SIFT Privacy Notice

We recognize that protecting personal information is very important to you and that you have an interest in how we collect, use, store and share such information. We always respect our customers’ privacy and personal information and we take this matter very seriously. We have worked very hard to earn our customers’ trust and keeping it is our top priority.

That’s why we comply with the obligations that are laid out under data protection laws.

This privacy notice sets out how we, as a data controller, will use and protect your information.

We will use your personal information only for the purposes and in the manner set out in this privacy notice. We recommend that you read this privacy notice carefully.

Please note: you have the right to object to the processing of your personal data where that processing is carried out for our legitimate interests or for direct marketing purposes.

1. About us

www.siftmobile.io and any associated Sift mobile applications, present or future, (each the “Applications”) are operated by, and the top-up services (and any other services available on the Applications from time to time) (“Services”) are provided by, Mocom SAS, SIFT Mobile (“Sift”, “we” or “us”). We are registered in France with registered number 794 046 672 and we have our registered office at 4 avenue herbillon 94160 Saint Mandé.

Sift is a registered business name of Mocom SAS.

All correspondence in relation to any Sift company should be sent to 4 Avenue Herbillon 94160 Saint Mandé. France

2. How can you get in contact with Sift?

If you have any questions about this privacy notice or any other queries or complaints, our customer care team is here to help – please email us: hello@siftmobile.io

3. Scope of Sift’s privacy notice?

Personal data is information that identifies a person or can be used to identify a person. For us to provide our Services to you, we need to collect and process personal data about you. Without this information, we may not be able to provide our Services to you.

This privacy notice will apply to personal data about you collected by us through the Applications or otherwise. It also applies to any third parties whose personal data you provide to us in respect of which we are a data controller. You acknowledge that you have informed any such third party that their personal data may be collected and processed by Sift and made them aware of this privacy notice.

Any changes to Sift’s privacy notice will be posted clearly on our Applications.

4. What data does Sift collect?

We may collect and process the following information about you:

·      Contact Details : name; email address; telephone number; social media ID;

·      Payment Details : cardholder name; credit or debit card details (however, we only retain certain parts); chargeback information;; Paypal ID;

·      Transaction Details : top-up transaction amount and currency;

·      Electronic Identifying Details : IP address; SMS content; cookies; activity logs (e.g. user session recordings); online identifiers; device identifiers (e.g. the mobile device and/or the internet browser that you use) and geolocation data;

·      Correspondence and complaints : any correspondence that you choose to send to Sift (including complaints); any information you provide to our customer care team; any information you publish about Sift (including on the app stores);

·      Transaction History: details of the top-up transactions you carry out on, and your visits to, the Applications. If you choose to grant the mobile applications access to contact information through your device, we may collect this information, including names, telephone numbers, email addresses and social media identifiers. We use this information to help us deliver the Services to your contacts in the most efficient manner and for the other purposes listed below.

5. How does Sift collect your personal data ?

You provide us with your personal data when you register for, or use our Services. We may also collect personal data about you from third parties (e.g. in the event of chargebacks or through third party direct marketing services). We also collect information about you through your use of our Applications, your visits to our Applications and details of the transactions you carry out of our Applications. When you visit our Applications, your device and/or browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connection to an Application or other technical communications information), some of which may constitute personal data.

6. Why do we process your personal data and what is our legal basis for doing so ?

Reason for processing personal data

·      To help you purchase the Services that you have requested and to process any payment

connected with that Services request

·      To deliver the Services that you have requested to the recipient of the Services

·      To contact you if it's required in relation to the Services that you have sent or to reply to any

communications that you might have sent us.

Legal Basis for processing your personal data

·      The use is necessary for the performance of a contract to which you are a party or in order to

take steps at your request prior to entering a contract

Reason for processing personal data

·      To provide you with information on products or services that might interest you

·      To notify you about any changes to the Applications or Services

·      To ensure that content on the Applications is presented in the most effective manner for you

and your device

·      To provide you with customer care

·      For marketing analysis

·      For security and fraud prevention purposes

·      To help improve our Applications and our Services

Legal Basis for processing your personal data

·      The use is necessary for the purpose of our legitimate interests

We will also process personal data as is necessary to comply with any of our legal obligations. We will inform you in advance if we intend to further process your personal data for a purpose other than as set out above. We will also seek your specific consent to the processing of personal data for other specific purposes. You will have the right to withdraw such consent at any time.

7. Do we carry out any automated processing of your personal data ?

We use automated statistical analysis of the personal data we collect about you in order to comply with our legal obligations to detect and prevent fraud, dishonesty and other crimes. We may use automated processing to screen for suspicious transactions, or to identify transactions that may be subject to international sanctions.

When we make solely automated decisions that affect you in a legal or a significant way, you have the right to provide your point of view and have those decisions reviewed by a member of our staff.

8. What happens if you do not provide us with your personal data ?

If you do not provide us with your personal data or object to the use of certain personal data, we may not be able to provide the Services to you. We will tell you when we ask for information which is a contractual requirement or needed to comply with our legal obligations.

9. Who do we disclose your personal data to ?

We currently share your personal data, where necessary, with the following recipients:

·      you and, where you request, any third party you ask us to share it with;

·      mobile operators (directly or via third parties);

·      anti-fraud service providers;

·      governmental, legal, regulatory, or similar authorities, on request or where required, including for the purposes of reporting any actual or suspected breach of applicable law or regulation;

·      third party payment processors;

·      direct marketing service providers;

·      data analytics service providers (e.g. Google Analytics, Appsflyer);

·      third party service providers used for the delivery of some aspects of the Services (e.g. SMS delivery, email delivery, web notifications, app notifications and phone number lookup);

·      hosting infrastructure companies based in the EEA;

·      potential purchasers or bidders.

Our Applications may, interface with third party services that you have previously interacted with (e.g. Facebook and Google), or contain links to third party content (e.g. mobile operator content). Please note that Sift is not responsible for such services or content, or the privacy policies associated with those services or content. We recommend that you review any third party’s privacy policy before accessing such services or content.

10. Does Sift transfer your personal data outside the EEA?

Sift may be required to transfer your personal data outside the EEA for the purposes of providing the Services. To ensure that your personal data receives an adequate level of protection and is treated securely, we have put the appropriate safeguards in place to protect the privacy and integrity of such personal data when being transferred outside the EEA.

11. What if Sift is bought by another company?

We reserve the right to transfer information (including your personal data) to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company. The third party must only use your personal data for the purposes that you provided it to us in the first place and as set out in this privacy notice. You will be notified in the event of any such transfer.

12. Data Security

We have implemented appropriate technical and organizational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with data protection laws.

You are responsible for ensuring that any personal data that is sent to us is sent securely.

13. How long do we keep your personal data?

We will keep your personal data only for so long as is necessary to carry out the purposes set out above and to comply with any legal obligations. The criteria for determining the duration for which we retain your personal data are whether it is necessary:

·      to maintain an ongoing relationship with you (e.g. to provide our Services to you or where you are lawfully included in our direct marketing lists and have not unsubscribed);

·      in connection with the lawful purposes set out in this policy, or where we have a valid legal basis; or

·      to comply with any applicable limitation period under applicable law, and a reasonable amount thereafter.

Once the periods above have concluded, we will either:

·      permanently delete or destroy the relevant personal data;

·      archive your personal data so that it is beyond use; or

·      anonymise the relevant personal data.

14. Where does Sift hold your personal data?

Your personal data is held by us on secure servers which are hosted by Sift or by a third party hosting infrastructure company located within the EEA.

15. Your Rights

You have a right to obtain a copy of, and the right to rectify any inaccuracies in, the personal data we hold about you by making a request to us in writing. You also have the right to request erasure, restriction, portability, or object to the processing, of your personal data or not to be subject to a decision based on automated processing, including profiling. You should inform us of any changes to your personal data. Any requests made under this section can be made using the contact details set out below. We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than one month after receipt of your request. You have the right to lodge a complaint with the Office of the Data Protection Commission if unhappy with how your personal data is being handled by us. Their contact details are as follows:

Commission Nationale de l’Informatique et des Libertés (CNIL)

3 Place de Fontenoy
TSA 80715
75334 PARIS CEDEX 07
Téléphone : +33 (0)1 53 73 22 22

If we are relying on your consent to allow us to process your information, you can withdraw your consent at any time. From that point on we would no longer be able to carry out the processing we were carrying out with your consent. Any processing we carried out before you withdrew your consent would remain valid. We do not generally rely on consent for processing personal data.

Please contact us at hello@siftmobile.io or at Sift, 4 Avenue Herbillon 94160 Saint Mandé, France to exercise any of your rights under this section.

16. Will Sift use your personal data for direct marketing purposes?

Where we have your consent to do so, we will use your personal data to send you information by SMS, email or app notifications relating to our products and services which may be of interest to you or similar products and services to those you have previously purchased from Sift.

17. Can you opt-out/unsubscribe from direct marketing?

You will be provided with an opportunity to opt-in at the point of registration. You can also opt-out at any time, free of charge, by: (i) for SMS and email, by using the unsubscribe facility in the SMS or email that Sift sends to you; (ii) for push notifications, by opt-out in the Sift Mobile application menu; or (iii) by sending an email to hello@siftmobile.io

Sift does not sell or share your personal data with subsidiary companies or third parties for marketing or profit purposes.