Privacy Policy
Our Site and the Aya Wallet are operated by Mimo Initiative Ltd, registered in the Republic of the Seychelles under company number 228264 and have our registered office at Suite 309, Capital City Building, Independence Avenue, Victoria, Mahé, Republic of Seychelles. Our site is also used by other Mimo group companies ("Mimo", “we” or “us”).
This Privacy Policy explains what information we gather about you, the source of that information, what we use that information for, the lawful basis on which that information is used, and who we share that information with when you use products, services, content, features, technologies or functions offered by Mimo and all related sites, applications, and services (collectively, the “Mimo Services”). It also sets out your rights in relation to your personal data and who you can contact for more information or queries.
1. Overview and legal basis
1.1. Overview
To provide the Mimo Services and to reduce the risk of fraud, Mimo, the data controller, must ask you to provide the information (as defined below) about yourself, including technical information such as IP addresses and device information, and publicly available information related to wallet addresses imported into the Aya Wallet.
1.2. Legal Basis
We process your personal data based on the following legal grounds:
1.2.1. It is necessary for the legitimate interests of Mimo and its subsidiaries, provided such interests are not overridden by your privacy interests.
1.2.2. It is necessary for us to enter into, and perform our obligations under, our contract with you.
1.2.3. It is necessary for compliance with legal obligations.
1.2.4. Where we have obtained your prior consent.
1.3. Information
For the purposes of this Privacy Policy, “information” or “personal data” means any information about you that we or our third-party service providers collect from you or a third party, including the information set out in Section 2 below. Mimo takes the processing of your personal data very seriously and will use your personal data only in accordance with the terms of this Privacy Policy. It is important for you to review this Privacy Policy as it applies to all of the Mimo Services.
1.4. Notification of Changes
This Privacy Policy may be revised over time as new features are added to the Mimo Services or as we incorporate suggestions from our customers. We may change this Privacy Policy at any time by posting a revised version of it on our website. Unless we have legal grounds to do so otherwise, we will provide you with at least 30 days' prior notice of the effective date of the revised privacy policy. We will post the notice on our site followed by a notification either through the Aya Wallet or by e-mail.
1.5. Third-Party Websites or Applications
Some pages on the websites of Mimo or parts of the Mimo Services may include links to third-party websites. These sites are governed by their own privacy statements and terms of use, and Mimo is not responsible for their operations, including but not limited to their information handling practices. Users submitting information to or through these third-party websites should review the privacy statements and terms of use of these sites before providing them with personally identifiable information. Mimo is not responsible for the content or information practices of such third parties.
2. Information We Collect
2.1. Provision of the Mimo Services
We will collect the following information to provide you with the Mimo Services:
Technical Information: When you use the Mimo Services, we collect and store device sign-on data (including but not limited to device ID) and IP addresses.
Wallet Information: We collect and analyze publicly available information related to wallet addresses that you import into the Aya Wallet. This includes transaction history and balances as recorded on the blockchain.
Website Traffic Information: When you visit our Site, we automatically receive the web address of the site that you came from or are going to. We also collect information on the pages of our website that you visit, IP addresses, the type of browser you use, and the times you access our website.
Cookies and Similar Technologies: We use cookies, pixel tags, Flash cookies, or other local storage provided by your browser or associated applications. These are used to recognize you as a customer, customize the Mimo Services, measure promotional effectiveness, and to promote trust and safety.
Customer Support Information: We collect email addresses or Telegram handles that you provide to us for the purpose of providing customer support.
3. How We Use the Information We Collect
3.1. Internal Uses
Our primary purpose in collecting your information is to provide you with a safe, smooth, efficient, and customized experience in your use of the Mimo Services. We do this by processing your information to:
Provide the Mimo Services.
Manage risks in relation to any potential activity breaching our terms and conditions.
Improve the Mimo Services by customizing your user experience.
Measure the performance of the Mimo Services and improve their content and layout.
Manage and protect our information technology infrastructure.
Provide targeted marketing and advertising, service updates, and deliver promotional offers based on your communication preferences and your activities when using the Mimo Services.
ncial products providers, business partners, marketing and public relations agencies, Mimo Group companies, marketplaces, service providers, and your agents or legal representatives for purposes of our provision of the Mimo Services.
Intellectual Property Rights Owners: Disclosure may be required under applicable national law in the event that an owner of intellectual property rights pursues a claim against Mimo.
Mergers or Acquisitions: In the event of a merger or acquisition involving Mimo, the successor company will have access to your personal data maintained by us.
4. Sharing Information with Third Parties
4.1.
We will share your information with the following types of third parties in the circumstances described below:
Law Enforcement and Fraud Prevention: We may disclose necessary information to the police and other law enforcement and/or fraud prevention agencies.
Third-Party Service Providers: We may disclose necessary information to payment processors, auditors, financial products providers, business partners, marketing and public relations agencies, Mimo Group companies, marketplaces, service providers, and your agents or legal representatives for purposes of our provision of the Mimo Services.
Intellectual Property Rights Owners: Disclosure may be required under applicable national law in the event that an owner of intellectual property rights pursues a claim against Mimo.
Mergers or Acquisitions: In the event of a merger or acquisition involving Mimo, the successor company will have access to your personal data maintained by us.
5. Cross Border Transfers of Your Information
5.1.
Some of the recipients of your information may be based in countries outside of the European Economic Area (EEA) whose laws may not provide the same level of data protection. We are committed to adequately protecting your information regardless of where the data resides and to providing appropriate protection for your information where such data is transferred outside of the EEA.
6. Your Rights
6.1.
You have a number of rights in relation to your information under the GDPR, including rights of access, rectification, and erasure, as well as the right to object to processing and withdraw consent. To exercise any of your rights, please contact us at support@aya.cash.
7. Retention of Your Account Information
7.1.
We will retain your information for as long as necessary to fulfill the purposes outlined in Section 3. Generally, we will retain your information during the period when you are using the Mimo Services and for at least six (6) years after your use of the Mimo Services ceases.
8. Information Security
8.1.
We use computer safeguards such as firewalls and data encryption, enforce physical access controls to our buildings and files, and authorize access to information only for those employees who require it to fulfill their job responsibilities. The security of your Aya Wallet account also relies on the protection of your account password. You must not share your password with anyone, and if you believe someone else has obtained access to your password, please change it immediately and contact us.
9. Accountability
9.1.
Our privacy office and our data protection officer are responsible for ensuring that our day-to-day procedures comply with this Privacy Policy. If you have any questions about this Privacy Policy or your dealings with Mimo in relation to your information, you can contact us at privacy@aya.cash.
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