Privacy Notice

Effective Date: February 1, 2021
Posted Date: February 1, 2021

We’ve included annotations in these gray boxes as a guide to our notices. Annotations aren’t part of the notices and have no legal effect, but they should help you follow the text.

If you are a XPay customer, this privacy notice applies to you. It explains what data we collect about you, what we do with it, when and why we share it with others, how long we keep it, how we secure it, what cookies are and what they (and similar technologies) do, what data is collected about you by third party service providers, and what choices you have to control your data.

By using XPay you consent to these data practices.

This Privacy Notice describes how XPay collect, use, disclose, transfer, store, retain or otherwise process your information when you (“you,” “your”) download XPay through a relevant app store and sign up for a XPay account and other services through the app or online at https://XPay.app/ (collectively, “Services”).

This Privacy Notice applies to your use of our Services, and covers only information collected in connection with your access to and use of our Services. Please read this Privacy Notice carefully. By continuing to interact with our Services, you are consenting to the practices described in this Privacy Notice.

INFORMATION WE COLLECT ABOUT YOU

We use your data to make XPay’s products and services work better for you and for others. This describes what data we get about you (which can vary depending on where you live).

We need to collect information about you to provide you with the Services or the support you request. Specifically, we collect (and/or have collected during at least the 12-month period preceding the effective date of this Privacy Notice) the categories of personal information described below. Additionally, you can choose to voluntarily provide information to us.

Information You Provide to Access our Services

We use data you put into our systems when you use XPay, like financial information, information that identifies who you are, transaction information, and any other data you give us.

We collect information you provide when you apply or sign up for a XPay account, go through our identity or account verification process, authenticate into your account, communicate with us, answer our surveys, participate in contests or promotions offered by us or our partners, or otherwise use our Services.

We collect the following categories of information about you when you use our Services, including:

Identification Information.such as: Your name, email address, zip code, phone number, XPay username, signature, and authentication credentials (for example, information you use to log in to your XPay account), including Internet Protocol (“IP”) address.
Additional Identification Information for Verified Users.such as: Your full mailing address; date of birth; government-issued identification, including Social Security number, passport, or driver’s license;
Financial Information.such as: Bank account and payment card numbers you add to your XPay account, as well as your XPay Card number if you have one.
Contacts Information.In order to provide you with the Service, we will also need to collect information from you about the intended recipient of the payment you request us to make. We will therefore ask you to provide contact details of your intended recipient. You can do this by: (a) manually entering a phone number or email address into XPay; or (b) as described below (under Information You Provide to Enhance Your Experience), you can choose to give us access to your phone contacts to facilitate the entry of recipient information. We may also ask you to provide limited access to your phone contacts for account verification purposes. You can update your settings to stop sharing your phone contacts with us at any time, although we will always need a recipient’s phone number or email address to send money to them as requested by you.
Transaction Information.When you use our Services to make, accept, or request payments, we collect information such as: when and where the transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer amounts, and the devices and payment methods used to complete the transactions.

Information You Provide to Enhance Your Experience

We also use data you give us to make your experience with XPay better, like contacts you choose to upload to make it easier for you to exchange money with them.

You can choose to provide us with additional information to improve your user experience when using our Services:

Contacts Information.If you choose to give us access to your phone contacts, we collect the telephone numbers of all your phone contacts to facilitate the entry of payment recipient information. You can update your settings to share your phone contacts with us at any time, although we will always need a recipient’s phone or email address to send money to them as requested by you. 
Other Information You Provide.We collect information that you voluntarily provide to us, including your photograph, if you choose to upload a picture to the Services; survey responses; participation in contests, or other prospective marketing forms or devices; suggestions for improvements; referrals; or any other actions you perform on the Services.

Information We Collect From Your Use of our Services

We also get data from the devices you use when you interact with our systems, like your location and information about the device you’re using. We need this data to do things like help protect your account from hackers, combat fraud, check if payments are being made or received legally and by you, and making our products and services better for you and others.

We collect information about you and the devices you use to access the Services, such as your computer, mobile phone, or tablet. The information that we collect includes:

Geolocation Information.The location of your device, including your IP address, device language, and location of your network provider. For more information and to learn how to disable collection of location information from your mobile device, please see below.
Device Information.Information about your device, including your hardware model, operating system and version, device name, unique device identifier, mobile network information, and information about the device’s interaction with our Services. If you use an iOS device, we also automatically detect if you have downloaded Chrome, so we can ask you which browser you prefer to use to open links from your XPay application.
Internet or other electronic network activity information.Information about how you use and interact with our Services, including your access time, “log-in” and “log-out” information, browser type and language, country and language setting on your device, IP address, the domain name of your internet service provider, other attributes about your browser, mobile device and operating system, any specific page you visit on our platform, content you view, features you use, the date and time of your use of the Services, your search terms, and the website you visited before you visited or used the Services.
Inferencesdrawn from any of the information we collect to create a profile about you that may reflect, for example, your preferences, characteristics, and behavior, including for account security purposes or to enhance our Services to you.

SOURCES OF INFORMATION WE COLLECT ABOUT YOU

We also need to check that you are using our services legally, that you are eligible for the services you want to use, and we protect your data and our services from fraudsters who may put you and your money at risk. To do this, we may collect data about you from companies that help us verify your identity, do a credit check, prevent fraud or assess risk.

We collect (and/or have collected during at least the 12-month period preceding the effective date of this Privacy Notice) information about you from the following categories of sources:

You directly, when you submit information to us or allow us to access information
Your devices and how you interact with our Services
Our group companies or affiliates
Other sources, including:
Identity Verification.Information from third-party verification services (e.g., identity verification agencies and through companies which provide third party analytics (see “Third-Party Analytics” below)), and publicly available sources. In some circumstances, where lawful, this information can include your government-issued identification number.
Credit, Compliance, and Fraud.Information about you from third parties for any credit investigation, credit eligibility, identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law. This includes, without limitation, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment, financial institutions, and personal reporting agencies.

HOW WE USE YOUR INFORMATION

We use your data to do things like make sure the products you are using work, help you log in to your account, verify who you are, secure your data, fight fraud, follow the law, enforce our agreements, figure out what new products we can build, and market and tailor our products to you.

We may collect, use and share (or have collected, used or shared during at least the 12-month period preceding the effective date of this Privacy Notice), information about you for the following reasons:

Providing, Improving, and Developing our Services

Determining whether the Services are available in your country;
Processing or recording payment transactions or money transfers;
Providing you with XPay products and features you choose to use;
Displaying your historical transaction information;
Connecting you with people you already know;
Providing, maintaining and improving our Services;
Developing new products and services;
Delivering the information and support you request through the use of our Services;
Improving, personalizing and facilitating your use of our Services, content and applications;
Measuring, tracking and analyzing trends and usage in connection with your use or the performance of our Services; and
Otherwise providing you with the products and features you choose to use.

Communicating with You About our Services

Sending you surveys and getting your feedback about our Services; and
Sending you information we think you may find useful or which you have requested from us about our products and services.

Protecting our Services and Maintaining a Trusted Environment

Conducting investigations, complying with and enforcing any applicable laws, regulations, legal requirements, and industry standards, and responding to lawful requests for information from the government or to valid legal process;
Contacting you to resolve disputes, collect fees and help you with our Services;
Debugging to identify and fix errors that impair how our Services function;
Making sure you follow our Terms of Service or other applicable agreements or policies;
Investigating, detecting, preventing, recovering from, or reporting fraud, misrepresentations, security breaches or incidents, other potentially prohibited, malicious, or illegal activities, or to otherwise help protect your account, including to dispute chargebacks on your behalf;
Protecting your, our, or our other customers’ rights or property, or the security or integrity of our Services;
Verifying or maintaining the quality and safety of our Services; and
Verifying your identity (e.g., through government-issued identification numbers).

Advertising and Marketing

Marketing our Services to you; and
Communicating with you about opportunities, products, services, contests, promotions, discounts, incentives, surveys, and rewards offered by us and select partners.

If we send you marketing emails, each email will have instructions on how you can “opt out” of getting future marketing from us.

Other Uses

For any other reason we may tell you about from time to time.

WHEN AND WITH WHOM WE SHARE YOUR INFORMATION

We share your information with others in the circumstances described in this section. For example, with other people with whom you interact when you use our services; who may offer services that we think could be useful to you; with service providers who help us run our services; or if we need to share your information to comply with the law.

We may share the information described in the “Information We Collect About You” section with the following categories of service providers and third parties:

With Other Users of our Services with Whom You Interact

With other users of our Services with whom you interact through your own use of our Services. For example, we may share information with the person(s) with whom you transact when you make or accept a payment or money transfer using our Services. This helps them know they’re getting money from you (or that you requested a payment from them).

With our Service Providers

With service providers who help us provide, maintain, and improve our Services (e.g., vendors who help us with fraud prevention, identity verification, and fee collection services), as well as financial institutions, payment networks, payment card associations, credit bureaus, carrying brokers, and other entities in connection with your payment, money transfer process, investing activity, or otherwise to help us provide the Services;
With service providers that help us run our advertising campaigns, contests, special offers, or other events or activities.

Business Transfers and Corporate Changes

To a subsequent owner, co-owner, or operator of one or more of the Services; or
If we do or try to do a corporate merger, consolidation, or restructuring (including during due diligence and negotiation of these); the sale of substantially all of our stock and/or assets; the financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change.

Safety and Compliance with Law

If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from creditors, tax authorities, law enforcement agencies, in response to a garnishment, levy, or lien notice, etc.); (ii) to establish, exercise or defend our legal rights; (iii) to enforce or comply with our General Terms or other applicable agreements or policies; (iv) to protect our or our customers’ rights or property, or the security or integrity of our Services; (v) for an investigation of suspected or actual illegal activity; or (vi) to protect us, users of our Services or the public from harm, fraud, or potentially prohibited or illegal activities.

With Your Consent

With your consent. For example:
- At your direction or as described at the time you agree to share;
- When you authorize a third party application or website to access your information.

With Others

With other companies who deliver services on our behalf, including via the use of cookies and similar automated technologies, and third party analytics.

Aggregated and Anonymized Information

We also may share (with service providers or other third parties) aggregated and anonymized information that does not specifically identify you or any individual user of our Services.

COOKIES AND OTHER SIMILAR AUTOMATED TECHNOLOGIES

Digital cookies and similar technologies help us make our services better to use by doing things like recognizing when you’ve signed in, analyzing how you use our services so we can make them more useful to you, giving you a more personalized experience, and making our ads to you work better.

When you interact with our online services, or open emails we send you, we obtain certain information using automated technologies, such as cookies, web server logs, web beacons, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag, or clear GIF, is a tiny graphic image that may be used in our websites or emails.

We use these automated technologies to collect your device information, internet activity information, and inferences as described above. These technologies help us to:

Remember your information so you do not have to re-enter it;
Track and understand how you use and interact with our online services and emails;
Tailor our online services to your preferences;
Measure how useful and effective our services and communications are to you; and
Otherwise manage and enhance our products and services.

We set some of these automated technologies ourselves, but others are set by third parties who deliver services on our behalf. For example, we may use other companies’ web analytics services (described in the “Third-Party Analytics Services” section), which use automated technologies to help us evaluate how customers use of our websites.

Your browser can alert you when cookies are placed on your device, and how you can stop or disable them via your browser settings. Please note, however, that without cookies all of the features of our online services may not work properly. If you use a mobile device, you can manage how your device and browser share certain device data by changing the privacy and security settings on your mobile device. You can learn more about cookies and how to manage your preferences by visiting http://www.allaboutcookies.org.

THIRD-PARTY ANALYTICS SERVICES

We use other companies as service providers to help us analyze our site, and track metrics. These service providers generally promised us under contract to keep data private but have their own privacy policies that you should be aware of.

We may use third-party analytics service providers to help us with our online services, such as Google Analytics, Adjust, Facebook Analytics, Firebase Analytics, Amplitude, Mixpanel and Crashlytics. The analytics providers that administer these services use technologies such as cookies, web beacons, and web server logs to help us analyze how you use our online services. We may disclose your site-use information (including IP address) to these analytics providers, and other service providers who use the information to help us figure out how you and others use our online services.

To learn more about Google Analytics and how to opt out, please visit https://marketingplatform.google.com/about/ or https://support.google.com/analytics/answer/181881?hl=en. 
To learn more about Adjust, please visit https://www.adjust.com/terms/privacy-policy/.
To learn more about Facebook Analytics, please visit https://www.facebook.com/policy.php.
To learn more about Firebase Analytics, please visit https://firebase.google.com/support/privacy.
To learn more about Amplitude, please visit https://amplitude.com/amplitude-security-and-privacy.
To learn more about Mixpanel, please visit https://mixpanel.com/legal/privacy-policy/.
To learn more about Crashlytics, please visit https://fabric.io/terms.

HOW LONG WE KEEP YOUR INFORMATION

We keep your information as long as you keep using our products and services. After that, we keep it for as long as we need it to do things like fight fraud, collect fees you owe, resolve disputes with (or involving) you, follow the law, enforce our agreements and defend our rights in court.

We generally keep your information as long as reasonably necessary to provide you the Services or to comply with applicable law. However, even after you deactivate your account, we can retain copies of information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our General Terms or other applicable agreements or policies, or to take any other actions consistent with applicable law.

YOUR CHOICES

You can see, change or fix information you gave us, ask us to deactivate your account, control your location information, or tell us to stop marketing to you by opting out.   

Personal Information

You can access, change, or correct information that you have provided by logging into your XPay account at any time or by making a request to us using the contact details below. We will need to verify your identity before granting access or otherwise changing or correcting your information.

Deactivating Your Account

If you wish to deactivate your account, you can do so at any time by logging into your XPay account

If you would like to have your account closed permanently, please contact customer support through XPay application.

Location Information

In order to provide certain Services, we may require access to location information, including precise geolocation information collected from your device. If you do not consent to collection of this information, certain Services will not function properly and you will not be able to use those Services. You can stop our collection of location information at any time by changing the preferences on your mobile device. If you do so, some of our mobile applications will no longer function. You also may stop our collection of location information via mobile application by following the standard uninstall process to remove XPay mobile applications from your device.

Do Not Track

Certain web browsers allow you to instruct your browser to respond to Do Not Track (“DNT”) signals to website you visit, informing those sites that you do not want your online activities to be tracked. At this time, our websites are not designed to respond to DNT signals or similar mechanisms from browsers.

Promotional Communications

You can opt out of receiving in-app push notifications containing promotional messages from us by following the instructions on screen or by following the instructions in those messages. If you decide to opt out, we may still send you non-promotional communications in-app, or via email and text, such as transaction receipts and messages about your account, or our processing of your information in accordance with the provision of our Services.

Right of Deletion

You have the right to ask us to delete the personal information we have collected from you (subject to exceptions the law provides). Please note that you may no longer be able to use our Services if you delete your personal information.

Right of Non-Discrimination

You have the right to not be discriminated against if you exercise these privacy rights. We will not discriminate against you, deny, charge different prices for, or provide a different quality of goods or services if you choose to exercise these rights.

How to Exercise Your Rights

To help protect your privacy and maintain security, we take steps to verify your identity and will require you to be logged in to your XPay account before granting you access to your personal information or complying with your request.

You may designate an authorized agent to make a request on your behalf as permitted under law, though before we process that request, we will require that you provide the authorized agent written permission to do so and verify your identity directly with us.

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

CHILDREN’S PERSONAL INFORMATION

If you are a kid under 16, please don’t use our services. If we collect your data and later learn you are a kid under 16, we will delete it.

Our Services are general audience services not directed at children under the age of 16. If we learn that any information we collect has been provided by a child under the age of 16, we will promptly delete that information.

HOW WE SECURE INFORMATION

We do a lot to keep your data safe. While we think we have strong defenses in place, no one can ever guarantee that hackers won’t be able to break into our sites or steal your data while it is stored or flowing from you to us or vice versa.

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, and misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, the internet is not a 100% secure environment, and we cannot guarantee absolute security of the transmission or storage of your information. We hold information about you both at our own premises and with the assistance of third-party service providers.

STORAGE AND PROCESSING

We operate in many countries, and we (or our service providers) may move your data and process it outside the country where you live.

We may, and we may use third-party service providers to, process and store your information outside the country where you live.

CHANGES TO THIS PRIVACY NOTICE

We can change this privacy notice. When the changes impact your rights or how we use your data in important ways, we’ll tell you first by email (if you’ve given us your email address).

We may amend this Privacy Notice from time to time by posting a revised version and updating the “Effective Date” above. The revised version will be effective on the “Effective Date” listed. We will provide you with reasonable prior notice of material changes in how we use your information, including by email, if you have provided one. If you disagree with these changes, you may cancel your account at any time. If you keep using our Services, you consent to any amendment of this Privacy Notice.

HOW TO CONTACT US

You can contact our privacy team with any questions or concerns at the address below.

Please contact our privacy team with any questions or concerns regarding this Privacy Notice: Greek Campus, Tahrir, Cairo, Egypt.

If you have any questions or concerns regarding our privacy notice, or if you believe our privacy notice or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with our privacy team listed above. We will respond to let you know when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution.

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