Privacy Policy

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1. Introduction

Firstcom Global Payments S.A.is committed to protecting the privacy of the information of those who use our Services and Apps. 

This privacy policy describes how Firstcom collects, uses, shares and protects users' personal data, in accordance with applicable legislation, in particular Law No. 213-450 of 19 June 2013 on the protection of personal data.

By visiting our website or using our mobile application and/or providing your personal information, you agree that Firstcom may collect, use and disclose your personal information as described in this Privacy Policy. 

2. Data Collected

Firstcom collects information when you use our Apps. For example, we collect data when you purchase or receive an e-gift card or we collect data when you contact our customer service. We only collect as much information as we need for specific, identified purposes.

· Personal Data : When you purchase or receive a gift card, you will be asked to provide certain personal information, such as your name, email address, phone number, or similar information. This information is collected to enable the processing of your order. We may also automatically collect personally identifiable information when you use the Apps with Facebook or Google. Some of the information we receive is required to set up your account and send your gift. You may choose not to use Facebook or Google with our Apps, and you may also choose not to provide certain personally identifiable information, but then you may not be able to take advantage of the services provided by our Apps.

· Sensitive data: Identification information (ID number), biometric data (fingerprints, facial recognition). Financial information (payment card number, transaction history). We do not store your credit card number, this information is transmitted directly to our payment gateway provider for the purpose of processing your payment.

· Cookie Information : When you visit our Apps, we may send one or more cookies (a small text file containing a string of alphanumeric characters) to your computer. Firstcom uses both session cookies and persistent cookies. A persistent cookie remains after you close your browser and can be used by your browser on subsequent visits to the sites. These persistent cookies can be deleted, but every web browser is a little different. Please consult your browser's "Help" file to find out how to properly change your cookie settings. We do not link the information we store in cookies to any personally identifiable information you submit on our site.

· Information Collected Automatically : When you use our Apps or open one of our emails, we automatically record certain data using technology, including "clear GIFs" or "web beacons," cookies (see above), IP addresses, and unique "device identifiers" (similar to IP addresses). "Automatically collected" data includes the type of web browser, the website that referred you to us, the web pages you viewed on our Apps, and the dates and times you visited our Apps.

· Customer-Provided Information : When Firstcom administers promotions or other services for a customer (a business or organization to which Firstcom provides business services), certain personal information is also shared in order to process the activity of creating and redeeming gift cards on behalf of that customer. The use of personal information shared with us by our customers is also subject to the terms mentioned in this Privacy Policy.

· Gift Card Recipients. When you choose to use our services to send a gift card to someone, you represent that you have their consent to provide us with their name, email address, and/or mobile phone number. We will automatically send the gift card recipient a mobile email or text message or WhatsApp message informing them of the gift card received. Unless we are authorized by your friend, we will only use your friend's name, email address and/or mobile phone number for the purpose of sending this email and reminder emails for the use of gift cards and keeping a log of your friend's activity.

3. Use of personal data

We use the data collected to:

· To provide the services subscribed to by the user, such as the issuance of digital gift cards and virtual payment cards;

· Manage customer relationships, including responding to inquiries and providing technical support;

· Comply with legal and regulatory obligations, such as KYC (Know Your Customer) and Anti-Money Laundering and Anti-Terrorist Financing procedures;

· Analyze and improve the services offered by Firstcom, including by conducting market research and statistical analysis;

· Prevent and detect fraud, using data to identify suspicious activity and take appropriate action;

· Personalize the user experience, using data to provide offers and promotions tailored to each user's needs and preferences;

· Communicate with users, sending them information about Firstcom's products and services, as well as relevant newsletters and notifications;

· Troubleshoot problems, resolve disputes, enforce our agreements with you, including our Terms and Conditions and this Privacy Policy;

· Respond to any official request from duly authorized public or judicial authorities.

4. Sharing Collected Information

Firstcom may share the information collected and personal data in specific circumstances for the performance of services essential to the provision of our services, in accordance with applicable regulations.

With Third Parties:

· Our affiliates, created or to be created;

· External service providers contracted with us for the development of financial applications and technologies, the provision of technical and hosting infrastructures such as Amazon Web Services, the performance of payment services, identity verification and compliance of the customer file, communication and messaging services;

· Our banking partners; 

· Financial, Judicial and Regulatory Authorities;

· Any other parties involved in transactions such as merchants.

For operational reasons:

· To support audit, compliance and corporate governance functions;

· To assess and manage risks;

· To prevent fraud.

5. Transfer and Retention of Personal Data

The personal data collected is mainly processed and stored in Côte d'Ivoire. However, it may be processed and kept by Firstcom's technical partners for the performance of their contractual obligations, in the ECOWAS zone or outside the ECOWAS zone in countries offering the same guarantees and protection in terms of the protection of personal data, in accordance with the regulations in force. 

6. Data security

Firstcom is committed to protecting the personal data you share with us. We use a combination of industry-standard technologies, procedures, and organizational security measures to help protect your personal data from unauthorized access, use, or disclosure.

· We strive to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts the information you input.

· We only reveal the last four digits of your credit/debit card numbers when confirming an order. Of course, we pass on the entire credit/debit card number to the respective credit/debit card company when processing the order. We do not store this information in our Apps.

· It is important that you protect yourself from unauthorized access to your password and computer. Be sure to log out when you're done using a shared computer.

· If you use the Apps with Facebook, be sure to sign out of Facebook or through the Apps (which will also log you out of Facebook) if you are using a shared computer.

7. Retention Period

Personal data is retained for ten (10) years, in accordance with applicable laws and regulations, operational requirements, as well as the needs of preserving legal rights or responding to requests from regulatory bodies.

8. Rights of access to your data

Users have the following rights in accordance with the law:

· Right of access and rectification of data;

· Right to erasure of data;

· Right to restriction of data processing;

· Right to object to data processing.

Because our goal is to give you simple and meaningful choices about your information, most of the choices available to you are built right into the app, on our website, or in your settings. For example, you can:

· Change personal information, i.e. name and mobile number in your profile at any time.

· Choose not to disclose information, even though it may be necessary to take advantage of or register for certain features of the Apps.

· In some cases, if you refuse to share personal information, we will not be able to provide you with certain services. You may also choose to unsubscribe from future marketing by following the unsubscribe instructions in the emails we send you.

· You can contact us to exercise these rights by sending an email to the following address: compliance@firstcomglobalpayments.com 

9. Firstcom Global Payments SA Employee Data

Personal data of Firstcom employees is collected and used in connection with human resources management, including recruitment, performance and compensation management, and compliance with legal labor obligations.

10.Precautions for the Protection of Personal Data

Firstcom takes appropriate technical and organizational measures to protect personal data from unauthorized access, disclosure, alteration or destruction. Firstcom employees are required to respect the confidentiality of personal data and are trained in good data protection practices.

11.Legal references

This policy complies with Law No. 213-450 of 19 June 2013 on the protection of personal data, as well as any other relevant data protection legislation.

12.Changes to this Privacy Policy

This Privacy and Personal Data Use Policy is effective immediately upon publication and is subject to periodic review to ensure compliance with legislative and regulatory developments, as well as best practices in data protection. If we make any changes to this Privacy Policy or the way we use personal information, we will notify you by posting an announcement on our website or by sending you an email. By continuing to use our Apps, you are bound by any changes to the Privacy Policy each time you use our Apps after the first posting of such changes.

13.Contact Us

If you have any questions or concerns about how your information is handled, please contact us by email at: compliance@firstcomglobalpayments.com.