1. Information We Collect

• 1.1 Personal Information: We collect personal information that you provide directly to comply with the Iraqi government E-KYC regulation letter 10/10/9 issued by the Central Bank of Iraq on 10/01/2023, such as your name, contact details, your Iraqi national ID or non-Iraqi passport digital information, a selfie of you, and other relevant details necessary for providing our payment services and verifying your identity.
• 1.2 Device Information: We automatically collect information about the device you use to access the App, including the device model, operating system, and unique device identifiers.
• 1.3 Usage Information: We collect information about your use of the App, including transaction details, log information, and other data generated when you interact with our services.
• 1.4 Location Information: With your consent, we may collect and process information about your location to enhance the functionality of our services.

2. How We Use Your Information?

• 2.1 Identity Verification: We use your personal information to verify your identity. The verification process of your personal information is handled by three teams, Anti Money Laundry, Risk Management and Compliance. We may ask you to update your information if the information provided does not comply with the Iraqi government E-KYC regulation letter 10/10/9 issued by the Central Bank of Iraq on 10/01/2023.
• 2.2 Payment Processing: We use your personal information to process payments, facilitate transactions, and provide you with the services requested.
• 2.3 User Account Management: Your information is used to manage and maintain your user account, including account authentication, security, and customer support.
• 2.4 Improving Our Services: We analyze usage patterns and feedback to enhance and improve the functionality, security, and features of the App.
• 2.5 Communications: We may send you service-related communications, including updates, alerts, and account notifications.

3. Information Sharing

We may disclose your information to governmental institutions, national security entities, a court of law or payment networks to comply with applicable laws, regulations, or legal processes.

4. Security Measures

We employ industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. We apply highest security precautions to protect your information. When you submit sensitive information via the app, your information is protected both online and offline. Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.

5. Account Deletion

You can delete your account by following below steps:

• Go to Settings.
• In the Danger Zone section, choose Delete Account.
• Enter your username and reason for account deletion.
• A One Time Password (OTP) will be sent to the phone number associated with the user account and you will be redirected to the OTP verification screen.
• Enter correct OTP and submit.
• You will be automatically logged out of the application and your account will be deleted.

6. Data Retention

If you have deleted your account, we will retain your data for 5 years according to article 11 of chapter 5 of the Iraqi Anti-Money Laundering and Terrorist Financing law no. 39 of 2015, after which we will completely remove your information from our systems. We will use the retained data to respond to governmental institutions, national security entities, a court of law or payment networks such as MasterCard or VISA inquiring about you regarding financial transactions made using your payment cards.

7. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the updated Privacy Policy on the App or by other means.

8. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at info@aps.iq.