Thawani Technologies LLC (“Thawani”) provides you with this privacy policy (“Privacy Policy”) to let you know Thawani’s information collection and usage policy and practices that apply to the information collected on Thawani’s website(s) including www.thawani.om (“Websites”) and/or on the mobile applications deployed by Thawani on the Device to access the Services, including electronic (mobile) wallet solution application, which facilitates you in making payments of the products obtained from the merchants by you through applications (computer programs) based on smart phones or other electronic devices (“Mobile Wallet Solution”). All the mobile applications provided by Thawani including Mobile Wallet Solution are hereinafter referred to as (“Mobile Applications”).

Thawani wants to make sure you understand what personal information Thawani collect about you and how Thawani uses it. Thawani understands the sensitive nature of your personal information as well as need to safeguard it. In the interest of safety and transparency, Thawani has put together this Privacy Policy that explains what types of information Thawani collects and the circumstances under which Thawani might share it.

At Thawani, we value your trust & respect your privacy. The Privacy Policy covers both online activities offered by Thawani on the Websites and/or on the Mobile Applications used by you on personal computers, mobile devices or otherwise electronic devices (“Device”) used to access the Services and also covers offline activities undertaken by Thawani such as collection of data through mailings, telephone, or in person and on activities owned, operated, provided, or made available by Thawani. Both online and offline activities are collectively referenced as the (“Services”). Additionally, The Privacy Policy also applies to your use of interactive features or downloads that: (i) Thawani own or control (ii) are available through the Services; or (iii) interact with the Services and post or incorporate the Privacy Policy.

By using the Website, Mobile Applications and the Services offered by Thawani, you agree to the terms of this Privacy Policy, to be bound by the users terms and conditions and expressly give us a consent to use and disclose your Personal Information in accordance with the Privacy Policy.

If you have questions about this Privacy Policy, please contact us through email address provided on the Websites and the Mobile Applications.

1. PERSONAL INFORMATION

Thawani only collects information about you that could reasonably be used to identify you personally (“Personal Information”). The Personal Information is relevant and required for the use of the Services and includes your name, e-mail address, mailing address and telephone number, browser type and internet protocol address, credit, debit, rewards, and other card information which may include card number, card issuer, card type (e.g., Visa), card expiration date, card security code, name of card holder, bank name, bank account number, bank account number and sort code, date of birth, social security number, demographic information, a password that you create, transaction history, mobile device type and a personal identification number that you create (“PIN”). It may be noted that Thawani might have to share your Personal Information to the payment processors and financial institutions when you make or accept a mobile payment ,which might also include the information in relation to amount, date, transaction description, names of the buyer and the seller and transaction location, last four digits of card used and authorization code issued by the card payment processor and/or financial institutions.

In addition to any Personal Information or other information that you choose to submit to Thawani, Thawani and/or the third party service provider (“TPSP”) may use a variety of technologies that automatically (or passively) collect certain information whenever you use the Services (“Usage Information”). This additional information may include the details of the browser that you are using, the URL that referred you to Thawani, IP address or other unique code identified for the Device which is automatically assigned to the Device (“Device Identifier”).

Thawani may also use cookies to enhance browsing of the Site. “Cookies” are small files or records that are placed on your Device’s computer’s hard drive to collect information about your activities on the Websites and/or Mobile Applications. It may be noted that the Usage Information may be collected using a cookie. If you do not want information to be collected through the use of cookies, your browser allows you to deny or accept the use of cookies. Cookies can be disabled or controlled by setting a preference within your web browser or on the Device. If you choose to disable cookies or flash cookies on the Device, some features of the Services may not function properly or may not be able to customise the delivery of information to you. Thawani cannot control the use of cookies (or the resulting information) by third parties, and use of third party cookies is not covered by the Privacy Policy.

We may, from time to time, supplement the information we collect about you through the Website and/or the Mobile Applications or through the use of the Services and from the information provided by third parties.
The Services of Thawani are primarily provided through the Mobile Applications. Thawani may collect and use technical data and related information, including but not limited to, technical information about the Device, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and information (if any) related to the Mobile Applications.
When you use the Mobile Applications it may automatically collect and store some or all of the following information related to you from the Device, in addition to the Device Identifier, including without limitation:

• your preferred language and country site (if applicable);

• the manufacturer and model of the Device;

• the Device operating system;

• the type of the internet browsers you are using;

• your geolocation;

• information about how you interact with the Mobile Applications and any of the Websites to which the Mobile Applications links, such as how many times you use a specific part of the Mobile Applications over a given time periods, the amount of time you spend using the Mobile Applications, how often you use the Mobile Applications, actions you take in the Mobile Applications and how you engage with the Mobile Applications; and

• information to allow Thawani to personalize the Services and content available through the Mobile Applications.

2. HOW THAWANI USES YOUR PERSONAL INFORMATION

Thawani may use the Personal Information to provide you with services & products you explicitly requested for, to resolve dispute, troubleshoot concern, help promote safe service, inform you about offers, products, services, updates, customize your experience, detect and protect us against error, fraud and other criminal activity, enforce our terms and conditions.

Based upon the Personal Information you provided to us, when registering for an account, we will send you a welcoming email to verify your username and password.
We use the information collected from the Mobile Applications and/or the Websites so that we are able to serve you the correct application version depending on the Device type, for troubleshooting and in some cases, marketing purposes.

We use your Internet Protocol (“IP”) address to help diagnose problems with our computer server, and to administer the Websites. Your IP address is used to help identify you, but contains no Personal Information about you.

Thawani will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if the Services are temporarily suspended for maintenance, we might send you an email. If you do not wish to receive them, you have an option to deactivate your account.

In addition, we may use the Personal Information or the Usage Information that we collect about you:
(i) to provide you with information or services or process transactions that you have requested or agreed to receive including to send you electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties;

(ii) to enable you to participate in a variety of the Services’ features such as online or mobile entry sweepstakes, contests or other promotions;

(iii) to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or the Services’ policies;

(iv) for internal business purposes;

(v) for inclusion in our data analytics; and

(vi) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

We may also use the information collected from you for targeted advertising. This involves using information collected on an individual’s web or mobile browsing behavior such as the pages they have visited or the searches they have made. The information collected is only linked to an anonymous cookie ID (alphanumeric number); it does not include any information that could be linked back to a particular person, such as their name, address or credit card number.

3. HOW AND WHEN DO THAWANI DISCLOSE INFORMATION TO THIRD PARTIES

We do not sell, share, rent or trade the information we have collected about you, other than as disclosed within this Privacy Policy or at the time you provide your information. Following are the situations when information may be shared:

(a) When you agree to receive information from third parties
You may be presented with an opportunity to receive information and/or marketing offers directly from third parties. If you do agree to have the Personal Information shared, the Personal Information will be disclosed to such third parties and all information you disclose will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review the privacy policies and practices of such third parties prior to agreeing to receive such information from them. If you later decide that you no longer want to receive communication from a third party, you will need to contact that third party directly.

(b) Third parties providing services on our behalf
Thawani use third party companies and individuals to facilitate the Services, provide or perform certain aspects of the Services on our behalf – such as design and/or operate the Services’ features, track the Services’ analytics, process payments, engage in anti-fraud and security measures, provide customer support, enable us to send you special offers, perform technical services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Services‘ features), or perform other administrative services. These third parties will have access to user information, including the Personal Information to only carry out the services they are performing for you or for us. Each of these third parties are required to ensure the data protection to us and are obligated not to disclose or use the Personal Information for any other purpose.

TPSP may set and access their own cookies, web beacons and embedded scripts on the Device and they may otherwise collect or have access to information about you.
Thawani use a third-party hosting provider who hosts support section of the Websites. Information collected within this section of the Website by such third party is governed by the Privacy Policy.

(c) Co-branded services
Certain aspects of the Services may be provided to you in association with third parties (“Co-Branded Services”) such as sponsors and charities, and may require you to disclose the Personal Information to them. Such Co-Branded Services will identify the third party. If you elect to register for products and/or services through the Co-Branded Services, you shall have deemed to consent to providing your information to both Thawani and the third party. Further, if you sign-in to a Co-Branded Service with a username and password obtained through the Services, the Personal Information may be disclosed to the identified third parties for that Co-Branded Service and will be subject to their posted privacy policies.

(d) Contests and promotions
Thawani may offer -promotions through the Services that may require registration. By participating in a promotion, you are agreeing to official rules that govern that promotion, which may contain specific requirements of you, including, allowing the sponsor of the promotion to use your name in advertising or marketing associated with the promotion. If you choose to enter a promotion, you agree that your Personal Information may be disclosed to third parties or the public in connection with the administration of such promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the promotion’s official rules, such as on a winners list.

(e) Administrative and legal reasons
Thawani cooperates with Government and law enforcement authorities to enforce and comply with the law. Thus, we may access, use, preserve, transfer and disclose your information (including the Personal Information, IP address, Device Information or geo-location data), to Government or law enforcement officials as we reasonably determine is necessary and appropriate: (i) to satisfy any applicable law, regulation, subpoenas, Governmental requests or legal process; (ii) to protect and/or defend the terms and conditions for online and mobile services or other policies applicable to any online and mobile services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of Thawani, the Services or any third party; (iv) to protect the safety of the public for any reason; (v) to detect, prevent or otherwise address fraud, security or technical issues; and /or (vi) to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity.

(f) When you share information

The Personal Information may be collected and shared with third-parties if there is content that you specifically and knowingly upload, share with or transmit to an email recipient, online community, website, or to the public, e.g. uploaded photos, posted reviews or comments, or information about you or your payment that you choose to share with others through features which may be provided by the Services. This uploaded, shared or transmitted content will also be subject to the privacy policy of the email, online community website, social media or other platform to which you upload, share or transmit the content.

(g) Business transfer

Thawani may share your information, including the Personal Information and the Usage Information with our parent, subsidiaries and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process.

4. THIRD PARTY CONTENT AND LINKS TO THIRD PARTY SERVICES

The Services may contain content that is supplied by a third party, and those third parties may collect the Personal Information, the Usage Information and the Device Identifier, when web pages from any online or mobile services are served to your browser. In addition, when you are using the Services, you may be directed to other sites or applications that are operated and controlled by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third parties. For example, if you click on a banner advertisement, the click may take you away from one of the Websites onto a different web site. These other web sites may send their own cookies to you, independently collect data or solicit the Personal Information and may or may not have their own published privacy policies. We encourage you to read the privacy statements of all third-party web sites or applications before submitting any of the Personal Information to third parties.

5. SOCIAL MEDIA FEATURES AND WIDGETS

The Service may include social media features, such as the “Facebook Like” button, and widgets such as a “Share This” button, or interactive mini-programs that run on the Services. These features may collect your IP address, photograph, which page you are visiting in relation to the Services, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Services. Your interactions with these features and widgets are governed by the privacy policy of the company providing them.

6. CHANGE OF INFORMATION AND CANCELLATION OF ACCOUNT

You are responsible for maintaining the accuracy of the information you submit to Thawani, such as your contact information provided as part of account registration. If your Personal Information changes, or if you no longer desire the Services contact us through email address mentioned on the Websites or on the Mobile Applications. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.

You may also cancel or modify your communications that you have elected to receive from the Services by following the instructions contained within an e-mail or by logging into your user account and changing your communication preferences.

If upon modifying or changing the information earlier provided to Thawani, we find it difficult to permit access to the Services to you due to insufficiency/ inaccuracy of the information, we may, in our sole discretion terminate your access to the Services by providing you a written notice to this effect on your registered email address.

If you wish to not use the Services or request that Thawani no longer use your information to provide you the Services, contact us through email address provided. We will retain the Personal Information and the Usage Information (including geo-location) for as long as your account with the Services is active and as needed to provide you the Services. Even after your account is terminated, we will retain the Personal Information and the Usage Information as needed to comply with our legal and regulatory obligations, resolve disputes, conclude any activities related to cancellation of an account, investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and for other business reason. After a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide the Services effectively, but our use of the anonymized data will be solely for analytic purposes.

7. SECURITY

Thawani shall take all precautions to maintain the confidentiality of personal and sensitive information / data pertaining to its customers/users and business associates by imparting proper training to its employees and by providing restricted access to persons who may require access to such data strictly on a need to know basis. Thawani maintains reasonable physical, electronic, and procedural safeguards to protect the security of the Personal Information. These safeguards include encrypted storage of some of the Personal Information and limiting third-party decryption of the Personal Information to that which is reasonably desirable or appropriate for Thawani, merchants, card issuers, payment processors, and Thawani contractors to provide the Services. Thawani uses firewalls and other security technology to protect its network and systems from external attack, and by requiring you to enter a unique username, password and PIN to access or update the Personal Information. All users must enter their PIN when confirming changes to their Personal Information or executing transactions. Merchants agree with Thawani to employ certain security measures and meet certain security standards, but Thawani cannot and does not warrant that merchants will do so. We cannot guarantee the security of our databases, nor can we guarantee that information you supply won’t be intercepted while being transmitted to us over the internet or wireless communication, and any information you transmit to Thawani you do at your own risk. We recommend that you not disclose your password to anyone.

8. UPDATES AND CHANGES TO THE PRIVACY POLICY

Thawani reserve the right to change the data privacy practices and update this Privacy Policy as and when the need arises, and the same will be made available on the Websites. But our commitment to protect the privacy of the Websites users will continue to remain. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review at this Privacy Policy for the latest information on the privacy practices.

9. CONTACT US

If you have any questions or comments about the Privacy Policy, please contact us at:
[email protected]