Effective from: 01 June 2021
This Privacy Notice describe how PaySky Inc, its respective subsidiaries, affiliates, associated companies, brands and jointly controlled entities (collectively “PaySky”, ”Yalla”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of Yalla’s VPOS mobile applications and websites (respectively “Apps” and “Websites”), as well as products, features and other services globally, operated by PaySky directly or under its Yalla brand name (collectively, “Services”).
This Notice applies to our consumers, agents, vendors, suppliers, partners (such as driver and merchant partners), contractors and service providers (collectively “you”, “your” or “yours”).
“Personal Data” is any information which can be used to identify you or from which you are identifiable. This includes but is not to Egypt.
We collect Personal Data about you in the ways listed below. We may also combine the collected Personal Data with other Personal Data in our possession. If you have or are a party to multiple relationships with us (for example if you use our Services across our various business verticals, or if you are both a driver partner/delivery partner as well as a consumer to our Apps or on our other business verticals), we will link your Personal Data collected across your various capacities to facilitate your use of our Services and for the Purposes described below.
You provide your Personal Data to us
We collect your Personal Data when you voluntarily provide it to us. For example, you may provide your Personal Data to us when you:
- complete a user profile or registration forms (such as your name, contact information and other identification information where needed);
- interact with our social media pages (such as your social media account ID, profile photo and any other publicly available data);
- participate in contests or events organised by us (such as the pictures, audio files, or videos you may submit, which may include images of yourself);
- verify your identity through various means (such as social media logins, submission of selfie images or independently verified payment card information);
- fill up demographic information in surveys (such as your age, gender, and other information you may volunteer such as your marital status, occupation and income information); and
- agree to take a ride with in-vehicle audio and/or video recording features.
In certain circumstances, you may need to provide your Personal Data in order to comply with legal requirements or contractual obligations, or where it is necessary to conclude a contract. Failure to provide such Personal Data, under such circumstance, may constitute failure to comply with legal requirements or contractual obligations, or inability to conclude a contract with you, as the case may be.
For purposes such as detection and prevention of fraud, we may also collect your Personal Data without consent, by relying on Legitimate Interests or other exemptions provided by the applicable data privacy laws.
When our services are used
Personal Data may be collected through the normal operation of our Apps, Websites and Services. Some examples are:
- your location (to detect pick-up locations and abnormal route variations);
- feedback, ratings and compliments;
- transaction information (such as payment method and distance travelled);
- information about how you interacted with our Apps, Website or Services (such as features used and content viewed);
- device information (such as hardware model and serial number, IP address, file names and versions, and advertising identifiers or any information that may provide indication of device or app modification);
- personal data you enter in messages when you use our in-app communication features; and
- personal data that may be captured through your interaction with us, our agents, in-vehicle audio and/or video recording during a ride (such as your image or voice or both, and its related metadata).
From other sources
When we collect Personal Data, including but not limited to your name, contact information and other identification information where needed from other sources, we make sure that that data is transferred to us in accordance with applicable laws. Such sources include:
- referral programmes;
- our business partners, such as fleet partners, payment providers, ride-hailing partners and transport partners;
- insurance and financial providers;
- credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;
- publicly available sources of data;
- governmental sources of data;
- when our users add you as an emergency contact;
- when you use our in-app chat; and • marketing services providers or partners.
Personal Data about driver partners
If you are a driver partner, we may collect:
- telematics data (such as your speed, acceleration, and braking data);
- device data (such as accelerometer data, GPS location, your IMEI number and the names of apps you have installed on your device);
- your vehicle registration data; and
- personal data that may be captured through your interaction with us, our agents, our in-vehicle audio and/or video recording during a ride (such as your image or voice or both, and its related metadata).
Sensitive Personal Data
Some of the Personal Data that we collect is sensitive in nature. This includes Personal Data pertaining to your race, national ID information, religious beliefs, background information (including financial and criminal records, where legally permissible), health data, disability, marital status and biometric data, as applicable. We collect this information only with your consent and/or in strict compliance with applicable laws.
Personal Data of minors
As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to Yalla. In the event that such Personal Data of a minor is disclosed to Yalla, you hereby consent to the processing of the minor’s Personal Data and accept and agree to be bound by this Notice and take responsibility for his or her actions.
When you provide Personal Data of other individuals to us
In some situations, you may provide Personal Data of other individuals (such as your spouse, family members or friends) to us. For example, you may add them as your emergency contact or when you use the in-app chat. If you provide us with their Personal Data, you represent and warrant that you have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Policy.
II. USE OF PERSONAL DATA
Paysky or Yalla may use, combine and process your Personal Data for the following purposes (“Purposes”):
Providing services and features
Your Personal Data will be used to provide, personalise, maintain and improve our Apps, Websites and Services. This includes using your Personal Data to:
- provide you with Services across our various business verticals;
- engage you to provide Services;
- create, administer and update your account;
- conduct due diligence checks and risk assessments / analysis;
- verify your identity;
- verify your age (where necessary);
- validate your ride and process payments;
- offer, obtain, provide, facilitate or maintain insurance or financing solutions;
- track the progress of your trip and detect abnormal trip variations;
- enable features that personalise your App, such as lists of your favourite places and previous destinations;
- make your experience more seamless, such as automatically filling in your registration information (such as your name or phone number) from one Service to another Service or when you participate in our surveys;
- perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends;
- protect the security or integrity of the Services and any facilities or equipment used to make the Services available;
- process and manage your rewards;
- enable communications between our users;
- process, manage or verify your eligibility for or application of promotions, rewards and subscriptions with Yalla;
- enable our partners to manage and allocate fleet resources; and
- fulfil the services to you as a data processor, where you have provided consent to the data controller (i.e. the organisation you had purchased goods or services from, and for whom Yalla is providing services on behalf of) for such services to be rendered.
- Obtain your phone contacts in order to identify who are other Yalla customers in your contact list in order to allow you to send and receive money and get notifications from them.
Safety and security
Yalla support or Yalla care
We use Personal Data to resolve user support issues. For example, we may:
- investigate and address concerns;
- monitor and improve our user support responses;
- respond to questions, comments and feedback; and
- inform you about steps taken to resolve user support issues.
Research and development and security
We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our Services, develop new features, products and services, and facilitate insurance and finance solutions.
We may use the Personal Data we collect to investigate and resolve claims or disputes, or as allowed or required by applicable law. We may also use Personal Data without consent, by relying on Legitimate Interests or other exemptions provided by the applicable data privacy laws, for purposes such as detection and prevention of fraud. We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority. For example, we may use your Personal Data to:
- comply with court orders or other legal, governmental or regulatory requirements;
- enforce our Terms of Service or other agreements; and
- protect our rights or property in the event of a claim or dispute.
We may also use your Personal Data in connection with mergers, acquisitions, joint ventures, sale of company assets, consolidation, restructuring, financing, business asset transactions, or acquisition of all or part of our business by another company.
Marketing and promotions
We may use your Personal Data to market Yalla and Yalla partners’, sponsors’ and advertisers’ products, services, events or promotions. For example, we may:
- send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
- notify, invite and manage your participation in our events or activities.
We may communicate such marketing to you by post, telephone call, short message service, online messaging service, push notification, by hand and by email. If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, please click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our App settings.
III. DISCLOSURE OF PERSONAL DATA
We need to share Personal Data with various parties for the Purposes. These parties include:
- If you opted for a transfer of funds to a different user or a merchant we will share the necessary data to facilitate the transfer between you and the selected user.
- If you use our in-app chat service, we may share your mobile number and Yalla-registered name with the other parties to your chat.
With third parties
We may share your Personal Data with the following parties:
- If you are a passenger of driver partners, we may share a vehicle’s location and driver’s and/or your name with third parties when you use the “Share My Ride” feature or activate the Emergency Button.
- If you are a driver-partner, we may rely on Legitimate Interests or other exemptions provided by the applicable data privacy laws to disclose your vehicle plate number or other personal data to the insurance company and/or to your passenger for the purpose of submission of insurance claim.
With Yalla partners at your request
For example, if you requested a service through a Yalla partner or used a promotion provided by a Yalla partner, Yalla may share your Personal Data with that Yalla partners. Our partners include partners that integrate with our App or our App integrates with, delivery services partners, or business partners which Yalla collaborates with to a service, deliver a promotion, competition or other specialised service.
With the owner of Yalla accounts that you may use
For example, your employer may receive your usage data when you use your employer’s Yalla for Business account.
With Yalla’s service providers and business partners
We may provide Personal Data to our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This includes:
- payment processors and facilitators;
- credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;
- background check and anti-money laundering service providers;
- cloud storage providers;
- marketing partners and marketing platform providers;
- data analytics providers;
- research partners, including those performing surveys or research projects in partnership with Yalla or on Yalla’s behalf;
- fleet and merchant partners;
- insurance and financing partners;
- third party intermediaries involved in the managed investment of funds, such as brokers, asset managers, and custodians;
- service providers who perform identity verification services; and
- delivery solutions partners, vendors or third-party B2B or B2C delivery suppliers.
With our legal advisors and governmental authorities
We may share your Personal Data with our legal advisors, law enforcement officials, government authorities and other third parties. This may take place to fulfil the legal purposes (mentioned above), or any of the following circumstances:
- where it is necessary to respond to an emergency that threatens the life, health or safety of a person; or
- where it is necessary in the public interest (e.g. in a public health crisis, for contact tracing purposes and safeguarding our community).
IV. RETENTION OF PERSONAL DATA
We retain your Personal Data for the period necessary to fulfill the Purposes outlined in this Notice unless a longer retention period is required or allowed by law. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to erase, destroy, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Notice , or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.
VI. COOKIES AND ADVERTISING ON THIRD PARTY PLATFORMS
Additionally, we may share non-personally identifiable Personal Data with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising.
Disabling the collection of cookies on our websites You may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser.
VII. PROTECTION OF PERSONAL DATA
We will take reasonable legal, organisational and technical measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from getting lost, or used or accessed in an unauthorised way. We limit access to your Personal Data to our employees on a need to know basis. Those processing your Personal Data will only do so in an authorised manner and are required to treat your information with confidentiality.
Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through any online means, therefore, any transmission remains at your own risk.
VIII. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA
In accordance with applicable laws and regulations, you may be entitled to:
- ask us about the processing of your Personal Data, including to be provided with a copy of your Personal Data;
- request the correction and/or (in some cases) deletion of your Personal Data;
- in some cases, request the restriction of the processing of your Personal Data, or object to that processing;
- withdraw your consent to the processing of your Personal Data (where we are processing your Personal Data based on your consent);
- request receipt or transmission to another organisation, in a machine-readable form, of the Personal Data that you have provided to us where we are using your Personal Data based on consent or performance of a contract; and
- complain to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered as a result of unlawful processing of your Personal Data.
Where you are given the option to share your Personal Data with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. However, choosing not to share your Personal Data with us or withdrawing your consent to our use of it could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Section II (Use of Personal Data) or that you are unable to make use of the Services. After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.
If you wish to make a request to exercise your rights, you can contact us through our contact details set out in Section X (How to Contact Us) below.
We will screen and verify all requests beforehand. In order to verify your authority to make the request, we may require you to provide supporting information or documentation to corroborate the request. Once verified, we will give effect to your request within the timelines prescribed by applicable laws.
IX. AMENDMENTS AND UPDATES
PaySky and Yalla may modify, update or amend the terms in this Notice at any time. Such amendments shall be notified to you through the Application and/ or other appropriate means at least five (05) business days before the effective date. The updated version will be posted on the website https://yalla.online. It is your responsibility to review the Privacy Notice regularly. Your continued use of the Apps, Websites or Services, purchase products from Yalla or continuing to communicate or engage with Yalla following the modifications, updates or amendments to this Notice , whether or not reviewed by you, shall constitute your agreement to be bound by such amendments.
X. HOW TO CONTACT US
If you have any queries about this Notice or would like to exercise your rights set out in this Notice , please contact our Data Protection Officer at:
PaySky Data Protection Officer
c/o PaySky Inc.
Villa 41, Banafseg 1,
New Cairo, Cairo, Egypt
The original of this Notice is written in the English language. In the event of any conflict between the English and other language versions, the English version shall prevail.
ADDENDUM 1: Yalla FOR BUSINESS
II. YALLA’S RELATIONSHIP WITH USERS AND CLIENTS
How Yalla for Business works
Yalla for Business is a business line directed to facilitate corporate services like payroll, employees’ health insurance, payment acceptance, cash in/out services and delivery solutions When an organisation (“Client”) chooses to utilise Yalla for Business, the Authorised User is given the option of manage the account, payroll, insurance options and other transactions to the Client or its employees onboarded as Yalla users. As part of this feature, Yalla will disclose relavant information that Authorised Users have tagged as being for business purposes to the Client. Apart from this, Yalla does not disclose other Personal Data of its Authorised Users to the Client. For ease of reference, Authorised Users and individual users will each be referred to as a “User” and collectively as “Users” in this Addendum.
Yalla is a data controller, so are our Clients
In respect of any User and the processing of all their Personal Data (including but not limited to Linking Data and Portal Data), Yalla acts as a data controller. For further information on how Yalla collects, uses and discloses Users’ Personal Data, please refer to the Yalla Privacy Notice .
Due to the way Yalla for Business works, Yalla does not process any Personal Data for and on behalf of the Client. Accordingly, Yalla is not the data processor of the Client, but an independent data controller in respect of all Personal Data that it processes in the course of providing the Yalla for Business feature. Likewise, the Client is an independent data controller of the Personal Data (e.g. the Linking Data and Portal Data) that it discloses to and/or receives from Yalla.
III. WHAT PERSONAL DATA IS COLLECTED, PROCESSED AND DISCLOSED
What Yalla collects as part of Yalla for Business
In order to provide the Yalla for Business feature, the individual user or the Client will be required to provide the following information about the Authorised User to Yalla:
- full name;
- business email address;
- Mobile Number;
- National ID; and
- other identifying information about the Authorised User as reasonably requested by Yalla. Yalla will use this information for the purposes of:
- authenticating the User;
- where applicable, linking the Authorised User’s account with the Client’s Yalla for Business account or tracking the Authorised User’s business profile bookings on the Apps, as the case may be;
- where applicable, verifying the Corporate Billing status of such Authorised User from time to time; and
- contacting the User in accordance with the purposes set out in the Yalla Privacy Notice . Upon onboarding such User to the App, Yalla will process the Personal Data of the User in accordance with the Yalla Privacy Notice and this Addendum.
What Yalla discloses to its Clients
Yalla will disclose relevant payroll and insurance information as determined by Yalla from time to time to the Client to facilitate Corporate services.
IV. PARTIES’ OBLIGATIONS
The Client and Yalla shall each:
- individually inform their data subjects of how each processes Personal Data and allow their data subjects to exercise their rights under the local data protection/data privacy laws;
- comply with the obligations applicable to each party under the applicable data protection/data privacy laws when processing any Personal Data of the Proposed or Authorised Users;
- obtain the necessary consents (if applicable) to facilitate the provision of the Yalla for Business feature; and
- implement appropriate legal, technical and organisational measures to protect Personal Data against unauthorised or unlawful processing and against unauthorised loss, destruction, damage, alteration, or disclosure, as well as any breach or attempted breach of each party’s security measures (“Information Security Incident”).