SASAI FINTECH MOBILE APP PRIVACY POLICY

Last revised: 10-08-2022

1. INTRODUCTION

Purpose. Your privacy is important to us. The purpose of this Privacy Policy is to describe how Sasai Fintech collects, uses, and shares information about you through our mobile App, SASAI. Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us or as described at the end of this Policy.

Our Privacy Policy explains:

Information We Collect and Why We Collect It

How We Use and Share Your Information

Access to Your Information and Choices

Security of Your Information

Changes to Our Privacy Policy

Questions and How To Contact Us

Scope; Third Party Sites. This Privacy Policy applies only to information we collect at and through the SASAI application. Our website and other affiliated sites, such as www.sasai.global may be governed by their own separate privacy policies which are set forth therein.  Links to third party sites are not owned or controlled by Sasai Fintech. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave The SASAI application and to read the privacy statements of each application that collects personal information.

Terms of Use. Please note that your use of the SASAI application is also subject to our Terms of Use.

2. INFORMATION WE COLLECT AND WHY WE COLLECT IT

Information You Provide To Us. We collect certain personal information when you provide it to us, such as when personally identifiable information is voluntarily provided when you use the SASAI application, when you register for an account, and when you electronically communicate with us. This information may consist of the following: your name, contact details, ID number.  The information you voluntarily supply will be used by Sasai Fintech to respond to your inquiries, supply you with requested information on the SASAI application. Your information is considered private and confidential and treated with the strictest confidence. We will not sell or divulge any of your private information to any 3rd parties. If you are not yet a client but have submitted personal information to Sasai Fintech electronically and would like it removed or modified, please contact us at legal@sasaifintech.com. We will gladly and expediently comply with your request. Please note that certain confidential client files related to services that have been provided are part of a permanent record that must be kept in accordance with applicable law.

Information We Collect Automatically. We collect certain information automatically as you use the SASAI application, such as general non-personal information used to help improve the SASAI application. This may include items such as: usage information and device information such as the device you use to access The SASAI application including the hardware model, operating system and version, IP address, and unique device identifier. In addition, The SASAI application may access your device's image storage applications, with your consent, to facilitate your use of certain features of The SASAI application.

Information Collected. We use an analytics tool and may use other third-party analytic tools to collect information about use of the SASAI application, such as how often users visit the SASAI application. We use the information we get from the analytics tools only to improve the SASAI application. The analytic tools do not collect your name or other identifying information. We do not combine the information collected through the use of the analytic tools with personally identifiable information. Although analytic tool plants a permanent cookie on your device to identify you as a unique user the next time you use the SASAI application, the cookie cannot be used by anyone but Sasai Fintech.

No Information From Children Under Age 18. If you are under the age of 18, please do not attempt to open a SASAI account or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 18, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 18, please Contact Us.  

3. HOW WE USE AND SHARE YOUR INFORMATION

To Provide Products, Services, and Information. As described above, we collect information from you so that we can communicate with you and provide and deliver the information and services you have requested. We use your personal information to contact you about your transactions, or to inform you about our other products and services available and new offerings from the SASAI application. We may provide information to third party service providers that help us process payments and fulfill and deliver services that you request from us.

We may use third parties to help host the SASAI platform, send out email updates about Sasai Fintech and the SASAI application, provide marketing and advertising services for us, remove repetitive information from our user lists, and process payments. These service providers will have access to your personal information in order to provide these services, but when this occurs, we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service.

Sasai Fintech, from time to time, may contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information is not transferred to the third party. Sasai Fintech may share data with trusted partners to help perform statistical analysis, send you email or mail, provide customer support, or as otherwise required to deliver the requested services. All such third parties are prohibited from using your personal information except to provide these services to Sasai Fintech, and they are required to maintain the confidentiality of your information.

Except as set forth in this Privacy Policy, we do not share, rent, license, or sell your personal information to third parties.

Surveys and Contests. From time-to-time Sasai Fintech may host surveys and contests which may require the submission and collection of personal information. Participation in these surveys or contests is completely voluntary and you may choose whether or not to participate and therefore disclose this information. Personal information requested may include contact information (such as name and shipping address), and demographic information (such as post code, age). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of The SASAI application and the services you receive from Sasai Fintech.

Your Consent. In addition to the sharing described elsewhere in this Policy, we will only share personal information with companies, organizations, or individuals outside of the Sasai Fintech when we have your consent to do so.

Legal Proceedings. We will share personal information with third party companies, organizations or individuals outside of Sasai Fintech if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to: (a) meet any applicable law, regulation, subpoena, legal process or governmental request; (b) enforce applicable Terms of Use, including investigation of potential violations; (c) detect, prevent, or otherwise address fraud, security or technical issues; or (d) protect against harm to the rights, property or safety of Sasai Fintech, our users, clients, or the public as required or permitted by law.

4. ACCESS TO YOUR INFORMATION AND CHOICES

You can access and update certain information we have relating to your SASAI account by signing into your account and going to the profile section of the SASAI platform. If you have questions about personal information we have about you or need to update your information, of if you want to opt-out of receiving marketing and promotional e-mails from Sasai Fintech, you can Contact Us. You can also opt-out of receiving future marketing and promotional e-mails from Sasai Fintech by using the opt-out or unsubscribe feature contained in the e-mails.

You can close your account by contacting us as set forth below. If you close your account, we will no longer use your online account information or share it with third parties. We may, however, retain a copy of the information to meet regulatory requirements.

Sasai Fintech may send push notifications or alerts to your device. You can deactivate these messages at any time by changing the notification settings on your device.

5. SECURITY OF YOUR INFORMATION

We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information.

CHANGES TO OUR PRIVACY POLICY

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes).

6. PARENTAL CONTROL & OBLIGATION

Permission by Parent or Guardian If you are under 18, you must have your parent or legal guardian's permission to use the Service. Please have them read this Agreement with you.

Permission by Parent or Guardian If you are a parent or legal guardian of a user under the age of 18, by allowing your child to use the Service, you are subject to the terms of this Agreement and responsible for your child's activity on the Service.

a)  The User shall be under the obligation to:

· use the Product in a way which does not disrupt its operation;

· provide true, current, and accurate information which is not misleading or infringing the rights of third parties;

· update the information provided in the registration form;

· keep the password and login secret and not share it with third parties;

· provide only legal content;

· not engage in activities aiming to infringe the safety of data processed in the Product, not attempt unauthorized access to the Product, and not engage in other activities aiming to disrupt the correct operation of the Product;

· use the Product as intended, that is to control internet access of persons under parental authority or guardianship of the User, with full respect of the right to privacy and telecommunication secrecy of underage persons;

· comply with legal regulations.

b)  If it is found that the User infringes these Terms & Conditions, and in particular engages in activities described in item 1 above, the Service Provider may immediately block or delete the User Account or limit the possibility to use the Product. The Service Provider may immediately block the possibility to use the Product in the following cases, among others:

· if the Service Provider discovers that an under-aged User was deprived of parental authority/guardianship, or that it was limited, over the person on whose mobile device the app controlled by the User is installed,

· if the Service Provider finds out that the User installed the App on a device of a person who is not under the User's parental authority/guardianship and who did not consent to the installation.

c) Removal or blocking the User Account in situations described in this section shall be equal to immediate termination of the contract for providing Services, to which the Service Provider is entitled.

d)  If the User entrusts the Device on which the app is installed to a minor or person under the User's parental custody/guardianship, the User shall be responsible for the use of this device by that person, and the User shall control and supervise the way the device is used by that person, which in particular consists in ensuring that the person does not

· Entrust the device to persons other than the User or use the device to engage in illegal activities. The User shall not make the Parent's Device available or entrust it to any other person.

· The person shall not access areas of the app for which permission has not been granted by parent

e)  The User represents and guarantees that he/she is authorized to convey to the Service Provider the data generated in the course of rendering Services for processing, including the list of content and features of the app viewed by a minor on the Device as well as dates and times of access to such content or features. The User represents that he/she holds appropriate consents of the persons whose personal and other information the User submits for processing, and that those activities do not infringe any legal regulations or personal rights of third parties. The User shall have the obligation to indemnify the Service Provider against any liability at his first request if any claims of third parties in the above respect arise.

f)  The User represents and shall have the obligation to ensure that only the User shall have access to the data referred to in the above item 5 provided to the User as part of the Service.

g)  The User shall be under the obligation to use the Services only as means of parental authority or guardianship over an underage person, i.e., exercising custody over that person with respect for the person's dignity and rights, and without activities that would infringe the rights of third parties in any way, that is to say the User may use the Services only as a particular way of exercising legal parental authority or guardianship.

h)  The Services shall only be made available on condition that the User utilizes them in compliance with these Terms & Conditions. Only using the Services in that way excludes any possibility of committing a crime.

i)  Using the Services to commit or attempt to commit any criminal act shall constitute a flagrant breach hereof. If the Service Provider has grounds for suspecting such behavior, the Service Provider shall forthwith notify relevant law enforcement agencies.

j)  If there are reasonable doubts as regards the authenticity of the data submitted by the User, the Service Provider shall have the right to limit the possibility of using the Product by the User until the data is verified.

h)   The User shall be solely liable for disclosing the login and password to other persons. The User shall be under the obligation to immediately inform the Service Provider about every case of disclosing the login or password to a third party, and about every case of infringing the rules set forth herein.

7. ACCEPTABLE USAGE GENERATED CONTENT POLICY

User-generated content (UGC) is content that users contribute to an app, and which is visible to or accessible by at least a subset of the app's users.

a) You may only contribute content in a manner that is lawful and that complies with the provisions of this Clause 7.

Specifically:

· you must ensure that content contributed complies fully with any and all applicable local, national, and international laws and/or regulations.

· you must not contribute content that is in any way, or used for any purpose, that is unlawful or fraudulent;

· you must not knowingly contribute content, upload, or in any other way transmit data that contains any form of virus or other malware, or any other code designed to adversely affect computer hardware, software, or data of any kind; and

· you must not contribute content that is in any way, or used for any purpose, that is intended to harm any person or persons in any way.

b) When contributing content using the Sasai App and Services you must not submit, communicate, or otherwise do anything that:

· is sexually explicit;

· is obscene, deliberately offensive, hateful, or otherwise inflammatory;

· promotes violence;

· promotes or assists in any form of unlawful activity;

· discriminates against, or is in any way defamatory of, any person, group or class of persons, race, sex, religion, nationality, disability, sexual orientation, or age;

· is intended or otherwise likely to threaten, harass, annoy, alarm, inconvenience, upset, or embarrass another person;

· is calculated or is otherwise likely to deceive;

· is intended or otherwise likely to infringe (or threaten to infringe) another person's right to privacy or otherwise uses their personal data in a way that you do not have a right to;

· misleadingly impersonates any person or otherwise misrepresents your identity or affiliation in a way that is calculated to deceive (obvious parodies are not included within this definition provided that they do not fall within any of the other provisions of this sub-Clause 7.b;

· implies any form of affiliation with Us where none exists;

·  infringes, or assists in the infringement of, the intellectual property rights (including, but not limited to, copyright, patents, trademarks, and database rights) of any other party; or

is in breach of any legal duty owed to a third party including, but not limited to, contractual duties and duties of confidence.

c) We reserve the right to suspend or terminate your Account and/or your access to The Sasai App if you materially breach the provisions of this Clause 7 or any of the other provisions of these Terms.  Specifically. We may take one or more of the following actions:

· Remove in close to real time any content that is objectionable using an UGC moderation system that has been implemented on Sasai.

· Users may use the in-app reporting system to report objectionable UGC and the Sasai team will take action against that UGC where appropriate;

· remove any Post(s) submitted by you that violate(s) this Acceptable Usage Policy

· remove or block abusive users who violate the app's Terms of Use and/or user policy;

· suspend, whether temporarily or permanently, your Account and/or your right to access and use the Services;

· issue you with a written warning;

· take legal proceedings against you for reimbursement of any and all relevant costs on an indemnity basis resulting from your breach;

· take further legal action against you as appropriate;

· disclose such information to law enforcement authorities as required or as We deem reasonably necessary; and/or

· any other actions that We deem reasonably appropriate (and lawful).

d) We hereby exclude any and all liability arising out of any actions (including, but not limited to those set out above) that We may take in response to breaches of these Terms.

8. QUESTIONS AND HOW TO CONTACT US

You may contact Sasai Fintech regarding the Privacy Policy, the Terms of Use, or with respect to any other comments or questions at:

Website: https://www.sasai.global/

Twitter: @SasaiGlobal

Facebook: @SasaiGlobal

Instagram: Sasai