SUYOOL SAL PRIVACY POLICY SUYOOL SAL, a joint-stock company validly existing under the laws of the Republic of Lebanon (“we”, “us”, “our” or “SUYOOL”), is committed to protecting and respecting your privacy and rights. SUYOOL complies with the Banking Secrecy Law of 3 September 1956 and its amendments ensuring the highest level of confidentiality for your financial information.

This Privacy Policy describes how your personal information is collected, used, and shared when you use and access our website, our application(s), or any services made available by us to our customers from time to time (collectively our “Platform”) or when you register for any type of account on our Platform (the “Privacy Policy”). We believe that you should know what personal data we collect and use, as well as understand your rights in respect of your personal data.

We urge you to read this Privacy Policy carefully before accessing or using our Platform. By downloading, accessing, or using any part of our Platform or registering for any type of SUYOOL account (corporate or personal) through it, or by using our services and/or any kind of functionality offered on our Platform (the “Services”), you are agreeing to be bound by this Privacy Policy. This Privacy Policy applies to natural persons who are our current or prospective customers or are authorised individuals or beneficial owners of legal entities, which are our current or prospective customers. As a user of our Platform, you may be referred to as “you”, “your(s)” or “User”.

Our Platform is not intended for use by minors, and we do not knowingly collect or store data relating to individuals under the age of 18.

For the purposes of the present Privacy Policy, the terms “personal data”, “data” and “personal information” are used to refer to any information relating to you that identifies or may identify you, either directly or indirectly, such as your name, address, occupation, income details, contact details, identification data (e.g. identity card/passport number), device information, payment information, authentication data and any other information that we may deem necessary to render the service sought. Moreover, the term “processing” is used herein to collectively refer to actions such as the collection, retention, use, disclosure, transfer, deletion or destruction of personal data.

For more information about this Privacy Policy, inquiries regarding our privacy practices, or to exercise any of your rights set out in this Privacy Policy, you may contact us at the following contact details:

Email: [email protected] Tel.
No.: +961 (0)1 290 900 or +961 81 484 000

We reserve the right to modify the terms outlined in this Privacy Policy at any time. In the event of such changes, we will inform you through multiple means via our Platform. Furthermore, if a particular change significantly affects your privacy, we may send you an email notification. This practice ensures that you have the opportunity to review and evaluate the modifications made. To stay up-to-date with any such revisions, we encourage you to periodically revisit this Privacy Policy.

Type of Personal Data	Details
Information you give us	We will collect and process the information you provide through our Platform such as: Identification Documents and Images, including numbers and copies of your identification documents as well as your image in photo or video form, as part of our Know-Your-Customer (KYC) checks, and any other information we ask you to give to comply with anti-money laundering laws, combat terrorist financing, and assist with fraud monitoring. Identity and Contact Information, including your name, surname, father’s name, mother’s name, date of birth, or similar identifier, phone number, email address, residency address, etc. This information is collected to register you on our Platform and provide access to your SUYOOL account and our Services. Personal Details, including gender, marital status, number of dependents, date of birth, place of birth, country of birth, citizenship, education level. Authentication Information, including signature, biometric data, usernames and passwords. Employment and Business Activity Information, including profession, employer’s name, job title, and employment address. Financial Profile Information, including income and expenses, assets and liabilities, financial history, and expected financial activity. Card details, including details of your debit cards and credit cards including the card number, expiry date and CVC2 (the three digits number on the back of the card).
Information collected from your use of our Platform, our Services and our products	Financial and Transaction Information, including your payment details and transaction information related to activities conducted through our Platform or through our card(s). This includes the date, time, amounts, currencies, exchange rates, beneficiary details, information about the merchants or ATMs involved in the transactions, IP addresses of sender and receiver, device details used for any transaction, and the payment method used. We collet this information to facilitate and process transactions securely and efficiently. Technical Information, including device identification number, IP address, login data, device type, network/browser data, time zone setting, geolocation, operating system etc. We collect this technical information to fulfil your requests, enhance the functionality of our Services, and ensure the security of our Platform. Commercial Information about your visit to our Platform, including the links you clicked on, through and from our website or application, services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (e.g., scrolls, taps and clicks), methods used to navigate away from the page, as well as information for marketing purposes and to use data analytic to improve our Platform and our customer services. Communication Information, when you communicate with us via email, chat, phone calls, video calls, etc.), more data is created and recorded (e.g. method of communication, date and time, content and outcome of our communication). We retain these records in our system, ensuring that we can provide you with optimum customer service and track customer service enquiries, requests, and comments.
Information collected from third parties and public sources	Third-party information, we gather information from third parties and publicly available sources, which includes the collection of personal data from entities that offer services through our Platform, such as merchants and agents, as well as other entities and partners who collaborate with us to enhance the delivery and security of our Services.

Information you give us

We will collect and process the information you provide through our Platform such as:

Identification Documents and Images, including numbers and copies of your identification documents as well as your image in photo or video form, as part of our Know-Your-Customer (KYC) checks, and any other information we ask you to give to comply with anti-money laundering laws, combat terrorist financing, and assist with fraud monitoring.

Identity and Contact Information, including your name, surname, father’s name, mother’s name, date of birth, or similar identifier, phone number, email address, residency address, etc. This information is collected to register you on our Platform and provide access to your SUYOOL account and our Services.

Personal Details, including gender, marital status, number of dependents, date of birth, place of birth, country of birth, citizenship, education level.

Authentication Information, including signature, biometric data, usernames and passwords.

Employment and Business Activity Information, including profession, employer’s name, job title, and employment address.

Financial Profile Information, including income and expenses, assets and liabilities, financial history, and expected financial activity.

Card details, including details of your debit cards and credit cards including the card number, expiry date and CVC2 (the three digits number on the back of the card).

Information collected from your use of our Platform, our Services and our products

Financial and Transaction Information, including your payment details and transaction information related to activities conducted through our Platform or through our card(s). This includes the date, time, amounts, currencies, exchange rates, beneficiary details, information about the merchants or ATMs involved in the transactions, IP addresses of sender and receiver, device details used for any transaction, and the payment method used. We collet this information to facilitate and process transactions securely and efficiently.

Technical Information, including device identification number, IP address, login data, device type, network/browser data, time zone setting, geolocation, operating system etc. We collect this technical information to fulfil your requests, enhance the functionality of our Services, and ensure the security of our Platform.

Commercial Information about your visit to our Platform, including the links you clicked on, through and from our website or application, services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (e.g., scrolls, taps and clicks), methods used to navigate away from the page, as well as information for marketing purposes and to use data analytic to improve our Platform and our customer services.

Communication Information, when you communicate with us via email, chat, phone calls, video calls, etc.), more data is created and recorded (e.g. method of communication, date and time, content and outcome of our communication). We retain these records in our system, ensuring that we can provide you with optimum customer service and track customer service enquiries, requests, and comments.

Information collected from third parties and public sources

Third-party information, we gather information from third parties and publicly available sources, which includes the collection of personal data from entities that offer services through our Platform, such as merchants and agents, as well as other entities and partners who collaborate with us to enhance the delivery and security of our Services.

The data we collect will always be handled with the utmost care and respect for your privacy. Our commitment to safeguarding your Personal Data is unwavering, and we will only share it with third parties when required by law or to provide our Services.

We collect and process your Personal Data in compliance with the Applicable Laws, including Law No. 81 dated October 10, 2018, relating to Electronic Transactions and Personal Data, to ensure its proper use for the following purposes:

- Fulfilling our contractual obligations: We will process your Personal Data to honour the agreements and contracts we have with you.

- Marketing and promotional purposes: we may also use your Personal Data for marketing and promotional purposes. This includes providing you with information about our products, services, promotions, special offers, and updates that we believe may be of interest to you. We will not share your Personal Data with third parties for marketing and promotional purposes but only use it within our organization.

- Providing our Services: In order to deliver our Services effectively, there may be instances where we require certain Personal Data without which we would be unable to fulfil your requests.

- Compliance with legal obligations: We are subject to various legal obligations and statutory requirements, as well as requirements of supervisory and/or regulatory authorities, such as the Central Bank of Lebanon (Banque du Liban). We have a legal duty to collect and store your Personal Data, and retain certain information even after you have requested its deletion. However, we will only retain the necessary data to meet our legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our agreements with you.

- Consent: Where you have provided your consent for the collection of your Personal Data, we will process it in accordance with the scope of your consent.

Your privacy and data protection are of utmost importance to us, and we are dedicated to safeguarding them. In the course of delivering our Services or when required by law, we may collaborate with trusted third parties and share your Personal Data with them. Rest assured that your data will only be shared with third parties who are bound by the same stringent privacy rules and standards that we adhere to.

Your data may be shared with various service providers and suppliers with whom we have contractual agreements. Additionally, we may disclose your personal information to other individuals and/or entities for the reasons described above, where we are legally obligated or otherwise authorized to do so, or when you have given us your explicit consent.

Recipients of your Personal Data include:

- Merchants;

- Agents;

- Financial institutions;

- Public and/or regulatory and/or supervisory authorities, and other public institutions, anti-fraud detection and prevention entities, law enforcement agencies, or courts;

- Technological and analytical service providers;

- Providers of customer support related services;

- Service providers and collaborators related to marketing and publicity, such as advertising agencies, advertising partners or social media outlets;

- Entities we work with for the provision of credit/debit card services (e.g., VISA and MASTERCARD), including the entities with which we cooperate for the issuance of our cards;

- Other third parties when you consent to such sharing.

Furthermore, it is possible that we may enter into transactions such as selling, transferring, or merging parts of our business or assets with third parties. Similarly, we may also consider acquiring other businesses or merging with them. In the event of such changes to our business structure, the new owners may utilize your Personal Data in the same manner as described in this Privacy Policy.

We hold a firm commitment to safeguarding the security and legality of your Personal Data, even when shared with third parties. We require that all third-party service providers respect the confidentiality and integrity of your Personal Data, handling it in strict accordance with the Applicable Laws.

We will retain your Personal Data for as long as your SUYOOL account is active or as needed to provide you with our Services and fulfil the purposes for which it was collected and processed. This includes complying with our legal and statutory obligations, as well as accounting and reporting requirements.

We will generally keep your Personal Data for a period of (10) ten years after our contractual relationship with you ends, or for the duration required by Applicable Laws.

To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of unauthorized use or disclosure, the purposes of processing, and whether we can achieve those purposes through other means.

In specific situations, such as when handling a complaint or anticipating litigation related to our relationship with you, we may retain your Personal Data for an extended period. Therefore, even after closing your SUYOOL account, we retain certain Personal Data to fulfil these obligations.

Additionally, there may be instances where we anonymize your Personal Data, rendering it no longer identifiable to you. In such cases, we may use the anonymized information indefinitely without further notice to you.

If you would like specific details regarding the retention periods for different aspects of your Personal Data, please contact us, and we will provide the necessary information.

We undertake to keep your Personal Data confidential and to use it for the purposes set out in this Privacy Policy as amended from time to time.

In addition, we may offer you the possibility to exercise your rights and setting your privacy preferences when using some of our services or visiting our Platform.

In particular, notwithstanding the purpose or legal basis we use to process your Personal Data, and to the extent provided by law, you are entitled to the following:

- To have access to the Personal Data we collected from you.

- To request us to rectify the Personal Data that we have available. This allows you to request corrections to any incomplete or inaccurate data we have in our records pertaining to you. We may require verification of the accuracy of any new data you provide to us in order to facilitate the necessary corrections. Please bear in mind that you shall be liable for any loss or damage caused to us or to any third party by providing erroneous, inaccurate or incomplete information.

- To request from us the deletion of your Personal Data to the extent that they are no longer necessary for the purpose for which we need to keep processing them, as explained herein, or when we are no longer legally permitted to process them. However, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

- To object to or restrict the processing of your Personal Data when we rely on legitimate interests (or the legitimate interests of a third party) and there are specific circumstances in which you believe that such processing infringes upon your fundamental rights and freedoms. Additionally, you have the right to object to the processing of your Personal Data for direct marketing purposes. However, it is important to note that there may be cases where we can demonstrate compelling legitimate grounds to continue processing your information. We will assess each objection on a case-by-case basis, taking into account the specific circumstances and applicable legal requirements.

- To withdraw consent, if you have given us your consent to process your Personal Data for any purpose, you also have the right to withdraw such consent at any time.

If you wish to exercise any of the rights set out above, please contact us.

We have implemented comprehensive security measures to protect your Personal Data from accidental loss, unauthorized access, alteration, or disclosure. Moreover, we restrict access to your Personal Data to only those employees, contractors, and third parties who require it for legitimate business purposes. They will handle your Personal Data strictly according to our instructions and are bound by confidentiality obligations.

In the event of any suspected Personal Data breach, we promptly address the situation and, where legally mandated, notify you and the relevant regulatory authorities of the breach. We take our responsibility to uphold data protection seriously and ensure compliance with the Applicable Law.

When browsing our website, we, and the third parties that provide content, functionality, or business services on through our website may use cookies to collect information about your activities. This information is used to provide you with more relevant content and promotional materials and help us understand your interests and improve our website.

It is important to be aware that our website utilizes persistent cookies to retain your confirmation of the Privacy Policy. Nevertheless, your consent will be required before employing cookies. You have the option to decline the use of cookies; however, doing so will result in restricted access to our website.

You can ask us to stop sending you marketing messages at any time through our application or by unsubscribing through the emails you receive from us.

If we change the way we use your Personal Data, we will update this Privacy Policy and, if appropriate, let you know by email, through our application or through our website.