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Data Privacy Policy

Preamble

"Mynk" is owned by QAZI Finance SARLAU, a Moroccan company with a capital of Two Hundred Thousand DHS (200,000), headquartered in Casablanca, Les Jardins d'Anfa Residence, Apartment 36 Building F, Angle Bd Lido and Rue Biarritz, Ain Diab, registered under number 003065707000085 in the Casablanca Trade and Companies Register.
QAZI Finance SARLAU respects your privacy and is committed to applying transparent rules on privacy protection. This "Privacy Policy" explains how we collect, use, and share your personal information in the context of your use of the Mynk application, and explains your rights regarding how we process your personal information.
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Protecting your personal data and your privacy is at the heart of our priorities. That's why, at Mynk ("Mynk" or "we" or "us" or "our"), we detail this Data Protection Policy (the "Policy") explaining our practices regarding the collection, use, and disclosure of information we receive when you use our application (the "Application") and our services (collectively, the "Services"). This Data Protection Policy applies only to the Services available on the Application. QAZI Finance collects your personal data to comply with regulatory provisions and to ensure the best quality of service. This processing has been subject to a declaration/authorization request to the CNDP.
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The personal data concerning the User may give rise to the exercise of a right of access, rectification, and opposition per the provisions of Law 09-08, by sending an email to support@mynk.ma or by sending a written letter with acknowledgment of receipt to the Customer Service, at the address indicated below, mentioning in the subject of the letter "DCP Mynk - QAZI Finance": Les Jardins d'Anfa Residence, Apartment 36 Building F, Angle Bd Lido and Rue Biarritz, Ain Diab, Casablanca.

1. Purpose of this data protection policy

This policy applies to all users (the "Users") and prospects for the provision of products and services defined in Mynk's Terms and Conditions of Use. It is regularly updated to reflect the developments in Mynk's practices as well as potential changes to the regulations applicable to personal data. Mynk invites its Users to consult it regularly to become aware of any modifications or updates made.
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As a Moroccan company, Mynk complies with all regulations and recommendations issued by the National Commission for the Control of the Protection of Personal Data (CNDP).
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Per the provisions of Law No. 09-08 on the protection of individuals regarding the processing of personal data, the User acknowledges and accepts that their personal data are intended for Mynk and are subject to processing operations for the management of their Account and the performance of the Contract, such as:
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- the collection;
- the recording;
- the storage in various forms and regardless of duration;
- and any other processing in general, including all transfers by Mynk to its commercial partners, advisers, subcontractors, and judicial authorities.
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The processing of this data has technical purposes, information on the subscribed Services, customizing of the subscribed Services, and management of the Account.
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All Mynk databases are stored in Morocco, at Mynk's partner, Orange Business Services.

2. Information collected by Mynk

2.1/ Data required during the use of the Mynk application
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When you sign up to Mynk, we collect your language preferences and phone number. An automated message is sent to you with a verification code for your phone number. We collect various data to improve the service we offer you. This data may include:

Information about the device: device type, device's operating system version, Android or IOS identifier (Device ID), IP address, device model, software version, screen size, name of the telecommunications operator, time zone, location where you downloaded the application, and type of network used (e.g. Wi-Fi).

Usage and connection information: time and date of opening the application, pages visited in the application, date and time of closing the application, duration of opening the application, and transaction data (details below). Mynk also collects crash data or cookies.

Transaction details: transaction times, dates, senders, beneficiaries, amounts transferred, amounts received in the application, amounts fed by credit card, funds transferred from Mynk to a bank account, funds withdrawn from an ATM. The history of all transactions, with the name of the sender/beneficiary, time, date, and amounts, is kept and accessible to users..

When you use the transfer feature to a contact in your directory, Mynk uses that contact's number to verify if they are a Mynk user before proceeding with the transfer. If the beneficiary doesn't have Mynk, a text message is sent to their number for them to download the application and receive their funds..

Geolocation data: Mynk may collect location information, as determined by data such as the IP address or GPS of the mobile phone, to provide a better user experience and enhance security (geolocation can, for example, be used as a check in case of suspicion of fraud). Most mobile phones allow you to control or disable the use of location services in applications from the device settings menu. It should be noted that your city and region can be deduced from the IP address..

Contacts using Mynk: The user can link their contact directories to the application to find out which of their contacts are using Mynk. To link a contact in the user's address book to a user who has just signed up for the application, Mynk needs to collect the phone numbers and email addresses in the user's address book. As Mynk does not make any other use of this information, Mynk only needs a fingerprint of this data and not the raw data. That is why this information is transmitted and stored encrypted, by a one-way public key. This function can be disabled by the user from the "settings" screen of the application.

Communications with Mynk Support: Mynk retains the history of communications that the user may have had with Mynk's support or customer service, such as email exchanges.

Tracking of actions carried out by Mynk employees: Mynk employees may be involved in managing an account, and comments on these operations may be stored

2.2/ Information provided by Users
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During the signup, Mynk collects the following information directly provided by users
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● Name (Required)
● First Name (Required)
● Phone Number (Required)
● Date of Birth (Required)
● Email address (Required)
● Gender/Sex (Optional)

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We use this
data for marketing intent and targeted promotional campaigns within the scope of Mynk. If you contact us through the form provided for this purpose in the application for any claims, we may collect data that allows us to identify you, such as your name, first name, or residential address. We will use this data to process your request.
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We will keep your personal data as long as you are registered on Mynk. If you unsubscribe from Mynk, your data will be deleted one year from the date of deactivation of your account.
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You can withdraw your consent for further storage and processing of your data at any time. Any processing of your data before your withdrawal is not affected and is covered by your consent.

Specific case of the moroccan National Identity card (ID): when upgrading to a Level 2 account (N2, described in the "Terms of Use"), the User must share a photo of their ID as well as a photo of themselves as "proof of life". In order to carry out these operations, Mynk relies on the technology developed by a third party "Indatacore", which has made its SDK available. The ID data will be processed by the teams of Lana Cash and Mynk for customer relationship management.

2.3/ Banking Data

RIB / Bank account details: To process a wire transfer to a bank account, the User is required to share a RIB. This information is stored and processed by Mynk and its partner Lana Cash.

Bank credit/debit cards : When you register one or more bank cards in the Mynk application, this data is handled directly through the secure system of the CMI using a tokenization process.
We neither collect nor store/ process any bank card data from our users.

3. Sharing of personal data with a third party

The data we collect is accessible to QAZI Finance SARLAU employees who require it for processing within the scope of their duties. 
Additionally, Mynk collaborates closely with Lana Cash, which provides its M-Wallet service.

3.1/ Lana Cash

The Service provided by Mynk relies on the expertise, know-how, and partnership with the mobile wallet service (the "M-Wallet") of Lana Cash. Lana Cash is a Moroccan joint-stock company with a share capital of Thirty-five million MAD (35,000,000) and its registered office located at 3, Rue Abou Dhabi Oasis, 20103, registered with the Casablanca Trade Register under number 434227 and a subsidiary of the CIH banking group. Lana Cash specializes in Payment operations as a payment institution authorized by Bank-Al-Maghrib.

The personal data collected may be transmitted to our partner Lana Cash.

3.2/ Authorities and legal competent courts
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The collected data may be transmitted to competent administrative and judicial authorities, national and foreign fund transfer partners, conventional service providers in case of disputes (lawyers, experts), relevant services or authorized agents of the General Tax Directorate, the Customs and Indirect Taxes Administration, Bank Al Maghrib, UTRF, the Office of Changes, and various public bodies authorized to receive them. Control services (statutory auditors, auditors and services in charge of internal or external control procedures) may also receive the data per the transfer request filed with the CNDP.

4. Data controllers and access to collected data

All of Mynk's databases, including those containing data related to the Application's Users, are hosted in a cloud in Morocco, thanks to Mynk's partner, Orange Business Services

Furthermore, the attention of the User is drawn to the following facts:
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‍- Mynk collaborates with the payment institution Lana Cash, a subsidiary of CIH Bank, which holds the mobile wallet.
- Per Circular C-6-W-16 issued by Bank-Al-Maghrib concerning payment institutions, funds held on the mobile wallet created by Lana Cash are segregated within a credit institution, in this case, CIH.
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Thus, the User's name, first name, date of birth, phone number, as well as all information related to the balance and transactions of the User are effectively shared with Lana Cash. Mynk and Lana Cash jointly define the purposes and means of these processing operations. The personal data of Users is only shared with these joint data controllers for the purpose of executing contracts established with Mynk.
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Mynk and Lana Cash are bound by mutual information obligations, particularly with regard to any violation of Users' personal data.

Moreover, like Mynk, Lana Cash has committed to complying with the prerogatives of the CNDP.
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To guarantee the secrecy, security, and confidentiality of data, and in compliance with the provisions of Law No. 09-08 relating to the protection of individuals with regard to the processing of personal data, Mynk and Lana Cash have committed to:

- Take all necessary precautions to preserve the security of data, particularly to prevent them from being distorted or damaged, and to prevent any unauthorized access not previously authorized by them.
- Ensure the lawfulness of the processing carried out within the framework of the entrusted mission;
- Respect their obligation of secrecy, security, and confidentiality, during any maintenance and remote maintenance operations carried out within their respective premises;
- Take all security measures, particularly material and logistical, to ensure the preservation and integrity of the processed data;
- Take all measures to prevent any misuse, malicious or fraudulent use of the processed data.

5. Use of collected information

The collection and processing of User Data by Mynk are carried out to ensure the best quality of service on Mynk while protecting and preventing fraud. More specifically, the objectives are:
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● To enforce our commitments to you according to our Terms of Service (TOS);
● To manage the account and provide services subscribed by Users;
● To keep Users informed about ongoing, completed, and upcoming transactions;
● To inform Users that some of their contacts use Mynk;
● To evaluate the effectiveness of messages sent by Mynk and adapt them;
● To ensure smooth communication with customer support/service;
● To manage reward programs or promotional events;
● To calculate reward levels and rights based on payment transactions made with Mynk;
● To detect and prevent fraud, abuse, security incidents, and other unauthorized activities (detailed in the TOS);
● To understand and analyze Users' usage to offer and/or develop new offers in line with their needs;
● To ensure compliance with current regulations and TOS;
● To request feedback or ask Users to leave a review or respond to a survey;
● To notify Users of changes to the application, our General Terms of Use, or our Privacy and Personal Data Protection Policy."

6. Consent

Following the reading of this Data Privacy Policy, the User expressly and unreservedly acknowledges having been fully informed beforehand of:

- all the data collected by Mynk and the partner Payment Institution Lana Cash;
- the purposes for which the processing of their personal data is intended;
- his rights conferred by law n°09-08. 
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The Client expressly and unreservedly gives their free, specific, and informed consent for the aforementioned processing, including being directly prospected by automated phone call, fax, email, or any other means employing the same technology to inform them of other offers of products and services similar to those subscribed to in the Agreement.

Préambule

Le présent document constitue les Conditions Générales d'Utilisation de l’application Mynk (ci-après « l’Application » ou « Mynk » ou « l’Application Mynk ») pour les utilisateurs Particuliers (dénommées ci-après les « CGU »), applicables à l’ensemble de nos utilisateurs (dénommés ci-après le(s) « Utilisateur(s) ») et pour la fourniture de nos produits et services (les « Service(s) ») liés aux comptes Mynk (dénommé ci-après les « Compte(s) »).

Ces Conditions Générales d’Utilisation (CGU) entrent en vigueur à compter du 1er décembre 2023.

Afin de pouvoir utiliser le Service Mynk, l'Utilisateur est tenu préalablement de prendre connaissance et d’accepter :

1- Les présentes Conditions Générales d’Utilisation (CGU) ;
2- Les Conditions tarifaires du Service figurant dans l’Annexe Tarifs & Limites ;
3- La Politique de protection des données à caractère personnel Mynk.

Ces trois documents sont disponibles pour consultation à tout moment sur le Site Web de Mynk et au sein de l’Application Mynk, disponible sur Google Play et l’App Store. Il est entendu que ces documents contractuels s’expliquent mutuellement. Toutefois en cas de contradiction ou de divergence entre les termes de ces documents, ils prévaudront dans l’ordre où ils sont énumérés.

En utilisant l'application mobile Mynk, l'Utilisateur reconnaît avoir lu et expressément consenti aux présentes. Mynk invite les Utilisateurs à consulter régulièrement les CGU. En effet, les présentes CGU peuvent évoluer et faire l’objet de modifications par Mynk. Dans ce cas, Mynk s’engage à tenir informé l’Utilisateur de la modification des présentes, de ses annexes et des documents qui leurs sont associés, dans le cas où les droits ou obligations de l’Utilisateur seraient affectés par cette modification. Mynk en informera l’Utilisateur sur l’application mobile Mynk, au plus tard deux semaines avant la date d'entrée en vigueur des modifications. En cas de refus des modifications proposées, l’Utilisateur peut résilier son adhésion à Mynk.

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