breach where we are legally required to do so.

YOUR LEGAL RIGHTS (USER)

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to access, correct or erase your personal data, object to or restrict processing of your personal data, and unsubscribe from our emails and newsletters.

Users may exercise these rights at any time by writing to us at email: zapp@zappme.net

Compliant to the Anti Money Laundering Act, 2012 and other Related Laws, following an account deletion request, ZApp deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute.

ZApp retains user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data, the category of user to whom the data relates, and the purposes for which we collected the data.

CHANGES

We may occasionally update this Privacy Policy. We will notify you in advance of the changes through ZAPP Appilication or other means, such as email. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.

YOUR CONSENT

By using ZAPP, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. “Processing,” means using cookies on a computer/handheld device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information.

CONTACT US

If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at zapp@zappme.net

To measure the use of our Website and Services, including number of visits, average time spent on a Website, pages viewed, page interaction data (such as scrolling, clicks, and mouse-overs) etc., and to improve the content we offer;

To administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and

As part of our efforts to keep the Website safe and secure;