1.MODIFICATION OF THE PRIVICY POLICY

We may modify this Privacy Policy at any time. If we make any changes and post the new Private Policy on the Platform, the new Privacy Policy will be effective immediately. You agree that any information we hold about yours (as described in this Privacy Policy and whether or not collected prior to or after the new Privacy Policy became effective) will be governed by the latest version of the Privacy Policy. You can determine when this Privacy Policy was last revised by referring to the “Effective Date” above.

2.INCLUDING INFORMATION

We may collect the following categories of personal information from and about you, you understand that information we collect may various according to certain productions you choose from our services, and we commit that the personal information we collect from you shall be limited to minimum requirements for providing services to you and in case of terminating the relation between Opay and the customer all data will be deleted:

Identifiers:

such as your name, postal addresses, email addresses, social networking website user account names, or other addresses at which you are able to receive communications.

Demographic information:

such as your age, birth date, and gender.

Commercial information:

his information may include records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Commercial information may also include information about the utilities you use, rewards and points-based incentive programs, program membership information, and information about your mobile device and carrier.

Audio, Visual, and Electronic Information:

Due to the character verification we will need a personal photo, please upload a clear personal photo or take a photo during activating your account on the mobile application we can also collect any other communications between you and us.

Internet and network activity information:

such as information about your browsing behavior, search history, and interactions with websites and advertisements, including data from cookies, pixel tags, and web beacons.

Inferences regarding preferences and other characteristics:

such as our assessment of the types of products or services you may have an interest in.

3.COLLECTION OF INFORMATION

We may collect personal information about you from a variety of sources, including:

From you:

We collect information that you submit to us. We will collect any information you voluntarily provide, and we may also request optional information to support your use of the Services. We also collect any information that you voluntarily enter into any postings, comments, or forums within the Platform.

From your device:

When you use the Platform, we may collect information about the devices you use to access the Platform, including hardware model, operating system and version, Internet Protocol (“IP”) address, and other unique device identifiers, mobile network information, and information about the device’s interaction with our Platform. We also collect information about how you use our Platform, including your access times, browser types, and language. Note that this Privacy Policy covers only how we use information collected via cookies; it does not cover the use of such information by third parties.

Location information:

We may collect different types of information about your location after approving the access to the location from the internal settings of the device, including general information, such as the city, state, and/or zip code associated with your IP Address, and, if you agree, more specific location information that is provided through the GPS functionality on mobile devices used to access the Platform. You may be able to disallow our use of certain location data through your device or browser settings, for example, by disabling “Location” services for our application in iOS privacy settings.

Social media networks and other third parties:

We may obtain information about you or your use of the Platform from third party sources, such as our vendors, like web hosting providers, analytics providers, or advertisers. When you access the Platform through social media networks,other third party platforms and choosing to register using your account and data through the platforms of any third party, you are authorizing us to collect, store, and use such information and content in accordance with this Privacy Policy. Please keep in mind that any information provided to us by a third party may also be subject to that third party’s privacy policy.

4.USE OF PERSONAL INFORMATION

We may use information collected as described in this Privacy Policy to:

Operate, maintain, and improve the Platform and other programs, features, and functionality related to the Platform;

Provide you with interest-based ads, push notifications, communications, and offers for services from us and our business partners, including based on your precise geolocation;

Process your services application, facilitating transactions, for verification purposes, regulatory requirements；

Evaluate your eligibility for certain types of offers, products, or services that may be of interest to you, and analyze advertising effectiveness;

Answer your questions and respond to your requests;

Perform analytics and conduct customer research;

Communicate and provide additional information that may be of interest to you about us and our business partners, sometimes by combining your information with information we obtain from other sources;

Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, marketing messages, and requested information, including on behalf of our business partners;

Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored by us or our business partners;

Manage our everyday business needs, such as administration of the Platform, forum management, fulfillment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and Terms of Use, or to comply with the law, including but not limited to Know Your Customer, Anti-Money Laundering, Anti-Fraud requirements;

Verify your requests made pursuant to this Privacy Policy;

Enhance other information we have about you to help us better understand you and determine your interests.

We also may use information collected as described in this Privacy Policy with your consent or as otherwise required or permitted by law.

5.DISCLOSURE OR SHARING OF PERSONAL INFORMATION

We may share your personal information as follows:

as required to comply with the law or legal obligations, such as to comply with legal orders and government requests, or as needed to support auditing, initial public offerings, compliance, and corporate governance functions;

in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in Arab Republic of Egypt;

in the event we go through a business transition such as a merger, acquisition by another company, bankruptcy, reorganization, or sale of all or a portion of our assets and you data is needed for continuation of providing you with our services and our business;

to combat fraud or criminal activity, and to protect our rights, users, and business partners, or as part of legal proceedings affecting us;

 if the information has been aggregated, de-identified, or otherwise does not identify you personally; and otherwise with your consent;

6.SECURITY OF PERSONAL INFORMATION

We have implemented an information security program that contains administrative, technical, and physical controls that are designed to reasonably safeguard personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. We will follow the international security standards constantly and devote ourselves to ensure your information’s security. If you have any questions about security on our Website, you can contact us in accordance with Clause 13 .

7.COOKIES

We together with our marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Platform on an ongoing basis, and in order to provide our visitors, our merchants, and their customers with a better experience. The four main functions of these tools are as below:

Site functionality cookies

hese cookies allow you to navigate the site and use our features.

Site analytics cookie

these cookies allow us to measure and analyze how our customers use the site, to improve its functionality experience.

Customer preference cookies

when you are browsing on our Platform, these cookies will remember your preferences (like your language or location).

Targeting or advertising cookies

these cookies are used to deliver ads relevant to you.

By using our site on Platform, you agree to us placing these sorts of cookies on your device and accessing them when you visit the site in the future. You may manage how your browser handles cookies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available.

8. SOCIAL COMMUNITY AREAS

The Platform may be accessible through or contain connections to areas where you may be able to publicly post information, communicate with others such as discussion boards or blogs, review products and merchants, and submit media content. Prior to posting in these areas, please read our Terms of Us carefully. All the information you post may be accessible to anyone with Internet access, and any personal information you include in your posting may be read, collected, and used by others. We recommend that you do not post any personal information in the social community areas.

9. PRIVACY PRACTICES OF THIRD PARTIES

This Privacy Policy only addresses the use and disclosure of information by us through your interaction with the Platform. Other websites that may be accessible through links from the Platform and our co-branded websites may have their own Privacy Policies and personal information collection, use, and disclosure practices. Our business partners may also have their own privacy policies. We encourage you to familiarize yourself with the privacy policies provided by these other parties prior to providing them with information or taking advantage of a sponsored offer or promotion.

10.BUSINESS TRANSFER AND CORPORATE CHANGES

We reserve the right to disclose, transfer, or license any and all information related to the Platform, including personal information:

to a subsequent owner, co-owner, or operator of the Platform or any portion or operation related to part of Platform;

in connection with a corporate merger, consolidation, or restructuring, the sale of substantially all of our stock and/or assets, or other corporate change, including, without limitation, during the course of any due diligence process.

11.CHILDREN’S PRIVACY

The Platform is a general audience site not directed at children under the age of 18. By using our Platform, you represent that you are at least eighteen years old and understand that you must be at least eighteen years old in order to create an account and purchase the goods or services advertised through the Platform.

12.INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

We take appropriate steps to ensure that recipients of your personal information are bound to duties of confidentiality and we implement appropriate measures to ensure your personal information will remain protected in accordance with this Privacy Policy, such as standard contractual clauses.

13.CONTACT US

ou fully understand and acknowledge that we are entitled to final interpret the terms of this Privacy Policy. Please contact us if you have any questions or comments about our privacy practices or this Privacy Policy. You can reach us online at（ ）. You can reach us via postal mail at the following address: （ ）

14.Approval withdrawal and data deletion:

If you need to withdraw your approval you can go to the options and press on the button “Withdraw Approval and delete personal data” we will delete your data which were collected from our side and stop collecting any other personal data.

Please be advised that in the event of deleting your account on the Mobile Application or terminating the relation between you and us you all your personal data were collected from our side will be deleted.

In the event of occurring hacking, breach, or non-authorized disclosure caused sharing or a non-authorized disclosure you will be notified with such non-authorized disclosure and the precaution applied from our side in order to avoid/prevent such hackings.