Privacy Policy

1. Introduction and Consent
1. Introduction and Consent
1.1 This Privacy Policy describes the manner in which Flash and its affiliates (collectively “Flash”, “we”, “us” or “our”) collect, store, protect, use, share and process your personal information through the Flash App (including all its related sub-domains, sites and tools) and the Service. The term “personal information” means personally identifiable information which can be associated with a specific individual and can be used to ascertain the identity of the individual in question. Flash collects personal information from you when you access and use the Flash App and the Service (including, without limitation, when you register as a user, create an account on the Flash App, and when you use the the Flash App to pay for purchases made from Eligible Sellers in accordance with the Customer Agreement and other Flash App policies).
1.2 By accessing and using the Flash App and the Service and by providing Flash with your personal information, you are expressly consenting to the procedures and practices described in this Privacy Policy and to Flash collecting, processing, protecting, using and sharing your personal information in accordance with the terms of this Privacy Policy.
1.3 This Privacy Policy may be updated and amended by Flash at any time at its sole discretion. Without prejudice to the provisions of Section 4 (Updating the Privacy Policy) of this Privacy Policy, amendments introduced by Flash will become effective upon the earlier of posting the amendments to the Flash App or otherwise communicating them to you. Your continued use of and access to the Flash App and the Service will constitute your express consent to Flash continuing to collect, store, protect, use, share and process your personal information in accordance with the terms of the updated/amended Privacy Policy. Flash encourages you to check the Flash App regularly for the announcement of any amendments to our Privacy Policy.
1.4 You understand and agree that you are solely responsible for reviewing the Customer Agreement and this Privacy Policy and all other policies posted to the Flash App.
1.5 In this Privacy Policy, terms not defined herein shall have the meanings given to them under the Customer Agreement.

2. Information Collected by Flash
2.1 Flash collects your personal information for the purposes set out under Section 3 (Purposes for Which Flash Collects, Stores, Uses, Shares and Processes Your Personal Information) of this Privacy Policy and in order to provide and continually improve the Flash App and the Service provided thereby.
2.2 The types of personal information collected from you by Flash include, but shall not be limited to, the following:
2.2.1 Information Collected upon Registration and Account Creation: We receive and store any information you provide when creating an account/registering with the Flash App. As part of your registration with the Flash App, you will be requested to provide us with certain personal information, including, but not limited to, the following:
your name (first name and last name); email address (which may be subject to verification by Flash at its sole discretion); mobile number; address; gender; valid proof of identification (e.g. in the form of a national ID card or passport); and some additional information about you such as your date of birth or other identifying information as may be requested by Flash.
2.2.2 Payment Instrument Information: As part of your registration with the Flash App and prior to your use of the Service, you will be prompted to provide us with payment instrument information including but not limited to the following: (1) your credit card/debit card details, (2) details of any other eligible payment method accepted by Flash and (3) any other information related to the relevant debit/credit card and/or payment method (if any).
2.2.3 Contacts Information. In order to provide you with the Service, you can choose to let us access your phone contacts information to make it easier for you to make bill payments on behalf of others or to provide other personalized services. You can update your settings to stop sharing your phone contacts with us at any time.
2.2.4 Automatically Collected Information: We automatically collect and store certain types of information about your use of and access to the Flash App, including transactional information and such other information about your interaction with and use of the Flash App and the Service.
2.2.5 Other automatically collected information include, but shall not be limited to, the following:
Device Identifiers:
We collect device-specific information, including, but not limited to, device type, operating system version, browser type and version, and the mobile network being used on the device through which you are accessing the Flash App. Device identifiers shall be associated with Your Flash Account on the Flash App.
Device Location Information:
Depending on your device’s permissions, if you access or use the Flash App, we automatically collect and process information about the actual location of the device being used to access the Flash Platform. We use various technologies to determine the device’s location, including your device’s location API.
You may opt out of our access to your device’s location information through disabling and/or denying the Flash App’s access to your device’s location, although doing so may render certain features of the Flash App unavailable to you.
User Activity and Login Data:
We collect data in relation to user login to and use of the Flash App and the Service. Information/data collected by Flash in this respect include, but shall not be limited to:
a) your login information (including your email address, Your Credentials, registration and account creation date, and records of successful and unsuccessful login attempts);
b) details of transactions concluded and purchases paid for by you through the Flash App;
c) records of amounts credited to Your Flash Account in the form of cashback or rewards
arising from your use of the Service and/or your invitation of new users to the Flash App;
d) records of the Eligible Sellers with whom you have previously transacted through the
Flash App;
e) the internet protocol (IP) address used to connect your computer/device to the internet;
f) your internet service provider (ISP);
g) your device’s time zone settings;
h) date and time stamp of each of your visits to the Flash App;
i) navigation information; and
j) device metrics such as when a device is in use, application usage, connectivity data, and
any errors or event failures.
Cookies and Similar Technologies:
Like many mobile applications and websites, we use "cookies" technology and other unique identifiers to store your preferences. “Cookies” are text files with small pieces of data (such as a username and password) that are transferred to your browser or device and that are used to identify your computer/device as you use a computer/device network. Cookies allow us to obtain certain types of information (including, but not limited to, your browsing history, your preferences, and your username) when your web browser or device accesses the Flash App. We use cookies to enhance your experience on the Flash App by remembering your preferences. The cookies we use do not reveal any personal information about you.
For further information on our cookies policy, please refer to Section 8 (Cookies) of this Privacy Policy.
2.2.6 Information from Other Sources: We might receive additional personal information about you from other third-party and/or public sources, including financial institutions, banks and government institutions and/or other public bodies.

3. Purposes for Which Flash Collects, Stores, Shares, Uses and Processes Your Personal Information
3.1 We collect, store, use, share and process your personal information for, amongst other things, the following purposes:
3.1.1 providing you with access to the Flash App;
3.1.2 providing the Service to you and enabling you to make contactless payments using
the Payment Services;
3.1.3 transmitting of payment instructions in order to enable the processing of payments
which you authorize or initiate using Your Flash Account;
3.1.4 enabling you to make payments to Eligible Sellers using transaction specific QR
Codes and any other payments using the Payment Services;
3.1.5 providing customer support to you;
3.1.6 providing you with records and details of payments made by you through the Flash
App;
3.1.7 allowing for personalization and offering you better services and products;
3.1.8 offering you services which are relevant to your location;
3.1.9 measuring and improving our Service and your use of and access to the Flash App;
3.1.10 analyzing user trends and improving the administration of the Flash App and the
Service;
3.1.11 preventing illegal activities, fraud and spam activities as well as providing you with
a safe and secure platform;
3.1.12 ensuring compliance with legal and/or regulatory obligations;
3.1.13 making disclosures to law enforcement agencies, government agencies or other third
parties where we are compelled so to do by court order or similar legal procedure; where we are required to disclose your personal information to comply with law; where we are cooperating with an ongoing law enforcement investigation or where we have a good faith belief that our disclosure of your personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate a possible violation of the Customer Agreement, other agreements; or protect the rights, property, or safety of Flash, our users or others;
3.1.14 preforming and implementing the Customer Agreement, this Privacy Policy and other policies posted by Flash on the Flash App;
3.1.15 troubleshooting problems;
3.1.16 understanding how users use the Flash App and the Service;
3.1.17 performing fraud detection;
3.1.18 improving the Flash App and the Services
3.1.19 taking legal action or other procedures; and
3.1.20 providing you with promotional and marketing emails and verifying information
you give us.

4. Updating the Privacy Policy
4.1 You acknowledge and agree that Flash shall endeavor to give you notice for any amendment to this Privacy Policy which materially increases your obligations or decreases your rights under this Privacy Policy ("Substantial Amendment") in accordance with the terms of this Privacy Policy. You acknowledge and agree that Flash, at its sole discretion and without liability, may make amendments that are not Substantial Amendments without your further specific consent at any time with immediate effect by posting a notice of the amendment on the Flash App.
4.2 If you do not agree to be bound by the amended/updated Privacy Policy please delete Your Flash Account and do not access, register with or continue to use the Flash App. Your continued use of and access to the Flash App will constitute your express consent to the terms of the amended/updated Privacy Policy.

5. Accessing, Reviewing and Amending Your Personal Information
5.1 You can access, review and modify your personal information on the Your Flash Account section of the Flash App. If your personal information changes in any way, is incorrectly presented on the Flash App, or is outdated, incomplete, inaccurate or misleading in any way you must immediately update or correct your personal information (as applicable) by accessing the Your Flash Account section of the Flash App or, alternatively, by contacting Customer Support.
5.2 The information and data we collect about you in accordance with this Privacy Policy may be stored and processed inside as well as outside the Arab Republic of Egypt on secure servers. We shall retain your personal information during and following the end of your use of the Flash App and the Service as required: (a) to fulfil the purposes for which the information was collected as set out under this Privacy Policy; (b) to comply with law and regulation; (c) to comply with accounting and auditing requirements; (d) for technical troubleshooting requirements; (e) to prevent fraud; (f) to assist in any legal investigations; and (g) to take legal or any other actions otherwise permitted by law.

6. Entities with whom We Will Share Your Personal Information
6.1 We share users’ personal information collected in accordance with this Privacy Policy with subsidiaries and/or affiliates of Flash and with such other third parties as may be necessary to achieve the purposes set out under Section 3 (Purposes for Which Flash Collects, Stores, Uses, Shares and Processes Your Personal Information) of this Privacy Policy. You hereby acknowledge and agree that we may share your personal information as follows:
6.1.1 Payment Processing Entities: We may, at our sole discretion, employ duly licensed entities to undertake (1) the processing of payments made using the Flash App and (2) the provision of payment services and/or payment systems (as the case may be). Said entities have access to personal information needed to perform their functions but may not use it for other purposes. The entities in question are required to adhere to laws and regulations governing data protection. 6.1.2 Third-Party Service Providers: We employ other companies and individuals, located inside as well as outside the Arab Republic of Egypt, to perform functions and deliver services on our behalf. Examples of such services include cloud storage, conducting background and other checks, analyzing data and providing marketing and advertising services. These third-party service providers have access to personal information needed to perform their functions but may not use it for other purposes. Third-party service providers are required to adhere to laws and regulations governing data protection.
6.1.3 Corporate Affiliates and Group Companies: We may share your information/data with other Flash group companies and affiliates of Flash which are located inside as well as outside the Arab Republic of Egypt.
6.1.4 Business Transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the terms and conditions set out in any pre-existing Privacy Policy (unless, the user consents otherwise). Also, in the event that Flash or substantially all of its assets are acquired, user information will be one of the transferred assets.
6.1.5 Eligible Sellers/Merchants: We may share any of the following data: (i) your full name; (ii) your phone number; (iii) your payment amount; (iv) the time of your payment; and (v) your location at the time of payment, with Eligible Sellers/merchants while you pay any purchases for any Eligible Sellers/merchants by using the Payment Services.
6.1.6 Protection of Flash and Others: We release account and other personal information when we believe release is appropriate to (a) comply with the law (including release of information to law enforcement authorities, competent courts, regulators, governmental or public bodies); (b) enforce or apply the Customer Agreement, this Privacy Policy and other agreements and policies and (c) protect the rights, property, or safety of Flash, our users, or others. This includes exchanging information with other companies and organizations for fraud protection.
Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to consent to the sharing of your personal information.

7. Marketing and Communication
7.1 You hereby expressly consent and agree to us communicating with you via email, SMS or in-app notification in connection with the Flash App and the Service to, amongst other things, confirm your registration and deliver other transactional messages in relation to the Service. As it is imperative for us to provide you such transactional messages you may not be able to opt-out of such messages. However, you can ask us to stop sending you marketing communication at any time by clicking on the opt-out link in the email sent to you or by reaching out to Customer Support. 7.2 You may receive marketing and other communications from us if you:
- have requested such information from us; or
- use and access the Flash App and the Service.

8. Cookies
8.1 We use cookies, pixels, and other technologies (collectively, "cookies") to recognize and track your browser, device or activity, learn more about your interests/preferences, provide you with essential features and services and for additional purposes, including:
8.1.1 recognizing you when you login to the Flash App and use the Service;
8.1.2 keeping track of your specified preferences;
8.1.3 conducting research and diagnostics to improve the Flash App and the Service;
8.1.4 detecting and preventing fraudulent activity; and
8.1.5 improving security.
8.2 You are always free to decline or refuse all or some of our cookies if your browser permits, although doing so may interfere with the functioning and/or your use of the Flash App.
8.3 For further information about the type of cookies used by the Flash App, please contact Customer Support.
9. Protecting Your Personal Information
9.1 By providing us with your personal information, you consent to the transfer of your personal information outside of the Arab Republic of Egypt. We take precautions to safeguard all your personal information from unauthorized access, use or disclosure and we shall adhere to applicable laws and regulations in our transfer of your personal information outside of the Arab Republic of Egypt.
9.2 The internet is not a secure medium and we cannot guarantee the privacy of your personal information. However, Flash shall endeavor to protect users’ data by using best security standards and practices.
9.3 You must enter your username and Your Credentials and authenticate yourself, in accordance with the requirements of the Flash App, each time you want to access Your Flash Account and conclude transactions and make payments through the Flash App.
9.4 Choose Your Credentials carefully using unique numbers, letters and special characters. We recommend that you frequently update your password.
9.5 Never share your username and/or Your Credentials with anyone. 9.6 The posting by you of any personal information anywhere on the Flash App other than on the Your Flash Account section of the Flash App shall be at your own risk and may lead to the suspension of your use of and access to the Flash App.
9.7 If you are concerned that your username or Your Credentials has been compromised, please contact Customer Support immediately and ensure you change Your Credentials by logging onto the Your Flash Account section of the Flash App.
10. General Provisions
10.1 Flash does not consider anonymized information or non-personally identifiable data to constitute personal information, as it cannot be used to ascertain the identity of a specific individual.
10.2 We cannot control nor guarantee the privacy of your personal information when you share your personal information with any Eligible Sellers or other users of the Flash App, we therefore encourage you to practice caution when sharing your personal information with Eligible Sellers and/or other users of the Flash App.
10.3 The Flash App may include links to third-party websites that are controlled by and maintained by others and which are completely unrelated to Flash. If you link or access such third-party websites, you will become subject to the privacy policies of said third-party websites. Any link to such third-party websites is not an endorsement of such websites, their content or their services or a warranty that such websites will be free of viruses or other such items of a destructive nature.
10.4 You may receive information relating to us or our affiliates or to the Service that is not known to the general public ("Confidential Information"), therefore You agree that: (a) all Confidential Information will remain our exclusive property, (b) you will use Confidential Information only as is reasonably necessary for your use of and access to the Service and your personal use of the Flash App, and (c) you will not otherwise disclose Confidential Information to any other person.
10.5 You may not use our communication tools to send spam or otherwise send content that would violate the Customer Agreement or the provisions of this Privacy Policy. We automatically scan and may manually filter messages to check for spam, viruses, phishing attacks and other malicious activity or illegal or prohibited transactions.
10.6 For any privacy-related matters or questions or for additional information, please check the privacy settings on the Your Flash Account section or contact Customer Support.

Arabic Version