1. Definitions

Unless specified otherwise, capitalized terms shall have the meaning ascribed to such terms in the Terms of Use (defined below).

Chat Service means the chat functionality of the PosalePay Platform which allows you to communicate with other users/account holders of the PosalePay Platform;

Customer means a consumer who opens and maintains a PosalePay Account and is registered on the PosalePay Platform;

Merchants means the person who is in the business of providing goods and/or services to consumers and who has accepted PosalePay Merchant T&C’s for receiving payments from Customers utilizing the PosalePay Platform;

PosalePay Platform means the electronic platform, whether accessed through a mobile application, handheld devices, portals, payment gateways or websites, or other means, developed and operated by PosalePay to open PosalePay Accounts and provide Services, and shall, for the purposes of this Privacy Policy, include the PosalePay Merchant Portal;

Personal Data personal information that can be associated with an identified or identifiable person. “Personal Data” can include name, postal address (including billing and shipping addresses), telephone number, email address, payment card number, other financial account information, biometric data, account number, date of birth, and government-issued credentials (e.g., driver’s license number, CNIC Number, , passport, and Taxpayer IDs). Personal Data does not include information that does not identify a specific individual;

Privacy Policy means this PosalePay Privacy Policy as amended from time to time;

Terms of Use means the terms and conditions applicable to Users and which may be accessed at here;

User refers to Customers and Merchants collectively.

2. Objective

The purpose of this Privacy Policy is to explain how we may collect, retain, process, share and transfer your Personal Data when you use our Services. This Privacy Policy applies to your Personal Data when you use our Services and does not apply to online websites or services that we do not own or control, including websites or services of Merchants.

This Privacy Policy is designed to help you understand our privacy practices in relation to the collection, use, processing, and, disclosure of your Personal Data and to help you understand your privacy choices when you use our Services.

Please contact us if you have questions about our Privacy Policy.

Our contact information is as follows:

3. Legal Requirements

PosalePay is licensed as an Electronic Money Institution by the SBP and is bound by its confidentiality obligations under Applicable Laws including, but not limited to the EMI Regulations, Payment Systems and Electronic Fund Transfers Act, 2007, and Protection of Electronic Crimes Act, 2016.

4. Scope

This Privacy Policy shall apply to all departments of the Company and employees of such departments who have access to Personal Data of the Users.

5. Policy Statement

Respect for your privacy is coded into our DNA. Since inception, we have aspired to build our Services with a set of strong privacy principles in mind.

PosalePay provides digital payment services, messaging, and other services to the Customers across Pakistan. Our, inter alia, Privacy Policy helps explain our information (including messages, transaction histories etc.) practices. For example, we talk about what information we collect and how this affects you. We also explain the steps we take to protect your privacy – like building PosalePay so that messages that have been delivered through our Chat Service are not stored, and giving you control over who you communicate with on our Services.

When we say “our,” “we,” or “us,” we refer to PosalePay. This Privacy Policy (“Privacy Policy”) applies to all of our Services, unless specified otherwise.

Please also read PosalePay Terms of Use, which describe the terms under which you use our Services.

What Personal Data do we collect?

PosalePay receives or collects information when we operate and provide our Services, including when you install, access, or use our Services. The information may have been provided by you or automatically collected by us, subject to your acceptance of our Terms of Use. The information consists of information you provide and/or information we collect and includes, but is not limited to, the following:

• Your Account information – When you register to use our Services by creating a Chat profile and establishing a PosalePay Account, we will collect Personal Data as necessary to offer and fulfill the Services you request.

That information would include all necessary details required for the purpose of activating Chat profile and Payment Services, as required by the relevant regulations to perform customer due diligence, which would include the name, phone number, address, national identification documents, etc.

We may require you to provide us with additional Personal Data as you continue to use our Services.

• Transaction and experience information – When you use our Payment Services, whether to send money to friends and family, to receive money, to make purchases from Merchants, or to process payments, we collect and save information about the Transaction, as well as other information associated with the Transaction such as amount sent or requested, amount paid for products or services, Merchant information, including information about source of funds used to complete the Transaction, device information, technical usage data, and geolocation and / or other relevant information.
• Participant information – When you use our Services, we collect and save Personal Data you provide to us about the other participants associated with the Transaction or Chat.
  • Send or request money: When you send or request money through the Services, we collect Personal Data about the participant who is receiving money from you or sending money to you. The extent of Personal Data required about a participant may vary depending on the Services you are using to send or request money.
  • Pay or request someone else to pay a bill: If you use our Services to pay a bill for the benefit of someone else, or if you request a User to pay a bill for you, we may collect Personal Data from you about the account holder such as name, postal address, telephone number, email address, and account number of the bill that you intend to pay or request to be paid.
  • Add money to your PosalePay Accounts: If you use our Services to add money to your PosalePay Account through the various available modes, or someone else adds money to your PosalePay Account, we may collect Personal Data from you about the other party, or from the other party about you to facilitate the request.
  • Your messages: We do not retain your messages in the ordinary course of providing our Services to you except for group Chat Services. Once your messages (including your chats, photos, videos, voice messages, files, and share location information) are delivered, they are deleted from our servers. Your messages are stored on your own device. If a message cannot be delivered immediately (for example, if you are offline), we may keep it on our servers for up to 30 days or till the message storage limit for the intended recipient is exhausted, as we try to deliver it. If a message is still undelivered after 30 days or if the message storage limit of the intended recipient is exhausted, we delete it. To improve performance and deliver media messages more efficiently, such as when many people are sharing a popular photo or video, we may retain that content on our servers for a longer period of time. We also offer end-to-end encryption for our Chat Services, except for group Chat Services. End-to-end encryption means that your messages are encrypted to protect against us and third parties from reading them.
• Information about your contacts – It may be easier for us to help you interact with your friends and contacts if you choose to sync or upload your contact list information to your PosalePay Account. If you choose to do so, we will collect and use the names, telephone numbers, addresses and email addresses in your contact list information, including those of users of our Services and your other contacts, on a continued basis to improve your experience when you use the Services. This information is used to identify which of your contacts in your device’s phone book are also PosalePay users and add them to your PosalePay contact book so you can chat and transact with them easily. We will also update your PosalePay contacts when your contacts who are not yet using PosalePay sign up later. You can control the contact sync feature from your app as well as device-based settings. Learn more about our contact syncing feature here.
• Information that you choose to provide us to obtain additional Services or specific online Services – If you request or participate in an optional site feature, or request enhanced Services or other elective functionality, we may collect additional information from you. We will update this Privacy Policy from time to time to cover information required to obtain additional Services or specific online Services as and when such Services are offered on the PosalePay Platform.
• Information about you from third-party sources – We obtain information from third-party sources such as NADRA, Merchants, and credit and other related data bureaus, where permitted by Applicable Laws.
• Other information we collect related to your use of our Sites or Services – We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.

Why Do We Retain Personal Data?

We retain Personal Data to fulfill our obligations under Applicable Laws and for our business purposes. We may retain Personal Data for longer periods than required by Applicable Law if it is in our legitimate business interests and not prohibited by Applicable Law. If your PosalePay Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with Applicable Law. We will continue to use and disclose such Personal Data in accordance with this Privacy Policy.

How Do We Process Personal Data?

We may process your information for the following reasons:

• To provide the Services, including:
  • Initiate and execute a Transaction;
  • authenticate your access to a PosalePay Account;
  • communicate with you about your PosalePay Account, the Services, or PosalePay;
  • connect a Linked Account which is maintained with a Partner Institution with the PosalePay Platform;
  • perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes;
  • keep your PosalePay Account and financial information up to date.
• To manage our business needs, such as monitoring, analyzing, and improving the Services’ performance and functionality. For example, we analyze your behavior and perform research about the way you use our Services.
• To manage risk and protect the PosalePay Platform, the Services and you from fraud by verifying your identity. PosalePay risk and fraud tools use Personal Data, device information, technical usage data and geolocation information from our PosalePay Platform and websites that offer PosalePay Services to help detect and prevent fraud and abuse of the Services.
• To market to you PosalePay risk and fraud tools use Personal Data, device information, technical usage data and geolocation information from our PosalePay Platform and websites that offer PosalePay Services to help detect and prevent fraud and abuse of the Services.
• To provide personalized Services offered by PosalePay on third-party websites and online services. We may use your Personal Data and other information collected in accordance with this Privacy Policy to provide a targeted display, feature, Services or offer to you on third-party websites. We may use cookies and other tracking technologies to provide these online services and/or work with other third parties such as Merchants, advertising or analytics companies to provide these online services.
• To provide you with location-specific options, functionality or offers if you elect to share your geolocation information through the Services. We will use this information to enhance the security of the Services and provide you with location-based Services, such as advertising, search results, and other personalized content.
• To comply with our obligations and to enforce the terms of our PosalePay Platform and Services, including to comply with all Applicable laws.
• To make it easier for you to find and connect with others, we may use your Personal Data and other information you have shared with the Service to suggest connections between you and people you may know. For example, we may associate information that we learn about you through your and your contacts’ use of the Services, and information you and others provide to suggest people you may know or may want to interact with through our Services. Social functionality and features designed to simplify your use of the Services with others vary by Service.
• To respond to your requests, for example to contact you about a question you submitted to our customer service team.

Do We Share Personal Data?

We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Policy for the purposes of and in connection with the use of the PosalePay Platform, PosalePay products and Services and general business purposes. Your Personal Data or other information will, at all times, be shared on a confidential basis and its usage will be restricted for the purposes for which it is shared or disclosed as provided in this Privacy Policy. We may share your Personal Data or other information for the following reasons:

With other members of the PosalePay corporate family: We may share your Personal Data with members of the PosalePay family of entities to, among other things, provide the PosalePay products or Services you have requested or authorized, or to provide products and services that are a part of our common or their individual public offering; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; and to help us manage the availability and connectivity of PosalePay products, Services, and communications.

With other service providers/agents: We may share Personal Data with service providers and/or agents that provide us support and facilitate us in providing the Services or otherwise perform services and functions at our direction and on our behalf. These service providers may carry out functions in relation to the Services, for example, verify your identity, assist in processing transactions, data analytics and other monitoring and analyzing of data for improving the Services’ performance and functionality, send you advertisements for our products and Services, or provide customer support.

With other financial institutions: We may share Personal Data with other financial institutions that we have partnered with to jointly create and offer products / Services. These financial institutions may only use this information to develop, market and offer PosalePay-related products and Services. We may also share Personal Data to process transactions, provide you with benefits associated with your eligible cards, and keep your financial information up to date.

With the other parties to Transactions when you use the Services, such as other Users, Merchants, and their service providers: We may share Personal Data and other information about you and your PosalePay Account with the other parties involved in processing your Transactions. This includes other Users, Merchants and service providers you are sending funds to or receiving funds from, when you use the Services to pay for goods or services. The information includes:

• Personal Data and PosalePay Account information necessary to facilitate the Transaction and to comply with Applicable Laws;
• information to help other participant(s) resolve disputes and detect and prevent fraud; and
• aggregated data and performance analytics, including results of polls conducted from time to time in order to gauge consumer and merchant behavior to help Merchants better understand Users and to help Merchants enhance Users’ experiences.

With other third parties for our business purposes or as permitted or required by Applicable Law: We may share your Personal Data or other information about you with other parties for PosalePay legitimate business purposes or as permitted or required by Applicable Law, including:

• if we need to do so to comply with a subpoena, court order, direction, or other legal process or requirement under Applicable Law issued or initiated by law enforcement, regulators, government officials, or other third parties (in India) to or against PosalePay or one of its affiliates;
• when we need to do so to comply with credit card rules or other requirements and regulations of local and foreign card payment schemes;
• when we believe, in our sole discretion (acting reasonably), that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss; or to report suspected illegal activity or to investigate violations of the Terms of Use or agreements with Merchants;
• to protect our property, Services and legal rights;
• to potential acquirers and merging entities or to otherwise facilitate a purchase or sale of all or part of PosalePay business;
• in connection with shipping and related services for purchases made using a Service;
• to help assess and manage risk and prevent fraud against us, our Users and fraud involving our PosalePay Platform or use of our Services, including fraud that occurs at or involves our business partners, service providers/agents, strategic ventures, or other individuals and Merchants;
• with Partner Institutions for the purpose of linked Partner Bank Accounts with PosalePay Accounts or as otherwise required under relevant agreements; and
• to support our audit, compliance, and corporate governance functions.

Otherwise With your consent: We do not share your Personal Data with third parties for purposes unrelated to the Services without your consent.

In addition, PosalePay may provide aggregated statistical data to third parties, including other businesses and members of the public, about how, when, and why Users visit our PosalePay Platform and use our Services. This data will not personally identify you or provide information about your use of the PosalePay Platform or Services. We do not share your Personal Data with third parties for purposes unrelated to the Services without your consent.

How Do We Use Cookies and Tracking Technologies?

When you access PosalePay Platform or use our Services, we may use cookies and other tracking technologies (collectively, “Cookies”) collected from you to recognize you as a User and to customize your online experiences, the Services you use, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Services. Certain aspects and features of our Services are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Services may be limited or not possible.

Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not respond to DNT signals.

What Privacy Choices Are Available to You?

You have choices when it comes to the privacy practices and communications described in this Privacy Policy. Many of your choices may be explained at the time you sign up for or use a Service or in the context of your use of the PosalePay Platform. You may be provided with instructions and prompts within the experiences as you navigate the Services.

• Personal Data.You may decline to provide Personal Data when it is requested by PosalePay, but certain Services or all of the Services may be unavailable to you. If you have a PosalePay Account, you generally may review and edit Personal Data by logging in and updating the information directly or by contacting us. Contact us if you do not have a PosalePay Account or if you have questions about your PosalePay Account information or other Personal Data.
• Location and other device-level information. The device you use to access the PosalePay Platform or Services may collect information about you, including geolocation information and User usage data that PosalePay may then collect and use. For information about your ability to restrict the collection and use of such information, please use the settings available in the device.
• Finding and connecting with others. If available, you may manage your preferences for finding and connecting with others from your PosalePay Account of the Service you use.
• PosalePay Account Linking. If you authorize Partner Bank Account Linking to a PosalePay Account or PosalePay Platform or linking of your PosalePay Account to your other accounts (including social media accounts), you may be able to manage your connection preferences from your PosalePay Account or the Partner Bank Account or other platforms/websites. Please refer to the privacy notice and policies that governs the Partner Bank’s or other relevant platforms for more information on the choices you may have.
• Cookies. You may have options available to manage your cookies preferences. For example, your browser or internet device may allow you delete, disable, or block certain cookies and other tracking technologies. You can learn more by visiting AboutCookies.org. You may choose to enable these options but doing so may prevent you from using many of the core features and functions available on the PosalePay Platform or in relation to a Service. You may also have an option regarding the use of cookies and other tracking technologies when you use a Service or visit parts of the PosalePay Platform. For example, you may be asked if you want the Service or the PosalePay Platform to “remember” certain things about you, and we will use cookies and other tracking technologies to the extent that you permit them.
• Marketing: We may send you marketing content about our Services, products, products we jointly offer with Partner Institutions, as well as the products and services of unaffiliated third parties and members of the PosalePay corporate family through various communication channels, for example, email, text, pop-ups, push notifications, and messaging applications. If you do not wish to be notified of any of the aforementioned communication, you can disable the notification by changing the appropriate setting on the PosalePay Platform.
• Informational and Other: We will send, as per the Terms of User, communications to you that are required or necessary to send to Users of our Services, notifications that contain important information and other communications that you request from us. You may not opt out of receiving these communications.

How Do We Protect Your Personal Data?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. While we are dedicated to securing our systems and Services, you are, as per the Terms of Use, responsible for securing and maintaining the privacy of your password(s), MPIN and PosalePay Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a Partner Bank based on Partner Bank Account Linking that you have authorized.

What Else Should You Know?

Changes to This Privacy Statement.

We may revise this Privacy Policy from time to time to reflect changes to our business, or Services, or Applicable Laws. Such revisions will be notified to the Users through the PosalePay Platform. The revised Privacy Statement will be effective as of the published effective date. Continuing use of PosalePay Services shall be deemed as acceptance of the revised Privacy Policy by the Users. We also may notify Users of the change using email or other means.