Privacy Policy

Mbongo Corporation. (“MBONGO”, “we”, “us” or “our”) is committed to protecting the privacy and confidentiality of personal information in our possession and control. This Privacy Policy explains the measures we take to fulfill these commitments and describes the manner in which MBONGO collects, uses, maintains, discloses and otherwise treats personal information of users (each, a “User”) of our website at www.mbongo.io and the MBONGO mobile application (collectively with all subpages and successor pages, the “Site”) as well as through other products and services offered by MBONGO (collectively the “Services”) and other interactions with our clients and prospective clients.

Your Consent:

By using the Site, registering for or obtaining a Service and/or providing us with personal information, you consent to the collection, use and disclosure of your personal information as described in this Privacy Policy. Capitalized terms that are used but not defined in this Privacy Policy have the meaning given to those terms in the MBONGO User Terms. In order to exercise any of your rights described herein you can contact us using the details in the “Contacting Us” section below.

Personal Information We Collect:

We collect personal information from Users directly, through their interactions with the Site and the Services, and through third parties, as described below.

We collect personal information from Users in a variety of ways, including, but not limited to, when Users visit or use our Site, register for or use a Service, and in connection with other activities, services, features or resources we make available on or through our Site. Users may be asked for, as appropriate, name, address, email address, telephone number, date of birth, government ID information, social insurance number, payroll provider, occupation, employer or other related organization, and banking or other account information.

Users may also provide us with other personal information when they contact us with questions, inquiries, complaints or suggestions. We also collect information about how Users use our Site and Services.

We also collect information about your use of our Services, including information about your transactions using your Card (such as transaction date, amount and location).

We may collect personal information from third party partners with User consent. For example, with your consent we may collect credit score and related information from credit bureaus.

If you create an account, you agree that we may verify your name, address, phone number, and other account details with information about you held by third party or publicly available sources (such as identity verification providers, fraud prevention services, government registries and your mobile service provider) in order to verify your identity and help protect against potential fraud, such as when someone other than you is trying to use your account or conduct a transaction without your permission, and you provide your consent for them to disclose and/or compare your information for this purpose. Your personal information will not be shared with these third parties for any other purpose.

Information we Collect Automatically through our Site:

We may collect information about Users whenever they interact with our Site. This information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information. We use this information to understand how Users interact with our Sites, and to make improvements.

Cookies and Similar Technologies. Our Site uses a technology called “cookies”. A cookie is a tiny element of data that the Site can send to your browser, which may then be stored on your hard drive so that you can be recognized when you return. We use cookies on the Site to enhance User experience and in order to deliver personalized recommendations, products and services. We also use cookies to provide us and our service providers with information about your use of the Site and other websites that we and they may use to personalize the Site or other content such as advertising in accordance with your interests and preferences (e.g. language preference) and improve your user experience. You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from the Site, you may not be able to take advantage of all of the features of the Site.

Tracer Tags & Web Beacons. The Site may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on the Site. These tracer tags are used to help us optimize and tailor the Site for you and other future visitors to the Site.

Online Advertising. We may use third parties to serve our advertisements on our Site or other websites. These companies may use cookies, tracer tags or web beacons to report certain information about your visits to our Site and other websites (such as web pages you visit and your response to ads) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant and tailored to you, both on and off our Site.

How we use Collected Information:

MBONGO may collect and use Users’ personal information for the following purposes:

  • To provide Services: We use information in order to register Users for a Service, to provide and administer our Services and to resolve any issues relating to a Service.
  • To process your application for a Card (including to verify your identity) and, if a Card is issued to you, to provide you with services relating to your Card (including to administer your Card and to process your Card transactions).
  • To respond to inquiries and provide and improve customer service: We use information to respond to a User’s inquiries, questions, and/or other requests. Information users provide helps us respond to customer service requests and support needs more efficiently
  • To personalize user experience: We may use the information we collect to personalize a User’s experience when they visit or use the Site or Services. We may also use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site
  • To improve our Site: We may use the information we collect, including feedback Users provide, to improve our Site and Services.
  • To run a promotion, contest, survey or other Site feature: We use information to administer contests, promotions, surveys and other Site features.
  • For marketing purposes: We may use personal information in order to better understand our User’s needs and preferences in order to provide them with information and offers that we believe may be of interest to them. We may provide information and offers by any means, including by e-mail, in-app notifications, push notifications, SMS and display advertising. Users may opt out of having their personal information used for these purposes by contacting us as described below.
  • For research and analytics: We may use the information we collect to generate aggregate or de-identified data, which is not capable of identifying any particular User. We may use aggregate and de-identified data for any lawful purpose, including research and analytics.
  • For our other reasonable business purposes: We may use information to detect and prevent fraud, for legal compliance purposes, to enforce our agreements with Users and to maintain business records. We may also use information for other purposes with User consent or as permitted or required by law.

How We Protect Your Information:

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Users’ personal information. Personal information is maintained on our servers or those of our service providers and is accessible to authorized employees, representatives and agents who require access in connection with their job responsibilities.

Your online access to certain of your personal information is protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages). If we learn of a breach, we will inform you and the appropriate authorities of the occurrence of the breach in accordance with applicable law.

Sharing your Personal Information:

We may disclose personal information to third parties (including outside of Canada) as necessary to provide the Services that a User has requested.

We may disclose personal information to third parties, such as identity verification providers, fraud prevention services, government agencies and mobile service providers, in order to verify your identity, contact information and account details, as described in the Personal Information We Collect section above.

We may disclose your personal information and payment history to credit bureaus for the purposes of updating and maintaining the information in their records.

We may use service providers to perform specialized services on our behalf such as data hosting or processing services, banking, payment processing services, research, marketing and analytics, customer service, digital support or mail distribution. Our service providers may at times be responsible for processing personal information. They are provided only the information necessary to perform the service. In addition, we require them to protect the information in a manner that is consistent with our Privacy Policy and security practices.

We may disclose personal information in connection with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of MBONGO or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. Assignees or successors of MBONGO or our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Policy.

We may disclose personal information in other circumstances with User consent or as permitted or required by law, including as required by foreign laws applicable to us, our affiliates and service providers.

We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.

We may transfer personal information we collect about you to jurisdictions other than the jurisdiction in which the information was originally collected and your personal information may be processed and stored outside of your jurisdiction of residence, including outside of Canada. Those jurisdictions may not have the same data protection laws as your jurisdiction of residence and your personal information may be subject to applicable foreign laws. If we transfer your personal information to other jurisdictions, we will protect that personal information in the manner described in this Privacy Policy.

Business Transactions:

If we enter into a business transaction involving personal information or are considering one, such as selling assets, we may share personal information securely with the other parties to the transaction, for example, as part of due diligence or when we complete the transaction. Accordingly, we may transfer information we have about you in connection with a prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of MBONGO or as part of financing, a corporate reorganization or stock sale or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.

Your Choices:

You may withdraw your consent to our collection, use and disclosure of personal information at any time, by contacting us as described in the “Contacting us” section below. Please note that your right to withdraw consent is subject to contractual and legal restrictions and reasonable notice. If you withdraw your consent, certain functionality of the Site may not be available to you and we may not be able to provide you with certain Services.

You may ask us to close your account by using the “Cancel Account” button in our mobile application. Please see the User Terms for additional information about account cancellation.

You may ask that we not use your personal information for marketing purposes by contacting us as described in the “Contacting us” section below or by using a unsubscribe feature found within our marketing communications, where applicable. Please note that if you ask us not to use your personal information for marketing purposes, you may still see certain types of ads from us (for example, online), but these will not be tailored to your interests.

Children’s Privacy:

Our Site is not directed to children under the age of sixteen and we do not knowingly collect information from children under the age of sixteen on our Site. If we become aware that we have inadvertently received information from a visitor under the age of sixteen on our Site, we will delete the information from our records.

User Submitted Content:

Users may be able to submit reviews, content and other information and materials that users have created through our Site and through third party social media platforms. ANY OPINIONS EXPRESSED IN ANY SUCH USER SUBMITTED CONTENT ARE SOLELY THOSE OF THE USERS THAT SUBMITTED THE CONTENT AND DO NOT NECESSARILY REFLECT THE OPINIONS, POLICY OR POSITION OF MBONGO . USERS ASSUME ALL RISKS ASSOCIATED WITH SUCH CONTENT, INCLUDING, BUT NOT LIMITED TO, ANY THIRD PARTY’S RELIANCE ON ITS QUALITY, ACCURACY, OR RELIABILITY, OR ANY DISCLOSURE OF INFORMATION IN YOUR USER CONTENT THAT MAKES YOU OR OTHERS PERSONALLY IDENTIFIABLE. YOU HEREBY AGREE THAT MBONGO HAS NO RESPONSIBILITY OR LIABILITY WHATSOEVER FOR ANY SUCH ACTIVITIES. YOU ALSO AGREE AND UNDERSTAND THAT YOUR USER CONTENT IS NOT SPONSORED OR ENDORSED BY MBONGO, AND YOU WILL NOT IMPLY THAT YOUR USER CONTENT IS IN ANY WAY SPONSORED OR ENDORSED BY MBONGO .

Third Party Websites:

Our Site may contain links to other websites that we do not own or operate. Also, links to our Site may be featured on third party websites on which we advertise. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

Safeguarding Credit Card Information:

We protect personal and credit card information in our possession or control from loss, theft, alteration and misuse. The safeguards employed by us to protect your personal information depend on the sensitivity, amount, distribution, format and storage of the personal information. Although technologies can make it easier for fraud to occur, we employ around-the-clock monitoring systems and controls to detect and prevent fraudulent activity. We also build fraud prevention measures into our due diligence processes and regularly update our fraud detection/prevention methods. While we take precautions to protect your personal information from loss, theft, alteration, or misuse, no system or security measure is completely secure. Any transmission of your personal information and credit card information is at your own risk and we expect that you will use appropriate measures to protect this information as well.

Retaining Your Personal Information:

We will retain personal information for as long as reasonably necessary to perform the Services you have requested, protect our Site and Services and related systems from fraud or other unlawful activity, meet our legal obligations, and protect and enforce our legal rights. If you withdraw your consent to our processing of your personal information or cancel your account, we will no longer use or disclose your personal information to provide the Services, but we may retain your personal information as necessary for the purposes noted above.

Changes to our Privacy Policy:

MBONGO may update or change this Privacy Policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about we handle personal information. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Your continued use of the Site or Services following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting Us:

You may request access to or correction of your personal information in our custody or control, by writing to the address below, attention Chief Security Officer. Our Chief Security Officer is responsible for the protection of personal information. Your right to access or correct your personal information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections. If you have any questions about this Privacy Policy, or our personal information handling practices generally, please contact us at:

MBONGO

www.mbongo.io

privacy@bongopay.cd

This document was last updated on August 20, 2023.