Privacy Policy for Mandalay Smart Pay ( MSP )

Effective Date: March 14, 2020

Scope and Consent

You accept this Privacy Policy when you sign up for, access, or use our products, services, content, features, technologies, or functions offered through our website, mobile application, and related services (collectively, “Mandalay Smart Pay ( MSP )” or “the Services”).

This Privacy Policy explains how Mandalay Smart Pay ( MSP ) (“we”, “our”, or “us”) collects, uses, discloses, and protects your personal information when you use our Services. By continuing to use our Services, you consent to the practices described in this Privacy Policy.

We may amend this Privacy Policy from time to time by posting an updated version within the App or on our website. The revised version will take effect on the date it is published.

1. Collection of Personal Information

We collect personal information necessary to provide you with secure, convenient, and personalized services. The information we may collect includes:

(a) Information You Provide to Us

When you register or use Mandalay Smart Pay ( MSP ), we may collect:

• - Full name, phone number, and email address
• - Company or organization name (if applicable)
• - NRC or government-issued identification number (for identity verification)
• - Address or location information
• - Linked bank account or payment details
• - Feedback, inquiries, or other communications you provide

(b) Information Collected Automatically

When you use our App or website, we automatically collect:

• - Device model, operating system, and IP address
• - App version, usage statistics, and crash logs
• - Location data (if permission is granted)
• - Date and time of access

This helps us operate, improve, and secure our Services.

(c) Information from Third Parties

We may obtain additional data from:

• - Partner banks and payment processors (for KYC and verification)
• - Regulatory bodies and public databases, as required by law
• - Social media or identity verification providers (only with your consent)

2. Use of Personal Information

We use the collected data to:

• - Create and manage your Mandalay Smart Pay ( MSP ) account
• - Enable secure payment and business transactions
• - Verify identity and ensure compliance with KYC and AML regulations
• - Provide customer support and resolve issues
• - Improve product performance and enhance user experience
• - Communicate important updates or policy changes
• - Comply with applicable laws and regulations

We do not sell or rent your personal data to any third parties.

3. Sharing and Disclosure of Information

We may share your information only when necessary and in compliance with legal requirements:

• - Partner Banks and Payment Processors: to facilitate transactions and identity verification.
• - Regulatory Authorities: to comply with applicable laws and government requests.
• - Service Providers: such as hosting, analytics, and support vendors who operate under strict data protection agreements.
• - Business Transfers: in case of a merger or acquisition, subject to continued privacy protection.
• - Legal Obligations: to comply with subpoenas, court orders, or applicable laws.

4. Data Retention

We retain your information only as long as necessary to:

• - Provide services and complete transactions,
• - Comply with legal or regulatory obligations,
• - Resolve disputes, and
• - Enforce our agreements.

Once no longer needed, your information will be securely deleted or anonymized.

5. Data Security

We apply appropriate technical and organizational measures to safeguard your data, including encryption, secure servers, and restricted access controls.

While we strive to protect your personal information, no system can be fully secure. You are responsible for maintaining the confidentiality of your account credentials.

6. Your Rights and Choices

You may:

• - Access, update, or correct your personal information;
• - Request account deletion or withdrawal of consent;
• - Manage permissions (camera, contacts, location, etc.) through your device settings;
• - Opt-out of marketing communications (while still receiving essential service updates).

You may submit such requests through the contact details below.

7. Use of Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your user experience and analyze site traffic. You may disable cookies in your browser settings, but some features of the Services may not function properly without them.

8. Children’s Privacy

Mandalay Smart Pay ( MSP ) are intended for users aged 18 years and above. We do not knowingly collect personal data from minors.

9. International Data Transfers

Your data may be processed and stored on servers located outside your country of residence. We ensure that such transfers comply with applicable data protection laws.

10. Updates to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal obligations. Updated versions will include the revision date and will be made available in the App and on our website.

11. Contact Information

If you have any questions, concerns, or data-related requests, please contact us at: