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Privacy Policy

This Privacy Policy describes the way Gafa LLC ., a Maryland (USA) corporation doing business through our mobile phone application, Gafa, and its affiliates (collectively, “Gafa” or “us”) obtains, uses, stores, manages and disposes of certain information that you, as a user of our services, provide to us. You have certain rights, described below, to know what information we collect, how we use it, and how you may obtain and correct it.

Gafa first collects information about you and about the person to whom you are sending money (your “Beneficiary”) from the data you supply on the Gafa application (the “App”). When you provide information to Gafa, through the App or otherwise, you are warranting to Gafa that all of the information you provide to us about yourself and about your Beneficiary is accurate and complete. Gafa is relying on your warranty when Gafa provides the Service to you. The information you provide includes Personally Identifiable Information, which is defined as information that can be used, on its own or with other information, to identify you.

In addition to the information you provide, Gafa may have, or may obtain from third parties, information about you or your Beneficiary, some of which may be Personally Identifiable Information. More information about these third parties appears below. Gafa uses this information to provide its services to you, and to help protect you, the Gafa service, your Beneficiary and the general public from mistakes, fraud, money-laundering and other problems.

Collection of Information

The initial information we collect from you is the information that you provide to us on the Gafa App. This includes information about yourself, such as your full legal name, address, date of birth, telephone number, email address, last four digits of your social security number (if a U.S. Citizen), as well as other information and/or documentation that will allow us to verify your identify. You must also provide us with information about an approved payment source, when needed, such as your debit card, and information about your Beneficiary, which may include sensitive personal information such as your Beneficiary’s name, address, mobile phone number and/or bank account information. Gafa may also collect information from your mobile phone or other device from which you access the Gafa App, including your IP (Internet Protocol) address, operating system, device identification information, and other information associated with your access to and use of the App. Gafa may also collect information about the websites you have visited prior to accessing the Gafa service. Gafa may keep and store such information and associate it with your use, in order to help Gafa identify you and facilitate your use of our service in the future.

Gafa may verify and confirm all of the information that you provide to us (or that we otherwise collect from your accessing the Gafa App) with third parties, including the financial institution that issued the payment card you propose to use, when necessary, and the telecommunications company or financial institution through which your money is sent to your Beneficiary. Gafa may also verify such information with identify verification services, electronic databases, social media companies and credit reporting agencies.

Gafa may share your information with the banks, telecommunications providers and other financial services firms who facilitate payment to your Beneficiary. From time to time, Gafa may require you and/or your Beneficiary to provide us with additional information and/or documentation to confirm your identify and your eligibility to use the Gafa service.

When you access the Gafa app, Gafa may collect and store information regarding your use of the App and the service. This includes information about the frequency with which you access the App, the time you spend there, the way you move through the site, your transfer history, and details regarding the amount of money you transfer and your Beneficiaries.

If you contact us for any reason, whether by telephone, email, text or otherwise, Gafa may record and store communications that you have with us.

Use of Information

Gafa may maintain and use all of the information and documentation that you provide, as well as information that we derive from your use of the service, and the information that we obtain about you from third parties, in order to provide the Gafa service to you, and to enable Gafa to comply with laws and regulations, including those intended to prevent fraud, money laundering, and other abuses of the financial system. Gafa may use your information to contact you as necessary to confirm or complete a transaction, and to allow our agents, partners and service providers to fulfill their obligations in providing the Gafa service to you. Gafa may also use your information to improve our service, to troubleshoot problems, to develop new products and services, and to create advertising, marketing and promotional campaigns. (More information about Gafa’s use of your data for marketing and promotion is below.) Finally, Gafa may disclose your information to third parties, including government agencies, when Gafa reasonably determines that such disclosure is required by law, such as responses to subpoenas and information requests by law enforcement, financial services regulators or national security authorities.

Gafa will not sell, rent or otherwise disclose your information to third party marketers or others unaffiliated with Gafa for the purpose of advertising, promoting or selling other services to you. However, where and to the extent allowed by law, Gafa may work with third parties to analyze the information that we gather from you when you visit us on-line, including our website, our Facebook page, and our Facebook advertisements, whether or not you use the Gafa service. Gafa may use the information we gather there, along with the information we obtain from your use of our service, which may include Personally Identifiable Information, to advertise and promote Gafa services to you and to others. For example, Gafa provides data to Facebook’s Ad Manager account and SDK programs, which provide us with information about the ways customers and other visitors access, view and use the Gafa website and application. We use that information to create advertisements and promotions; such advertisements and promotions may appear in your Facebook feed or on other sites owned or operated by Facebook, such as Instagram. We may customize our marketing and promotional messages to you based on your use of our service, the information that you provide to us or which we otherwise obtain about you, and algorithms designed to help us anticipate your potential needs, based on your information and the information of others who use Gafa services. Gafa believes that such programs provide valuable information and benefits to our current and potential users. By accepting this Privacy Policy you are giving Gafa your consent to the use of your personal data for marketing and promotional purposes.

Protection of personal information collected by Gafa

Gafa’s leading security experts and practices help ensure that your Personally Identifiable Information is secure. All such information is stored on servers with state-of-the- art data protection technology, and is accessible only to Gafa employees who, for business purposes, need to access it. We use 128-bit encryption and encode your debit card information as soon as it is entered in the Gafa app, a process that overwrites your details so that they are unreadable by unauthorized parties.

No method of transmission over the internet, or method of electronic storage, is 100% secure, however. Although Gafa uses strong methods to protect the data that you provide to us, and we regularly test our information protection practices and technology, Gafa cannot absolutely guarantee its security. We will, however, notify you of any breach or other compromise that affects your data, promptly and in compliance with applicable law.

Gafa protects the data you provide us in accordance with the requirements of Law No. 2008-12 of 25 January 2008 on the protection of personal data and in accordance with the authorization of the Commission for the Protection of Personal Data (CDP).

Use of Cookies and other Tracking Devices

Gafa uses “cookies” and other tracking devices to help us recognize you, remember your preferences and facilitate your future transactions and other interactions with us. We also use such tracking devices to help us understand consumer behavior on our App, in order to help us improve it and make it easier for future use. You may be able to disable your device’s use of cookies, but that may slow or prevent your ability to use the Gafa service.

Your Right to Access and Correct Your Personal Information

You have the right to access your personal information stored by Gafa, subject to provisions of Law No. 2008-12 of 25 January 2008 and subsequent laws, and in accordance with relevant data protection regulations and Gafa’s policies intended to prevent fraud and other abuses of financial services. In order to do so, you can contact us at gafapay@gafa.com

. If the information Gafa has maintained about you is wrong, incomplete or otherwise inaccurate, you have the right to require Gafa to correct it or correct the information yourself directly in the App.

Destruction of Information

Gafa maintains information about each transaction for a ten (10) year term in accordance with the provisions of BCEAO Instruction N°008-05-2015 and subsequent laws and regulations. After that period, Gafa may destroy such information, and it will no longer be available to you or anyone else.

Privacy Policy Changes

Gafa’s privacy policy may change in the future. If that happens, the revised version will be posted on our website, www.gafapay.com

, and will be sent to current users via the email addresses associated with their Gafa App registrations.