VALUE ADDED SERVICE (VAS) CONSULTS LTD

 

PRIVACY POLICY

Last Updated: February 10, 2024

 

VAS Consults, its parent, and affiliates (“VAS Consults”) recognize that people who use XPay, Reward Xperience and Ujirani Pay (the “Mobile Applications”) value their privacy. This Privacy Policy (the “Policy”) describes how VAS Consults (“we”, “our”, or “us”) collects, uses, shares, and stores personal information of its users from the mobile applications, and the websites, https://vasconsults.com/ and https://vasconsults.com/ (the “Sites”) with regard to the Digital Wallet Platform.  This Policy applies to the Sites, Mobile Applications, products and services (collectively, “Services”) on or in which it is posted, linked, or referenced.

By using the Services, you accept the terms of this Policy and our Terms of Use, and consent to our collection, use, disclosure, and retention of your information as described in this Policy. If you have not done so already, please also review our Terms of Service.  IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, THEN PLEASE DO NOT USE ANY OF THE SERVICES.

 

WHAT WE COLLECT

We collect personal information about you in the following ways: 1) from you when you voluntarily submit information directly to us; 2) using automated technology, including when you visit our Sites, social media, or communications; and 3) using third party sources, including our service providers, analytics providers, and social media companies. Automated technology collects information from your mobile device and includes cookies, web beacons, local shared objects, or other similar technology. More information is given below in the “Cookies and Other Technology” section below.

We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form.  We may combine data collected from third party sources.

Information you give us

Information we collect from you includes:

Contact and identity information, such as your name, phone number, email address, username;

User-created content, such as your chat messages, comments, likes, thumb-ups/downs, arts and graphics in social applications including chats and forums;

Network information regarding transactions, such as transactions you send or receive.

Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in community research activities, report a problem with Service, receive customer support or otherwise correspond with us;

Marketing information, such your preferences for receiving marketing communications and ads and details about how you engage with them.

 

Know Your Customer Verification Information

Separate from the personal data collected in our app and from other sources as set forth herein, and to comply with industry regulatory standards and government orders in different areas such as Anti-Money Laundering (AML), Know-Your-Client (KYC), and Counter-Terrorist Financing (CTF), VAS Consults collects personal information such as identity documents (including passport, driver’s license, national identity card, tax ID number, passport number, driver’s license details, national identity card details, visa information, selfie images, selfie videos etc.), proof of address, source of fund declaration, purposes of fund documents, and source of wealth (“KYC Data”). This KYC data is collected and used solely to verify the identity of members (“Community”) and to be compliant with regulatory requirements and the VAS Consults policy that only real human beings can use the services.

 

Information we get from others

We may get information about you from other third party sources and we may add this to information we get from your use of the Services. Such information may include:

We may collect information that other users provide about you when they use our services. For example, if another user allows us to collect information from their device phonebook or email contacts—and you’re one of that user’s contacts—we may combine the information we collect from that user’s phonebook or email contacts with other information we have collected about you. We may also obtain information from other companies. For example, we may offer the option for you to login to our services through your google account and Apple sign-in. With your authorization through Google or iOS, these companies will give us the information that you consent to send us.

Social Media Widgets: Our Sites may include social media features, such as the Facebook logins, “like” button and widgets, such as the “share this” button. These features may collect your personal information and track your use of the Sites. These social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing such functionality.

Information automatically collected when you use our services

When you use our services, we collect information about your usage of our mobile applications, activities you have through our servers, such as how many times you send or receive transactions, your usage information of VAS Consults mobile applications.

Account information. We collect information about account status, language, account behavior data. 

Device Information. We collect device-specific information, such as the hardware model, operating system version, advertising identifier, unique application identifiers, unique device identifiers, browser type, language, wireless network, and mobile network information (including the mobile phone number).

Device Phonebook. If you’re using our mobile applications, we may—with your consent—collect information from your device’s phonebook.

Location Information.  By using our services, you acknowledge that we may collect information about your location. With your consent, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses. If you are an admin –meaning you sometimes run the admin portal on the desktop – your IP address is public or you visited our websites.

Log Information. We also collect log information when you use our admin portals. That information includes, among other things:

details about how you’ve used our services

device information, such as your web browser type, operating system and language

access times

pages viewed

IP address

identifiers associated with cookies or other technologies that may uniquely identify your device or browser

pages you visited before or after navigating to our website.

the pages or features of our Sites to which a user browsed and the time spent on those pages or features, the frequency with which the Site is used by a user, search terms, the links on our Sites that a user clicked on or used, and other statistics.

We may use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level. For more information, please see the section entitled “Cookies Policy” below.

We also use Google Analytics to help us offer you an optimized user experience. You can find more information about Google Analytics’ use of your personal data here: https://policies.google.com/privacy?hl=en

Information we will never collect. We will never ask you to share your username or wallet password. The wallet password will be entered into the mobile applications’ interface locally on your phone to unlock your wallet, and will never leave your phone or come to our servers. Never trust anyone or any site that asks you to give your username or wallet password. 

 

HOW WE USE INFORMATION

To provide our service

We will use your information in the following ways:

develop, operate, improve, deliver, maintain, and protect our services,

communicate with you, to send information, including confirmations, technical notices, updates, security alerts, and support and administrative messages, etc..

monitor and analyze usage,

personalize the services by, among other things, suggesting new services, or customizing the content we show you, including ads,

enhance the safety and security of our products and services

verify your identity, and protect, investigate, and deter against fraudulent, unauthorized, or illegal activity,

use information we’ve collected from cookies and other technology to enhance the services and your experience with them.

To comply with law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to court orders or requests from government authorities.

To optimize our platform

In order to optimize your user experience, we may use your information to operate, maintain, and improve our Services. We may also use your information to respond to your comments and questions regarding the Services, and to provide you and other users with general customer service.

To fulfill your requests

With your consent, We may use or share your personal information with your consent, such as when you instruct us to take a specific action with respect to your personal information, or you opt into third party marketing communications.

 

SHARING OF PERSONAL INFORMATION

We do not share or sell the personal information that you provide us with other organizations without your express consent, except as described in this Privacy Policy. We disclose personal information to third parties under the following circumstances:

Affiliates. We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy.

Business Transfers. We may share personal information when we contemplate or enter into a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

Compliance with Laws and Law Enforcement; Protection and Safety. We may share personal information for legal, protection, and safety purposes. We may share information to comply with laws.

We may share information to respond to lawful requests and legal processes.

We may share information to protect the rights and property of ours, our agents, customers, and others. This includes enforcing our agreements, policies, and Terms of Use.

We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.

Professional Advisors and Service Providers. We may share information with those who need it to do work for us to provide the Services. These recipients may include third party companies and individuals to administer and provide the Service on our behalf (such as customer support, hosting, email delivery, database management services and identity KYC validators (identity verifiers), as well as lawyers, bankers, auditors, and insurers.

With third parties as part of a merger or acquisition.  If VAS Consults gets involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes. 

In the aggregate or after de-identification. We may also share with third parties aggregated or de-identified information that cannot reasonably be used to identify you.

We do not share any data with ad networks directly. However, the ad networks used inside our apps may request directly from your phone’s operating system, such as iOS or Android, an anonymized advertising identifier in order to for them to serve you with more relevant ads.

Other. You may permit us to share your personal information with other companies or entities of your choosing. Those uses will be subject to the privacy policies of the recipient entity or entities.

 

HOW INFORMATION IS SECURED

We retain information we collect as long as it is necessary and relevant to fulfill the purposes outlined in this Privacy Policy. In addition, we retain personal information to comply with applicable law where required, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service, and other actions permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

We employ industry standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, biometrics, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected.

 

INFORMATION CHOICES AND CHANGES

Accessing, Updating, Correcting, and Deleting your Information

You may access information that you have voluntarily provided through your account on the Services, and may review, or request that it be corrected, or deleted by logging into your account in the mobile application and visiting the user profile screen. For further requests in regard to personal data access, you may 1) submit a request ticket through the provided link, or 2) make a request through privacy@vasconsults.com. You can request to correct contact choices, opt-out of our sharing with others, and correct your personal information and preferences, subject to applicable law and VAS Consults terms of service.  If you choose to withdraw your consent from the collection, processing, and transfer of your information then we will be unable to provide you with a service and your account will be deleted. Data subjects have the right to withdraw their consent at any time and we will honor your request.  However, because your consent to the sharing of information is necessary for our ability to verifying the identity of members so as to be compliant with regulatory requirements and the VAS Consults policy that only real human beings can authorize transactions, without your consent we cannot provide you with our service.

Tracking Technologies Generally

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. For more information, please see the section entitled “Cookies Policy” below.

Google Analytics

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.

 

CONTACT INFORMATION. We welcome your comments or questions about this Policy, and you may contact us at the contacts shared on our Sites

 

CHANGES TO THIS PRIVACY POLICY. We may change this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make any changes, we will change the Last Updated date above.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the changes to the Site (or as otherwise indicated at the time of posting). In all cases, your continued use of the Site or Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

 

Legal Bases for Processing

We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal bases under which we process your personal information, contact us.

Processing Purpose	Legal Basis
To provide our services To enable features to you To communicate with you To optimize our platform For compliance, fraud prevention, and safety To enforce our terms of service	These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impacts on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law).
With your consent	Where our use of your personal information is based upon your consent, you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us

 

Use for New Purpose

We may use your personal information for reasons not described in this Privacy Policy, where we are permitted by law to do so and where the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis for that use. If we have relied upon your consent for a particular use of your personal information, we will seek your consent for any unrelated purpose.

 

Your Rights

You may ask us to take the following actions in relation to your personal information that we hold:

Opt-out. Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications.

Access. Provide you with information about our processing of your personal information and give you access to your personal information.

Correct. Update or correct inaccuracies in your personal information.

Delete. Delete your personal information.

Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.

Restrict. Restrict the processing of your personal information.

Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or respond to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.

 

Cross-Border Data Transfer

Please be aware that your personal data will be transferred to, processed, and stored in Amazon Web Services (AWS) data centers. Data protection laws in the countries where these data centers are may be different from those in your country of residence. We transfer your personal information out of your jurisdiction only upon your consent. You consent to the transfer of your information, including personal information, to the said data center locations as set forth in this Privacy Policy by visiting our Sites or using our mobile applications.

Whenever we transfer your personal information out of you jurisdiction to countries where these data centers are located or countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information.

 

Transfers to Third Parties

Courts, tribunals, government authorities and related parties or counterparties with whom we share personal data, third-party vendors and business partners are in some cases located outside the EU. Unless the recipients are located in countries that have been deemed adequate by the European Commission, we put in place data transfer agreements based on the applicable European Commission-approved Standard Contractual Clauses to protect the personal data so transferred.  In certain cases, we may rely on statutory derogations for international data transfers.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the country of your residence.

The collection, processing, and transfer of your information is necessary for our ability to provide you with our service. Without your consent we will be unable to authenticate your account, verify your identity, facilitate transactions, along with various other actions necessary for providing you with our service. As a result, if you decline to consent to the collection, processing, and transfer of your data we will be unable to provide you with our service.

 

COOKIES POLICY

We understand that your privacy is important to you and are committed to being transparent about the technologies we use. In the spirit of transparency, this policy provides detailed information about how and when we use cookies on our Site.

Do we use Cookies?

Yes. We and our marketing partners, affiliates, and analytics or service providers use cookies, web beacons, or pixels and other technologies to ensure everyone who uses the Site has the best possible experience.

What is a Cookie?

A cookie (“Cookie”) is a small text file that is placed on your hard drive by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. Some of the cookies will only be used if you use certain features or select certain preferences, and some Cookies will always be used. You can find out more about each Cookie by viewing our current Cookie list below. We update this list periodically, so there may be additional Cookies that are not yet listed. Web beacons, tags and scripts may be used in the Site or in emails to help us to deliver Cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our service/analytics providers on an individual and aggregated basis.

Why do we use Cookies?

We generally use Cookies for the following purposes:

To recognize new or past customers.

To store your password if you are registered on our Site.

To improve our Site and to better understand your visits on our platforms and Site.

To integrate with third party social media websites.

To observe your behaviors and browsing activities over time across multiple websites or other platforms.

Some Cookies are necessary for certain uses of the Sites, and without such Cookies, we would not be able to provide many services that you need to properly use the Site. These Cookies, for example, allow us to operate our Site so you may access it as you have requested and let us recognize that you have created an account and have logged into that account to access Site content. They also include Cookies that enable us to remember your previous actions within the same browsing session and secure our Sites.

We also use functional Cookies and Cookies from third parties for analysis, marketing and security purposes. Functional Cookies enable certain parts of the site to work properly and your user preferences to remain known. Analysis Cookies, among other things, collect information on how visitors use our Site, the content and products that users view most frequently, and the effectiveness of our third party advertising. Advertising Cookies assist in delivering ads to relevant audiences and having our ads appear at the top of search results.  Security cookies, such as CAPTCHA, ensure that users are human. Cookies are either “session” Cookies which are deleted when you end your browser session, or “persistent,” which remain until their deletion by you (discussed below) or the party who served the Cookie.

How to disable Cookies?.

You can generally activate or later deactivate the use of Cookies through a functionality built into your web browser. To learn more about how to control Cookie settings through your browser:

Click here to learn more about how to clear, enable and manage Cookies in Chrome;

If you want to learn more about Cookies, or how to control, disable or delete them, please visit http://www.aboutcookies.org for detailed guidance. In addition, certain third party advertising your internet browsing. To learn more about this feature from Google, refer to their cookie information.

We may link the information collected by Cookies with other information we collect from you pursuant to this Privacy Policy and use the combined information as set forth herein. Similarly, the third parties who serve Cookies on our Site may link your name or email address to other information they collect, which may include past purchases made offline or online, or your online usage information. If you are located in the European Economic Area, you have certain rights that are described above, including the right to inspect and correct or delete the data that we have about you.                                                                          

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