SIMBA MONEY is a Mobile money remittance service that enables customers to send money to their Families, Friends & Associates from Smartphones, Tablets, and Laptops (the “Service”). In this privacy policy, the terms “we”, “us”, “our”, and “Simba Money” refer to SIMBA MONEY AUB, Its Financial Service Company registered under the laws of LITHUANIA with registration number 305713850 and registered office at Konstitucijos 21A, Vilnius, 08130, LITHUANIA. In the language of the General Data Protection Regulation, Simba Money is the “controller” of your personal data, and you, our customer, are the “data subject”. This means that Simba Money determines the purposes and means of the processing of your personal data, while respecting your privacy rights.

We may collect and process the following information about you:

• Information that you provide us, including your name, address, date of birth, personal identity number, email address, telephone number, bank account number, credit or debit card number, and proof of your identity such as your passport, driving license, national ID card, etc.
• We request certain third-party personal data from you, such as your recipient’s full name, physical address, email address, and phone number.
• Additional “know-your-customer” information from you or third-party providers for the prevention or detection of crime or to help combat fraud, money laundering, and terrorist financing.
• Including your transaction history, how you use the Service to send or receive money, and to whom you send money.
• We may collect information about your computer, including where available your IP address, operating system, and browser type, for system administration. This is statistical information about our users’ browsing actions and patterns.
• In the event that we conduct competitions and campaigns, we may collect contact details of the participants and the winners and other information necessary to fulfill our obligations in relation thereto.

You do not have to disclose any of the above data to us. However, if you choose not to, we may not be able to provide you with the Service.

Personal Data Legal Processing

The following are reasons why we are collecting information:

• To verify your identity.
• To process your transactions.
• To collect payment for your transactions.
• To send transaction SMS/email alerts to you and the recipient of your money.
• To send you marketing & promotional details, service updates.
• To analyze our business operations.
• To provide you with information about the Service.
• To comply with applicable laws, regulations, and rules, such as those relating to “know-your-customer”, anti-money laundering, and counter-terrorist financing.

In general, we are required to collect personal data including any “know-your-customer” information, verification of your identity and transaction records, and communications with you in order to comply with our legal obligations. In order to fulfill our contract with you and provide the Service we will process your personal data and relevant third-party data to process your transactions, and collect payment for your use of the Service. The same applies in relation to competitions and campaigns, we will process the personal data of the participants and the winners to fulfill our part of the contract.

As long as you are a customer we believe that it is in your interest to receive occasional information about the Service and we may therefore send you marketing notices, service updates, and promotional offers that we believe are relevant for you based on your previous use of the Service. For the same reason, we may also process your data to analyze our business operations in order to improve the Service. In situations where you give us specific consent to process certain kinds of personal data, you are able to withdraw that consent at any time. We will then stop processing such data and, if no other legal ground for keeping your personal data apply, we will also erase your data from our system.

Depending on what purpose your data is used for, the length of time we keep it may vary. Either way, we will only hold your data as long as necessary to serve the purpose it is used for. In general, we are required to keep our customer records including any “know-your-customer” information, for five years after a customer’s most recent transaction in order to comply with our legal obligations.

Please note that we may retain any personal data mentioned above for a longer period than stated above, if required by law or if required to protect the rights, property, or safety of Simba Money or of the Service provided by us or our partners.

Third-party service providers under contracts to provide services to us may have access to personal data, however, they are obligated to handle such data with the same level of care as Simba Money. In case your personal data is processed by a third party, we will ensure that appropriate safeguards are in place to ensure that your data remains protected.

We may disclose your personal data to the following third parties:

• Service providers that we work with to help us provide our Service, including payment processors and fraud prevention services.
• If we are involved in a merger, acquisition, or asset sale, we may disclose your personal data to the prospective buyer.
• Law enforcement and government officials, but only in connection with a formal request, subpoena, court order, or similar legal procedure, as well as circumstances where we believe in good faith that disclosure is necessary to comply with the law, report suspected illegal activity, or investigate violations of our Terms and Conditions.
• We will not sell or otherwise transfer the information we collect to third parties for their promotional purposes unless we have received your explicit permission to do so.

Personal data which is submitted via our Service is sent to and stored on secure servers owned by, or operated for, us in the European Economic Area (“EEA”). Such data may be transferred to, or stored at, a destination outside the EEA and may also be processed by staff operating outside the EEA who work for us or for one of our service providers. Such transfers may be made in order to operate the Service, improve our Service, or to assist in our security or fraud protection activities.

Where recipients are outside the EEA, we will ensure that they provide an adequate level of protection for your personal data or that the transfer is otherwise permitted under applicable data protection legislation e.g. by using standard contractual clauses approved by the European Commission, by relying on a relevant adequacy decision by the European Commission, or on other legal grounds in accordance with applicable law.

The General Data Protection Regulation establishes certain rights in relation to your personal data, which are listed below:

• Information: the right to be informed about how we use your personal data.
• Rectification: the right to correct, amend or update your personal data if it is wrong or has changed.
• Erasure: the right to ask us to remove your personal data from our records.
• Restriction: the right to ask us to stop processing your personal data.
• Objection: the right to object to data processing, if you believe that our legitimate interest might infringe upon your rights.
• Access and Portability: the right to access and receive your personal data which you have shared with us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
• Automated decision making: the right not to be subject to individual decisions made solely by automated means.

At any time, you are welcome to contact us in relation to these rights. However, please note that there are certain exceptions where these rights may be superseded by laws and other requirements applicable to regulated financial institutions like Simba Money. An example of this would be the obligatory retention period, which supersedes the right to data erasure.

The security of your personal data is important to us. When you enter financial information (such as credit/debit card and banking information) within our Service, we encrypt the transmission of that information using secure socket layer technology (SSL). We use 256-bit data security encryption, so all information sent between your web browser and our Service remains private and secure.

By using our Service, you consent to our use of cookies on this site. A cookie is a small text file that is stored on your computer or telephone to identify your web browser or to store information or settings in your web browser. We use cookies to identify and analyze which pages a user has visited, which helps us to improve and tailor our Service to the individual user. The information is used to improve the user experience, as well as for statistical and marketing purposes.

Cookies will never give us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. If you no longer want to accept the use of cookies, you can change it in your settings on your web browser. You can also choose to remove permanent cookies that have been stored on your hard drive. If you decline cookies, this may prevent you from taking full advantage of our Service.

The Service contains links to other websites. Simba Money is not responsible for the privacy practices or the content of these other websites. We encourage you to familiarize yourself with the privacy practices of these other sites prior to submitting your personal data to them.

The Service includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly in our Service. Your interactions with these Features are governed by the privacy policy of the company providing it.

Simba Money (EU) Ltd

3 Charlotte Street, Wexford Town - Y35 CY66

Emails: info@simbamoney.com

Website: www.simbamoney.com

SIMBA MONEY LIMITED

SIMBA MONEY AUB

KONSTITUCIJOS 21A

08130, VILNIUS

LITHUANIA