Privacy Policy

My Rateb General Trading Company(the “Company” or “My Rateb”) is committed to protecting your information and respecting your privacy through our compliance with this Privacy Policy.

This Privacy Policy, together with our Terms of Service and any other document sets out the basis on which any personal data which we collect from you will be processed by us through our Services. By using our Services, you accept that this Privacy Policy applies to you. Please read it carefully.

1. What Data Does My Rateb Collect?

We may collect information about you when you visit our Sites or use our Services, including the following:

a. Registration and use information – When you register to use our Services by establishing an account, we will collect personal data as necessary to offer and fulfill the Services you request and to comply with local and laws and regulations. Depending on the Services requested, the information we gather from you may include your name, mobile number, nationality, civil ID number and your salary information to establish an Account. We may require you to provide us with additional personal data as you use our Services.

b. Transaction and experience information – When you use our Services or access our Sites, to receive money, or to process payments, we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, recipient information, sender information, device information, technical usage data, IP information, date and time of the transaction and geolocation information.

c. Participant information – When you use our Services or access our Sites, we collect personal data you provide us about the other participants associated with the transaction. When you send money through the Services, we collect and store some of personal data such as name, civil ID number, nationality and mobile number about the sender and the participant who is receiving money from you.

d. Other information – We may also collect data about the device you use, device information, technical usage data and geolocation information as necessary to complete the transaction.

e. Other information we collect related to your use of our Sites or Services – We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.

2. Personal Data Retention

We retain personal data to fulfill our legal or regulatory obligations and for our business purposes. We may retain personal data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your account is closed, we may take steps to mask personal data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such personal data in accordance with this privacy statement.

3. How Do We Process Personal Data?

We may process your information for the following reasons:

• To operate the Sites and provide the Services, including:

• to initiate a payment, send money, or add value to an account;

• to authenticate your access to an account;

• to communicate with you about your account, the Sites, or the Services;

• to compare information for accuracy and verification purposes;

• to keep your account and financial information up to date;

• to manage our business needs, such as monitoring, analyzing, and improving the Services and the Sites’ performance and functionality. For example, we analyze user behavior and perform research about the way you use our Services.

• to manage risk and protect the Sites, the Services and you from fraud by verifying your identity.

• My Rateb’s risk and fraud tools use personal data, device information, technical usage data, device IP and geolocation

• information from our Sites and websites that offer My Rateb Services to help detect and prevent fraud and abuse of the Services.

• to market to you.

• My Rateb’s products and Services and the products and services of unaffiliated businesses. We may also process your personal data to uniquely tailor the marketing content and certain Services or Site experiences to better match your interests on My Rateb and other third-party websites.

• to provide personalized Services offered by My Rateb on third-party websites and online services.

• We may use your personal data and other information collected in accordance with this privacy statement to provide a targeted display, feature, Services or offer to you on third-party websites. We may use cookies and other tracking technologies to provide these online services and/or work with other third-parties such as merchants, advertising or analytics companies to provide these online services.

• to comply with our obligations and to enforce the terms of our Sites and Services, including to comply with all applicable laws and regulations.

• to respond to your requests, for example to contact you about a question you submitted to our customer service team.

4. Do We Share Personal Data?

We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the privacy statement.

We may share your personal data or other information for the following reasons:

With other members of My Rateb: We may share your personal data with members of My Rateb to, among other things, provide the Services you have requested or authorized; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; and to help us manage the availability and connectivity of My Rateb products, Services, and communications.

With the Public Authority for Civil ID: We may share Civil ID to authenticate you as having a valid Kuwaiti Civil ID.

With other financial institutions: We may share some personal data such as Gender, Age and Nationality, Civil ID copy with other financial institutions that we have partnered with to jointly create and offer a product. These financial institutions may only use this information to market and offer My Rateb-related products, unless you have given consent for other uses.

With other parties such as Exchange companies: We may share information about you and your account with the

other parties involved in processing your transactions. The information includes:

• Civil ID copy and Mobile number necessary to facilitate the transaction or for an investigation of a transaction;

• information to help other participant(s) resolve disputes and detect and prevent fraud;

• With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for My Rateb’s business purposes or as permitted or required by law, including:

1. if we need to do so to comply with a law, legal process or regulations;

2. law enforcement, regulators, government officials, in relation to a court order, or other legal process or regulations that are applicable to My Rateb; when we need to do so to comply with such law; or when we believe, in our sole discretion, that the disclosure of personal data is necessary or appropriate to prevent physical harm or financial loss; or to report suspected illegal activity or to investigate violations of a user agreement;

3. to protect the vital interests of a person;

4. to protect our property, Services and legal rights;

5. to facilitate a purchase or sale of all or part of My Rateb’s business;

6. to help assess and manage risk and prevent fraud against us, our users and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals and merchants;

7. to companies that we plan to merge with or be acquired by;

8. to support our audit, compliance, and corporate governance functions.

In addition, My Rateb may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why users visit our Sites and use our Services. This data will not personally identify you or provide information about your use of the Sites or Services. We do not share your personal data with third parties for their marketing purposes, only marketing information such as Gender, Age, Nationality and General area location of our users.

5. How Do We Use Cookies and Tracking Technologies?

When you visit our Sites, use our Services, or visit a third-party website for which we provide online Services, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”) to recognize you as a user and to customize your online experiences, the Services you use, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Sites and Services. Certain aspects and features of our Services and Sites are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Sites and Services may be limited or not possible.

6. What Privacy Choices Are Available to You?

You have choices when it comes to the privacy practices and communications described in this Privacy Statement at the time you sign up for or use a Service or in the context of your use of a Site.

Choices Relating to the Personal Data We Collect

• Personal data. You may decline to provide personal data when it is requested by My Rateb, but certain Services or all of the Services may be unavailable to you.

• Location and other device-level information. The device you use to access the Sites or Services may collect information about you, including geolocation information and user usage data that My Rateb may then collect and use. For information about your ability to restrict the collection and use of such information, please use the settings available in the device.

Choices Relating to Cookies

• You may have options available to manage your cookies preferences. For example, your browser or internet device may allow you delete, disable, or block certain cookies and other tracking technologies. You can learn more by visiting AboutCookies.org. You may choose to enable these options but doing so may prevent you from using many of the core features and functions available on a Service or Site.

• You may have an option regarding the use of cookies and other tracking technologies when you use a Service or visit parts of a Site. For example, you may be asked if you want the Service or Site to “remember” certain things about you, and we will use cookies and other tracking technologies to the extent that you permit them.

Choices Relating to Your Registration and Account Information

If you have an account, you generally may review and edit personal data by logging in and updating the information directly or by contacting us.

Choices Relating to Communication Notices, Alerts and Updates from Us:

• We may send you marketing content about our Sites, Services, products, products we jointly offer with financial institutions or

other businesses, through various communication channels, for example, email, text, pop-ups, push notifications, and messaging applications. You may opt out of these marketing communications by following the instructions in the communications you receive.

• We will send communications to you that are required or necessary to send to users of our Services, notifications that contain important information and other communications that you request from us. You may not opt out of receiving these communications.

7. How Do We Protect Your Personal Data?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your personal data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s), PIN number and account/profile registration information and verifying that the personal data we maintain about you is accurate and current. We are not responsible for protecting any personal data that we share with a third-party based on an account connection that you have authorized.

8. What Else Should You Know?

Changes to This Privacy Statement.

We may revise this Privacy Statement from time to time to reflect changes to our business, the Sites or Services, or applicable laws. You will be asked to review and approve the revised Privacy Statement in order to continue using our products and services.

Transfers of Your Personal Data to Other Countries

Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers may store and process your personal data in Kuwait and/or elsewhere in the world. By using our Sites and Services, you consent to your personal data being transferred to other countries, including countries that have different data protection rules than your country.

9. Contact Us

You may contact us on info@myrateb.com if you have general questions about our Privacy Statement and practices or questions about your account information or personal data.

10. Definitions

Account means a My Rateb member account.

Device Information means data that can be automatically collected from any device used to access the Sites or Services. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device’s IP address; information about your device’s web browser and the internet connection being used to access the Site or Services; and geolocation information.

Geolocation Information means information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. Some of our Services may ask you for permission to share your current location. Some of the Sites and Services require this information to provide a specific product or online Service. If you do not agree to our collection of the geolocation information, our Sites or Services may not function properly when you try to use them.

My Rateb means My Rateb General Trading Company. In this Privacy Statement, My Rateb is sometimes referred to as “we,” “us,” or “our,” depending on the context.

Personal Data means personal information that can be associated with an identified or identifiable person. “personal data” can include name, mobile number, email address, payment card number, other financial account information, account number, date of birth, and government-issued credentials (e.g., driver’s license number, national ID, and passport)

Process means any method or way that we handle personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, disseminating or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data.

Services means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by My Rateb in connection with an account.

Sites means the websites, mobile apps, official social media platforms, or other online properties through which My Rateb offers the Services and which has posted or linked to this Privacy Statement.

Technical Usage Data means information we collect from your mobile, computer or other device that you use to access the Sites or Services. Technical usage data tells us how you use the Sites and Services, such as what you have searched for and viewed on the Sites and the way you use our Services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through cookies.

User means an individual who uses the Services or accesses the Sites and has established a relationship with My Rateb (for example, by registering or opening an account and agreeing to the My Rateb User Agreement) or otherwise uses the Services as a participant to a transaction.