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Privacy Policy Purpose

The purpose of this policy is to outline and describe the manner in which we handle the privacy of our customers at COWPAY. We reserve the full right of amending and/or updating this Privacy Policy, from time-to-time, to meet the recent practices of privacy and the updated laws. By establishing this policy, COWPAY aims to create a standardized, reliable, and secure environment that should smooth our business operations and Your experience through the Platform. This Policy explains your privacy rights regarding how we collect, use, disclose, share, protect and safeguard your Personal Data (as defined below) when you visit our Platform or use our payment gateway.

For the purpose of using this Privacy Policy, for the avoidance of any doubt, the following definitions should be applied:

• “Cookies” cookies are files with small amount of data, which might include an anonymous unique identifier. Cookies are sent to Your browser from our Platform and stored on Your computer's hard drive.

• “Employee” means, any employee of COWPAY or any of its affiliates, sister company(ies) and parent company(ies).

• “COWPAY” or “We” means, COWPAY, a Limited Liability company duly incorporated under the laws of the Arab Republic of Egypt under the commercial register No. 14220 and whose address is Capital Business Park, Building 4, 4th floor, Sheikh Zayed, Giza, Egypt or any of its affiliates or sister companies.

• “Personal Data” means, your information and/or data that might enable COWPAY to identify your personality and that are required to enable COWPAY to provide You with its services, to the extent stipulated under the Egyptian Personal Data Law.

• “Platform” means, https://cowpay.me that is owned, managed, and operated by COWPAY.

• “Policy” means, this Privacy Policy for customers that explains how COWPAY handles any customer, whether personal or juristic person’s Personal Data which gathered in its operations as it currently exists or as it existed or amended by the sole discretion of COWPAY at any time during which any Personal Data was collected or processed in connection with the operations.

Privacy policy Scope

This Policy between COWPAY and You constitute our commitment to Your privacy on our Platform. It is designed to provide information regarding our privacy practices and help you understand how we handle your Personal Data. We retain Personal Data in an identifiable format for at least 365 days for our business purposes and to fulfil our legal or regulatory obligations. We may retain Personal Data for longer periods if it is in our legitimate business interests and required to comply with applicable laws and practices. We will continue to use and disclose such Personal Data in accordance with this Privacy Policy.

Security Standards

If there any exception request for a specific point in this policy. This request will pass through internal exception process for COWPAY, and You will be informed through any means of communication with such exception. Such exception to this policy must be approved by the security team within COWPAY in advance and you will be informed with such details of such exception request and its purpose within four days as it is approved by the security team.

Privacy Policy

• This Privacy Policy is effective as of being posted on the Platform and your registering and creating an account on or using/accessing the Platform through Your account, you hereby acknowledge that:
1. You have read, understood, and accepted this Privacy Policy, as amended from time-to-time and any other applicable policies governing and regulating the Platform, including, but not limited to, this Privacy Policy, and irrevocably and unconditionally agree to comply with and be bound by them, in relation to Your use of the Platform
2. You have the legal capacity in accordance with the Egyptian law to accept and be bound by this Privacy Policy and any other applicable policies governing the Platform, including, but not limited to, this Privacy Policy.

• We reserve all the rights, at our sole discretion, to update and/or amend this Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the service provided by COWPAY through the Platform and/or accessing the Platform before and/or after we implement any updates and/or amendments to the Policy would constitute your acknowledgment and approval to this Privacy Policy, as amended from time-to-time and Your consent to abide and be bound by the Privacy Policy. If We implement any material updates and/or amendments to this Privacy Policy, we will notify You either through the email address provided to COWPAY, or by placing a prominent notice on the Platform.

• We use our customers Personal Data to a reasonable extent for the provision of our services. You acknowledge and agree to the collection and use of Your information in accordance with this Privacy Policy and applicable laws.

• While Your usage to the Platform, we may ask You to provide us with certain personally identifiable information that could be used to contact or identify You. Personally identifiable information may include, but is not limited to, Your Personal Data, your computer's Internet Protocol ("IP") address, browser type, browser version, the pages of our Platform that You visit, the time and date of the visit, the time You spent on those pages and other statistics. In addition, we may use third party services such as Google Analytics that collect, monitor, and analyse this. You, irrevocably, acknowledge and accept the usage of third-party(ies) services in the provision of our services.

• You, irrevocably, acknowledge and agree that we use "cookies" to collect information. You could be able to instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do so, you might not be able to use some portions of our Platform.

• COWPAY is committed to secure Your data and keep it confidential at all times. COWPAY has been doing all in its powers and authorities to prevent data theft, unauthorized access, and disclosure by implementing the latest technologies and software as applicable and acceptable with the Egyptian laws, which help us safeguard all the information We collect online.

• We, hereby, confirm that all credit and/or debit cards details, and personally identifiable information would not be stored, sold, shared, rented, or leased to any third parties.

• Some of the advertisements You might see on the Platform are selected and delivered by third parties, such as ad networks, advertising agencies, advertisers, and audience segment providers. These third-party(ies) might collect information about You and Your online activities, either on the Platform or on other websites, through Cookies, web beacons, and other technologies in an effort to understand Your interests and deliver to your advertisements that are tailored to Your interests. You acknowledge and agree that We do not have access to, or control over, the information these third parties may collect. If You click on a third-party link and/or advertisements, you might be directed to that website, and those external websites are not operated by COWPAY. Therefore, COWPAY assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services or any whatsoever type of illegal actions that You might be exposed to. You acknowledge and understand that Your use of the third-party(ies) links and websites is at Your own risk, and that COWPAY makes no warranties about the accuracy, integrity, safety, or legality of the content available thereon.

Payment

You understand that use of the services provided by COWPAY would result in charges. All charges are due within the moment of receiving the services, you hereby acknowledge and agree to pay the charges to COWPAY and authorize COWPAY to deduct the same during the process of the transaction. You agree and acknowledge that COWPAY shall have the full right, at its sole discretion to amend the charges from time-to-time.

Personal Data Protection

• Without prejudice to COWPAY’s Privacy Policy, you explicitly agree and authorize COWPAY to possess, collect, transfer, cross boarder transfer, store and process Your Personal Data provided by You during the provision of our services. This is to enable COWPAY to provide You with a better service and create a safer environment for its customers. We will retain Your Personal Data for as long as We can for the same purposes.

• You authorize and hereby unconditionally agree to receive communications from COWPAY in any form (including push notifications, calls, SMS, emails, etc.) for the purpose of confirming Your transaction, if any and required. In the event that You no longer want to receive communications from COWPAY, you shall notify COWPAY of Your non-acceptance, and COWPAY may cease or limit sending any communications upon Your request, to the necessary extent.

• You agree to provide true, current, and complete information, and in the event that COWPAY has reasonable grounds to suspect that any of Your Personal Data is untrue, inaccurate, not complete, or there was any abuse of service by any means from You; then COWPAY should have the full right to suspend or terminate Your account and prohibit any and all current or future use of COWPAY’s Platform.

• Your personal data should not be retained for a duration longer than that necessary for the fulfilment of the purpose therefrom and we would erase any Personal Data at our possession upon the satisfaction of the designated purpose in case of retention of such Personal Data for any legitimate reason and if such Personal Data should be retained, we would do it in a form that does not allow for identification of Your personality.

• Upon our knowledge of the occurrence of breach to personal data handled by us, we would inform the Data Protection Centre (the “Centre”) in accordance with the Egyptian applicable laws including, inter alia, the Egyptian Personal Data Law. You acknowledge and agree that the following information should be shared with the Centre or any competent authority:
  • 1. A description of the nature of the breach, its form, reasons, and the approximate number of personal data affected and their records.
  • 2. The information of the relevant data protection officer, if any.
  • 3. The potential consequences of the breach.
  • 4. A description of the procedures taken or proposed to be taken in order to address the breach and limit its negative consequences.
  • 5. Documenting any breach or violation of personal data and the rectification procedures undertaken to address the breach
  • 6. Providing any documents, information or data requested by the Center.

Liability

• You further agree and acknowledge that COWPAY should not be liable to You or to any third-party for any of the following:
  • 1. Damages, or harm from any kind that results from Your access or use of the Platform.
  • 2. Any interruption in communication to or from the Platform.
  • 3. Any bugs, viruses transferred through the Platform.

• You shall defend and hold COWPAY and its affiliates, employees, agents, shareholders, and directors harmless against any claim, action, demands, expenses, and damages, whether actual or consequential of every kind and nature, known and unknown, suspected and unsuspected, disclosed and undisclosed, arising out of or in any way connected with Privacy Policy, your use of the Platform, violation of any laws or regulations and any misleading information/data You may provide, at any time.

• You hereby acknowledge and agree to indemnify COWPAY, its affiliates and employees from and against all losses, damages, costs (including, but not limited to, reasonable legal and other professional fees) expenses any other liabilities incurred by or awarded against COWPAY, its affiliates or its employees in this regard.

• You hereby release COWPAY, its officers, employees, agents, and successors from any and all claims, demands and damages (actual and consequential) of every kind or nature, known or unknown, suspected, and unsuspected, disclosed, and undisclosed, arising out of or in any way related to Your use of the Platform.

Termination

• You hereby acknowledge and understand that COWPAY may close Your account, restrict Your use permanent or temporarily or cancel Your registration at any time without providing any reasons, at its sole discretion, for the purpose of termination for convenience.

• You hereby agree and accept that COWPAY shall have the right to cancel Your registration or close Your account, without the need of any further notices, legal proceedings, or judicial actions, in the following events:
  • 1. You rendered insolvent
  • 2. You commit a material breach with respect to its obligations under this Privacy Policy and fail to rectify same within one day from receiving notice, by any means of communication, of the breach from COWPAY.

Relationship between Parties

The relationship arising from this Privacy Policy between You and COWPAY does not constitute or create a partnership, joint venture, agency, employment, or fiduciary relationship of any kind. Further, this Privacy Policy of Use do not create any agency relationship between COWPAY and You.

Assignment

You hereby understand that this Privacy Policy is personal to You and that You should not assign or transfer or sub-contract or purport to assign or transfer or sub-contract to any other person any of Your rights or obligations under this Privacy Policy without the obtention of COWPAY’s prior written consent. COWPAY shall have the right to assign, sub-contract or transfer to any of its affiliates, sister companies, parent companies or related parties any of its rights or obligations under this Privacy Policy at its sole discretion without any need for prior written consent.

Waiver

No delay or omission by COWPAY to exercise any right or power occurring upon any non-compliance or default by You with respect to this COWPAY of Use shall impair any such right or power or be construed to be a waiver of right. A waiver by COWPAY hereto of any of the covenants, or conditions, to be performed by the other/s should not be construed to be a waiver of any succeeding breach thereof or of any covenant or condition herein contained. The failure of COWPAY to assert a right or enforce an obligation shall not be deemed a waiver of such right or obligation. No waiver by COWPAY for any default of the other under this Privacy Policy shall be considered as a waiver of any further default whether of like or different character. Any waiver, in order to be valid, should be in writing.

Governing Law and Dispute Resolution

This Privacy Policy is governed by and construed according to the laws of the Arab Republic of Egypt. Any controversy, claim or dispute arising out of or relating to This Privacy Policy, or the breach, termination, enforcement, interpretation, or validity thereof shall be finally settled by the competent courts in Cairo.

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