Politique de confidentialité

1.Introduction

This Privacy Policy explains what you can expect from us and what we need from you in relation to your personal data.

KOYA Send SAS offer a software platform and services to help individuals send in DR Congo or abroad. We collect data about our customers and their payees (“Data”) when they use our platform, our services, and our websites (collectively, “Services”). This privacy policy describes how we collect, use and disclose Data.

In this privacy policy, we sometimes refer to “You”. “You” may be a Visitor to one of our websites, a customer of one or more of our Services (“Customer”), or a payor / payee of a Customer (“Payee”). This policy does not apply to third-party websites, products, or services even if they link to our Services, and you should consider the privacy practices of those third-parties carefully. If you object to the practices described in this policy, you should (a) remove cookies from Your computer after leaving our website, and (b) discontinue your use of our Services.

We may change this Privacy Policy from time to time. We will post any changes, and such changes will become effective when they are posted. Your continued use of our Services following the posting of any changes will mean you accept those changes. We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.

2.How we handle your data

We receive Data from Visitors to our website, and Customers using our Services. The collection and use of data is crucial to providing our Services and keeping the Services safe. Data helps us increase the safety of your online payments, while reducing the risk of fraud, money laundering and other harmful activity. Generally, Data can be categorized into data that directly identifies you individually (“Personal Information”) and data associated with your activities (“Activity Information”).

All information you provide to us is stored on secure servers. You are responsible for keeping confidential any passwords we give you. We ask you not to share this password with anyone else and not to use this password for other services or products.

3.Collecting Personal Information

You may have to provide us with Personal Information to sign up for, or make use of, our Services. This data includes the following, for yourself and your recipient:

Name

Address

Date of birth

Place of birth

Email address

Demographic information (e.g. gender)

Phone number

Evidence of your identity (for example, passport information)

Financial information (including credit card, debit card, or bank account information)

Payment reason

Geographical location

Government ID number

Personal description

Photograph

IP address

Device ID

Device settings (e.g., language preference, time zone)

We may collect Personal Information about you from other sources. For example, we may:

Retrieve names associated with particular phone numbers from our payment service providers; and

Verify your identity against third party databases for anti-money laundering and fraud purposes

4.Collecting Activity Information

We also automatically collect Activity Information based on your use of our Services. This data would include your activities on our website, or actions performed on our payment platform. For example, we may collect:

Details of the transactions you carry out when using our Services, including geographic location from which the transaction originates;

Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

Information about your visit, including the full URL clickstream to, through and from our Website or App (including date and time); page response times, download errors, length of visits to certain pages, page interaction information, methods used to browse away from the page; and

Any phone number used to call our customer support center, as well as a recording of that call. By continuing to speak to a customer support agent after calling our customer support center, you are agreeing to our collection of this data.

Our Website also uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you use our Website and also allows us to improve our Website. By continuing to use our Website, you are agreeing to our use of cookies.

Personal Information and Activity Information we collect is stored in compliance with our various regulatory obligations for anti-money laundering and fraud purposes.

5.Data use

When you sign up to effectuate payments through our Service, you enter into a contract with us to make these payments on your behalf. We must process your Data to fulfil this contract.

Further, we are required by law to collect, process, and retain your Data, in fulfilment of our anti-money laundering regulatory obligations. We use your Data in the following ways:

Carry out our obligations relating to your contracts with us and to provide you with the information, products and services that you request from us;

Provide, maintain, personalize, optimize, and improve the Services, including research and analytics regarding use of the Services, or to remember you when you leave and return to the Services;

Provide and improve our products and services;

Provide you with more relevant content in marketing, promotional or other communications to which you may be subscribed;

Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.

We may combine information from the Services together and with other information we obtain from our business records or from third party sources.

KOYA Send SAS will only use your Data for marketing and promotional purposes if you "opt in" to such uses, and you can withdraw this permission at any time. You have the right to ask us not to contact you for marketing purposes by contacting us at [email protected].

As a regulated financial institution, we are required by law to store some of your Data beyond the termination of your relationship with us. After such time, your Data will only be accessed or processed if absolutely necessary. We will always delete Data that is no longer required by relevant legislation.

We may share Data to ensure that we can continue providing you with the Services you have contracted.

KOYA Send SAS may share your Personal Information and Activity Information with:

KOYA Send SAS Service Providers. We share Data with service providers who help us provide the Services. Service providers help us with things like payment processing (i.e., banks, mobile network operators), website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing;

Authorized Financial Institution(s). We share Data with the financial institution that holds the account you have designated for the sending or receiving transaction. By requesting a payment, you are consenting to sharing of Data by and between both KOYA Send SAS and the relevant Financial Institution(s) as necessary for the provision of payment services.

Safety, Legal Purposes and Law Enforcement. We use and disclose Data as we believe necessary: (i) under applicable law, or payment method rules; (ii) to enforce our terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

KOYA Send SAS may share only Activity Information (and not Personal Information) with:

Advertisers and advertising networks solely to select and serve relevant adverts to you and others; and

Analytics and search engine providers that assist us in the improvement and optimisation of our site.

7.How We Protect Your Data

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using Transport Layer Security technology. We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. If you feel your interaction with us is no longer secure (e.g., you believe your log in or other security credentials have been compromised), please contact us immediately

8.Our Partners

Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.

9.Changes to this Policy

Any changes we may make to our Privacy Policy will be posted on this page and, where appropriate, notified to you by e-mail or in the App. Please check back frequently to see any updates or changes to our privacy policy.

If you have any questions about this Privacy Policy, please email us at [email protected]