Ayoba App Privacy Policy

Version 2, December 2019

Progressive Tech Holdings Limited (“we”, “us” and “our”) are committed to respecting your privacy.   This privacy policy describes how we collect, use and process your personal data when you use the Ayoba application (the “Ayoba App“).  This privacy policy applies if you download the Ayoba App and when you use the Ayoba App. Please take the time to read and understand this privacy policy. We are incorporated and registered in Mauritius and our registered address is at 1st Floor, Anglo-Mauritius House, Intendance Street, Port-Louis, Mauritius and our company registration number is 117490 C2/GBL.  For notices under this section and this document, please send an email to legal@ayoba.me.

About this privacy policy

We are responsible for ensuring that your personal data is used in compliance with data protection law. Personal data is information which, on its own or in combination with other information, can be used to identify you.

You consent to the processing of your personal data

By downloading, installing, accessing and/or using the Ayoba App, you are also agreeing to this privacy policy.  In doing so, you consent to our use of your personal data as and for the purposes set out in this privacy policy.  If you want to withdraw your consent at any time or would like us to stop using your personal data for any reason, please contact us at the details above. If you withdraw your consent, for any reason, we will only continue use and process your personal data to the extent (and in the manner) permitted by applicable laws.  

Personal data that we collect about you

We will collect and process the following personal data about you:
  • Information that you provide to us. This includes information about you that you give us when registering and using the Ayoba App, including (but not limited to):
    • your name;
    • your Mobile Station International Subscriber Directory Number (i.e. your mobile number) (your “MSISDN“), which we may obtain from you or which may be provided to us by your mobile network service provider;
    • your email address;
    • your status on the Ayoba App;
    • your alias on the Ayoba App;
    • your date of birth;
    • your profile picture and any other information that you include in your profile;
    • your connections and contacts, including both users of the Ayoba App and other contacts on your mobile device that you make available to us;
    • your photos, videos and other files on your phone, when you upload these files on the Ayoba App; and
    • any information when you contact us for customer support or any other queries.
  • Information we collect or generate about you. This includes:
    • location information when you use the Ayoba App’s location feature or which we may determine on the basis of your MSISDN or internet protocol address or via similar technology;
    • information about your usage and activity on the Ayoba App, including (but not limited to) your status, the frequency at which you use the Ayoba App, the types of content you sent or submit via the Ayoba App, membership of any groups and group profile picture(s). We obtain this information from service logs and other monitoring systems;
    • device and connection information when you use the Ayoba App, including a unique application number and information concerning your device’s operating system, hardware model and settings; and
    • information about your behaviour when using the Ayoba App.
  • Information we receive from others. This includes:
    • other users of the Ayoba App providing your phone number from their mobile address book (in the same way that you may provide their number(s));
    • information about you (such as copies of chats) from other users of the Ayoba App if they report abusive or offensive content or behaviour on the Ayoba App; and
    • information from third party providers who help us operate and provide the Ayoba App. This also includes information from app stores that may supply reports in order to help us diagnose and fix service issues, as well as information provided to us by your mobile network service provider. The Ayoba App utilises HTTP Header Enrichment, which is a technology that enables mobile network providers to provide us with certain information about you, including your MSISDN or other information that enables us to identify you.

Uses of your personal data

Your personal data may be stored and processed by us in the following ways and for the following purposes:
  • service functionality and providing access to and operating the Ayoba App;
  • to create your account to use the Ayoba App and allow your continue use of the Ayoba App;
  • to allow other users of the Ayoba App to contact you;
  • to establish and verify your identity on the Ayoba App;
  • optimising user experience and improving the Ayoba App;
  • analysing user behaviour, usage and trends, as well as performing market research;
  • to advertise goods and services to you, including on a targeted basis and to create a marketing profile for future advertisements directed to you
  • operate, administer, maintain, secure and develop the Ayoba App and the performance and functionality of the Ayoba App;
  • to provide to third parties, including mobile network operators, in order to optimise our service to you and to better market information to you;
  • reporting to the appropriate legal and regulatory authorities;
  • managing our relationship with you, including communicating with you and keeping a record of our communications with you and your communications with us;
  • informing you about any changes to the Ayoba App, changes to the terms of use applicable to the Ayoba App, this privacy policy or other changes which are relevant to you;
  • diagnose and deal with technical issues and customer support queries and other user queries;
  • detect, prevent or deal with actual or alleged fraud, security or the abuse, misuse or unauthorised use of the Ayoba App and/or contravention of this privacy policy or the terms of use that apply to the Ayoba App; and
  • for other purpose relevant to our business activities, provided that are lawful.

Storing your information

In order to operate the Ayoba App, we may store your personal data in data centres which may be outside your country of residence and where the infrastructure may be owned or operated by our service providers or affiliated companies.  If the location that personal data is transferred to or stored does not have substantially similar laws which provide for the protection of personal data, we will take reasonably practicable steps to ensure that your personal data is adequately protected in that jurisdiction. You may also choose to store some of your personal data on your own device. We take reasonable technical and organisational measures to secure the integrity of retained information, using accepted technological standards to prevent unauthorised access to or disclosure of your personal data, and protect your personal data from misuse, loss, alteration or destruction.

Disclosure of your information to third parties

We may share your personal data:
  • with our affiliates;
  • with third parties, including mobile network operators, for the purposes of optimising our services to you and for increasing the relevance of any advertising that is displayed to you. In this context, we may share your MSISDN, usage information and billing details with third parties;
  • with our professional advisors and banks for the purpose of providing services to us,
  • where we are required to disclose your identity for regulatory and legal purposes;
  • if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
  • if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer;
  • with third party agents or contractors for the purposes of providing services to us;
  • to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, establish, exercise or defend our legal rights; and
  • to governmental agencies, exchanges and other regulatory or self-regulatory bodies if we are required to do so by law or if we reasonably believe that such action is necessary to:
    • comply with the law or with any legal process;
    • protect and defend the rights, property or safety of us, or our customers, employees, contractors, suppliers, service providers, agents or any third party;
    • detect, prevent or deal with actual or alleged fraud, security or technical issues or the abuse, misuse or unauthorised use of the Ayoba App and/or contravention of this privacy policy; and/or
    • protect the rights, property or safety of members of the public (if you provide false or deceptive information about yourself or misrepresent yourself as being someone else, we may proactively disclose such information to the appropriate regulatory bodies and/or commercial entities).

Retaining your personal data

We may keep and process some or all of your personal data (even if you delete the Ayoba App) if and for as long as:
  • we are required or permitted by law or a contract with you to keep it;
  • we reasonably need it for lawful purposes related to our functions and activities;
  • we reasonably need it for evidentiary purposes; or
  • you agree to us keeping it for a specified further period.
Keeping your personal data updated and correct Where required by law, we take reasonable steps to ensure that your personal data is accurate, complete, not misleading, and up to date.  You must let us know if any information we have about you is incorrect, incomplete, misleading or out of date, by notifying us at the contact details set out below or by updating your user account on the Ayoba App.

Your rights under the laws of your territory

Depending on the territory in which you access the Ayoba App, you may have certain rights under applicable data protection legislation in your territory.  These rights may include:
  • the right to access your personal data or copies of your personal data (in a structured or commonly used format);
  • the right to rectify errors in your personal data (which will be done free of charge, unless the request is manifestly unreasonable or excessive);
  • the right to request that your data is deleted, erased or forgotten by us;
  • the right to the object to our processing of your personal data;
  • the right to restrict the processing of your personal data;
  • the right to personal data portability, requiring us to transmit your personal data to a third party where this is technically feasible;
  • the right to withdraw your consent to our processing of your personal data, at any time;
  • the right to object to the processing of your personal data for marketing; and
  • the right to make a complaint the data protection authority in your jurisdiction.
Please note that these rights may differ or be subject to certain qualifications under the applicable laws of your jurisdiction.

Contacting us

If you would like further information on the collection or use of your personal data, please address your questions and comments to legal@ayoba.me. If we need to contact you, for any reason, we may do so via the Ayoba App or we may contact you on the mobile number and/or email address (or any other contact details) that you provide to us when registering to the use the Ayoba App.

Updates to this privacy policy

We may revise this privacy policy at any time. We will give you reasonable notice of any changes to this privacy policy. By continuing to access and use the Ayoba App you acknowledge and agree to those changes to this privacy policy.  Unless otherwise stated, the current version of this privacy policy will apply each time you access this Ayoba App. If you do not agree to the changes to this privacy policy, you must end your use of the Ayoba App in the way set out in the Ayoba App user terms and conditions (available at http://ayoba.me/terms-conditions).