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Privacy Policy

1. Introduction

MEMCash (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our website (memcash.app), mobile applications, and financial services. By accessing or using our services, you agree to the terms of this Privacy Policy.

2. Information We Collect

We may collect the following types of personal data:

  • KYC/AML Data: Documents and biometric data for identity verification
  • Identity Data: Name, date of birth, national ID/passport number
  • Contact Data: Email address, phone number, mailing address
  • Financial Data: Bank account details, transaction history, wallet balances
  • Technical Data: IP address, device type, browser type, operating system
  • Behavioral Data: Usage patterns, clickstream data, preferences

3. How We Use Your Information

We use your data to:

  • Ensure security and prevent fraud
  • Provide and improve MEMCash services
  • Facilitate micro-lending and fund aggregation
  • Verify identity and comply with KYC/AML regulations
  • Train and optimize our AI models
  • Communicate with you about updates, offers, and support

4. Legal Basis for Processing

We process your data under the following legal bases:

  • Legitimate Interest: To improve our services and protect users
  • Consent: When you explicitly agree to data collection
  • Contractual Necessity: To deliver services you request
  • Legal Obligation: To comply with financial regulations

5. Data Sharing and Disclosure

We may share your data with:

  • Licensed microfinance partners in your country
  • Payment processors (e.g., Stripe, Plaid)
  • Cloud infrastructure providers (e.g., AWS, Google Cloud)
  • Regulatory authorities (if legally required)
  • AI service providers (for model training and support)

We do not sell your personal data.

6. International Data Transfers

Your data may be transferred to and stored in countries outside your jurisdiction. We ensure appropriate safeguards are in place, including:

  • Standard Contractual Clauses (EU)
  • Data protection agreements (Georgia, Armenia)
  • Compliance with CCPA (USA)

7. Data Retention

We retain your data only as long as necessary for:

  • Service delivery
  • Legal and regulatory compliance
  • AI model training (anonymized where possible)

You may request deletion of your data at any time.

8. Your Rights

Depending on your jurisdiction, you may have the right to:

  • Access your personal data
  • Correct inaccurate data
  • Request deletion (“right to be forgotten”)
  • Object to processing
  • Withdraw consent
  • Lodge a complaint with a data protection authority

9. Security Measures

We use bank-grade security protocols:

  • AES-256 encryption
  • OAuth 2.0 authorization
  • Secure cloud storage
  • Regular audits and penetration testing

10. Cookies and Tracking

We use cookies to:

  • Improve user experience
  • Analyze site traffic
  • Personalize content

You can manage cookie preferences via your browser settings. See our [Cookie Policy] for details.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with a revised “Effective Date.”

12. Contact Us

If you have questions or concerns, contact us at:
Email: privacy@memcash.app