Privacy Policy

1. Understanding Our Privacy Policy

By accessing and using our services, you affirm that you have read and understood how we collect personal data, why we do so, and the legal basis for such collection. If you are not comfortable with any aspect of this Privacy Policy, you should not access our Services. We do not use your Personal Data for automated decision-making.

We reserve the right to modify this Privacy Policy at any time. In the event of material changes, We will notify you by email or through in-app notifications.

2. Personal Data

Personal Data means any information that identifies you or can be used to identify you, directly or indirectly. This includes information you voluntarily provide to us, as well as information we may obtain from our affiliates, service providers, or other third-party partners.

This Privacy Policy does not apply to anonymised data, which is data that has been irreversibly de-identified such that it cannot reasonably be used to identify you. You may be required to provide Personal Data when you interact with Roqqu Technologies, including when you use our products or services, contact our support teams, or access our platforms.

3. Lawful Basis For Processing

We only process Personal Data where we have a lawful basis for doing so, such as the following:

1. i.where processing is necessary to provide our Services or perform a contract with you;
2. ii.where we need to comply with a legal or regulatory obligation;
3. iii.where you have given consent (where required);
4. iv.where processing is necessary to protect your vital interests or those of another person;
5. v.where processing is necessary for reasons of public interest; and
6. vi.where processing is necessary for our legitimate interests, provided those interests are not overridden by your fundamental rights.

4. Personal Data Collected

This section details the Personal Data we may collect from you. We explain why we collect your Personal Data. If you decide to create an account or enquire about our Services, we'll ask you to provide us with some specific onboarding information.

We collect the following types of Personal Data:

1. i.Personal Identification Information: full name, date of birth, age, nationality, gender, utility bills, phone number, home address and/or email, and formal identification documents.
2. ii.Financial Information: estimated income range (where required), bank account information, bank statements where necessary, proof of funds, source of wealth, and other financial information we consider necessary.
3. iii.Transaction Information: Information about the transactions you perform through our platforms, such as the name of the recipient, your name, the amount, and/or timestamp.
4. iv.Contact Data: billing address and delivery address.
5. v.Contacts List and Address Book Information: Where you choose to grant us permission, we may access your device contact list to enable you to select recipients. We use this information only to facilitate transactions for your intended recipients. You may withdraw this permission at any time through your device settings.
6. vi.Employment Information: Office location, job title, and/or description of role.
7. vii.Online Identifiers and Location Data: Geolocation and/or personal IP addresses.
8. viii.Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
9. ix.Usage Data: survey responses, information provided to our support team, public social networking posts, authentication data, security questions, and other data collected via app cookies and similar technologies.

5. How Your Personal Data Is Used

Our primary purpose for collecting Personal Data is to provide you with a secure and efficient Service. We also use Personal Data to create, develop, operate, deliver, and improve our Services, content and advertising, as well as for loss prevention and anti-fraud purposes. We may use your Personal Data in the following ways:

1. i.to verify your identity in accordance with Know Your Customer (KYC), Anti-Money Laundering (AML) and sanctions screening requirements;
2. ii.to enforce our terms in our user agreement and other agreements
3. iii.to manage and maintain your account with us;
4. iv.to prevent fraudulent or unauthorised use of our products and services;
5. v.to better manage our business and your relationship with us;
6. vi.to improve our products and services, and to develop new products and services;
7. vii.to notify you about benefits and changes to the features of our products and services;
8. viii.to send you relevant updates, product information, and marketing communications;
9. ix.to respond to your inquiries and to resolve disputes; and
10. x.Where necessary to protect our legal rights and interests or the interests of others, we also use Personal Data in relation to legal claims, compliance, audits, risk management and regulatory functions.

6. Data From Third Party Sources

From time to time, we may obtain Personal Data about you from third-party sources as required or permitted by applicable law, such as identity verification providers, fraud monitoring partners, and compliance screening partners.

7. Collection and Use of Personal Data Collected Automatically

The Qash App may use app cookies and similar technologies to recognise your device and enhance your experience when using the App. Cookies are small data files stored on your device that allow the App to remember certain information about your interactions and preferences.

As the Qash App operates as a mobile application, we may also use similar technologies such as software development kits (SDKs), mobile device identifiers, local storage, and analytics tools to collect information about how the Qash App is accessed and used. These technologies help us operate, maintain, and improve the performance, security, and functionality of the Qash App, analyse usage patterns; and enhance the overall user experience.

Through these technologies, we may automatically collect certain technical information about the device you use to access the Qash App, including your device model, device identifiers, operating system and version, application version, Internet Protocol (IP) address, mobile carrier, and general location information such as country or city-level location.

We may also collect information about how your device interacts with the Qash App, including the features or screens accessed, links clicked, session activity, and device event information such as application crashes, system activity, and hardware settings. This information helps us diagnose technical issues, understand how users engage with the Qash App, and improve our Services.

Identifiers may also be used to recognise your device when you access the Qash App through external links or referral sources from third-party platforms.

8. How We Share Your Personal Data

We may, from time to time and only as strictly necessary, share your Personal Data with third parties to provide our Services, operate our business, comply with legal obligations, or protect our rights.

We do not share your Personal Data with third parties for their own direct target marketing purposes.

9. How We Protect and Store Personal Data

We understand how important your privacy is. Roqqu Technologies maintains (and requires its service providers to maintain) appropriate physical, technical, and organisational safeguards designed to protect the security and confidentiality of the Personal Data you entrust to us.

We may store and process your Personal Data (including personal and transactional data) in locations where we or our service providers maintain facilities. Where Personal Data is processed outside your country of residence, we take reasonable steps to ensure that appropriate safeguards are in place in accordance with applicable laws and regulations.

We protect your Personal Data by maintaining physical, electronic, and procedural safeguards, including measures such as firewalls, encryption, and access controls. We restrict access to Personal Data to authorised personnel who require it to perform their job responsibilities.

Where payment card information is processed, full card data is securely transmitted to and hosted by a third-party service provider in compliance with the Payment Card Industry Data Security Standards (PCI DSS). We do not store full payment card details, and such information is not accessible to our staff.

Despite the safeguards we have implemented, no method of transmission over the Internet or method of electronic storage is completely secure. As a result, we cannot guarantee absolute security against loss, misuse, unauthorised access, disclosure, alteration, or destruction of Personal Data.

You also play an important role in protecting your Personal Data. When creating an account, you should choose a strong password, keep it confidential, and notify us immediately if you suspect any unauthorised access to or use of your account.

Please note that we cannot guarantee the security of Personal Data transmitted to us via the Internet or wireless communications (including email, phone, or SMS) once it leaves your device and until it reaches our systems. If you have reason to believe that your Personal Data is no longer secure, please contact us immediately via our support channels.

10. Account Closure

If you close your account, we will mark your account in our database as "Closed", but we will keep your account information in our database in accordance with this Privacy Policy and applicable law. This is necessary in order to deter fraud by ensuring that people who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new one. However, your Personal Data will not be used by us for any further purposes nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

11. Rights In Relation to Use of Your Personal Data

This section describes your rights. You have the following rights:

1. i.right to request access to and rectification or erasure of your Personal Data;
2. ii.right to restrict processing or object to processing of your Personal Data;
3. iii.right to data portability;
4. iv.right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal; and
5. v.right to lodge a complaint with the relevant authority.

In the event that you wish to exercise your rights, please reach out via email at legal@roqqu.com

You will not be charged a fee to exercise your legal rights. However, we may charge a fee if your request is excessive, repetitive, and unreasonable. We may refuse to comply with your request where there is a legal justification for such refusal.

12. Retention of Personal Data

We store your personal Personal Data securely throughout the life of your account. We will only retain your Personal Data for as long as permissible under applicable laws and only to fulfil the purposes for which we collected it, including to comply with AML/CFT obligations, resolve disputes, enforce our agreements, and comply with regulatory requirements.

13. Children's Personal Data

We do not provide Services to people under 18. If it is determined that a user submitting Personal Data is younger than 18 years of age, we will close or restrict such an account and will not allow the user to continue transacting. We will also take steps to delete the Personal Data as soon as possible. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent access to our Services.

14. Global Company

In the event that we need to transmit your Personal Data outside the jurisdiction where you reside (e.g., for utilising the subprocessors' services and technical infrastructure), the transmission shall be in accordance with the requirements, principles and safeguards as stated in the applicable data protection laws, such as relying on adequacy decisions issued by or approved standard contractual clauses or compliance with applicable data transfer accountability requirements.

Contact

If you have any questions, requests or clarifications, or wish to exercise your legal rights, You may reach out via email at legal@roqqu.com