The purpose of this privacy policy (« Policy ») is to inform you about how and why Fair-eZone collects and processes your personal data when you use:

·         Our websites www.mypocket.io and www.fair-ezone.com (the « Site »),

·         The MyPocket mobile application available on Android and iOS (the « Mobile Application »),

·         Any services accessible via the Site or the Mobile Application (the « MyPocket Services »).

This Policy is also intended to inform you of your rights regarding your personal data. It is therefore important that you read it, as well as any other specific information that we may provide to you from time to time, when we collect or process personal data about you.

1. The data controller

The controller of your personal data is Fair-eZone, a Simplified Joint Stock Company (“Société par actions simplifiée”), registered in Nanterre, France, under n° 800 845 323, having its registered office at 20 bis Rue Louis-Philippe 92200 Neuilly-sur-Seine, France.

In this Policy, the terms « we », « us », « our » refer to the company Fair-eZone.

2. The personal data we collect

When providing its services, Fair-eZone may collect and process the following categories of personal data about you:

When you subscribe to our MyPocket Services:

·         Identification data, such as your civility, identity, date of birth, nationality, country and place of birth, identity document, selfie, proof of residence, and professional occupation.

·         Contact information, such as your email and postal addresses and mobile phone number.

·         Financial and banking data, such as monthly income level, expected top-up level, expected expenditure level.

When you use our MyPocket Services to complete a transaction:

·         Transactional data, such as amount, currency, card number, bank account number, account balance, merchant, supplier or beneficiary name.

·         Profile data, such as your preferences when using the MyPocket Services and your direct marketing preferences.

·         MyPocket Services usage data, for troubleshooting incidents as part of customer support.

When you browse the Site or use the Mobile Application:

·         Technical data, such as your device model, browser, IP address, your browsing in the Mobile Application or on the Site…

·         If you expressly authorize us to do so, your geolocation data, your mobile phone contacts, your mobile phone status data (mobile ID, language…) and, during the identification document collection phase, the images from your phone’s camera, in order to scan your identification documents. You can withdraw your consent at any time by disabling the authorization given for the Mobile application in your device settings.

This data is collected and processed for the purposes described below, depending on whether you use the Site, the Mobile Application or our MyPocket Services.

Where we need to collect personal data about you (under a legal obligation or a contract that we have with you, or that we are intending on entering into with you) and you fail to provide such personal data when requested, we may not be able to provide you with the services you require. The mandatory nature is indicated to you at the time of collection.

3. Why we process your personal data

The table below shows you the reasons why your personal data is collected and the legal basis on which Fair-eZone processes your data in accordance with applicable laws and regulations.

Please note that we may process your personal data on more than one lawful ground, depending on the specific purpose for which we use your personal data. For more details on this subject, do not hesitate to contact us (our contact details are available below, see point 9).

Fair-eZone does not take decisions based solely on automated processing that would produce legal effects for you.

4. Our use of « cookies”

When using our Websites or Mobile Application, information relating to the navigation of the device (computer, tablet, smartphone, etc.) may be stored in « cookie » files on the device, subject to the choices made regarding cookies which may be modified at any time.

3 types of cookies are used by Fair-eZone:

·         Internal cookies required by the Site to operate

These cookies allow the Site to function optimally. They include, for example, cookies that allow you to connect to secure areas of our Site.

·         Cookies for audience measurement

In order to adapt our MyPocket Services to the requests of visitors of the Site, we measure the number of visits, the number of pages viewed as well as visitor activity and frequency of return. We use Google Analytics cookies. Google Analytics collects information anonymously. It reports on Site trends without identifying individual visitors. You can disable Google Analytics without affecting the way you visit the Site. For more information about Google Analytics, click here.

·         Third-party cookies to improve Site interactivity

The Site relies on certain services offered by third party websites. These include videos posted on the Site (YouTube). These features use third-party cookies placed directly by these services. When you first visit the Site, a banner informs you of the presence of these cookies.

You block cookies by activating your browser setting which allows you to refuse the installation of all or part of the cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or part of our Site.

5. The recipients of your personal data

We do not rent, sell or disclose any personal data to third parties for their own marketing purposes. Your personal data is only shared with third parties under the following circumstances.

We share some of your personal data with partners who provide us with certain specialized services or who cooperate with us on projects. These partners act as separate data controllers and are therefore responsible for their own compliance with data protection laws and regulations. These include Prepaid Financial Services, the issuer of the MyPocket card, whose privacy policy can be found here.

Your personal data may also be transmitted to service providers selected by Fair-eZone, to provide certain services on behalf of and according to instructions provided by Fair-eZone. These service providers (« processors » within the meaning of the data protection laws and regulations) are subject to an obligation of confidentiality and have access to your personal data only to the extent necessary to provide their service and are therefore not authorised to use your data for other purposes. These include our anti-fraud service providers and some of our IT service providers (hosting, audience analysis, etc.).

We may also disclose your personal data (i) if we are required to do so by law (ii) to enforce our rights and protect the security of our services and (iii) in connection with mergers or acquisitions of companies.

6. International transfers and the security of your personal data

Your personal data that we collect is transferred and stored within the European Economic Area (EEA). As we provide an international service, your data may be processed outside the EEA so that we can perform our contract with you to provide the MyPocket Services. We will have to process your personal data in order, for example, to be able to respond to a request from you to make an international money transfer, process your payment information and comply with our anti-fraud obligations. We will take all necessary measures to ensure that your personal data is processed securely and in accordance with this Policy.

7. How long your personal data will be kept

Your personal data is kept by Fair-eZone for the time necessary to achieve the purposes for which it was collected.

To determine the appropriate retention period for your personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk resulting from the unauthorised use or disclosure of personal data, the purposes for which we process your personal data and our legal obligations.

8. Your rights

Depending on your personal situation, you have the rights listed below under data protection laws and regulations. We will honour your requests as required by applicable law, but keep in mind that these rights are not absolute: they do not always apply and may be subject to exceptions.

Right of access: You have the right to access the personal data we hold about you. This gives you the right to receive a copy of your personal data and certain information relating to the processing of your personal data.

Right to rectification: You have the right to ask us to correct your personal data if it is inaccurate or obsolete. If you have created a user account, you can correct some of your information by visiting your account.

Right to erasure: In certain circumstances, you have the right to request the deletion of your personal data. Please note that your personal data may only be deleted when they are no longer necessary for the purposes for which they were collected and that we have no other legal basis for processing them.

Right to object: where we are relying on a legitimate interest, you may object to the processing when your situation justifies it. In some cases, we may not grant your request if we demonstrate that the legitimate interest we are pursuing prevails. You also have the right to object to the processing of your personal data for direct marketing purposes at any time and without justification.

Right to restriction: You may request a suspension on the use of your personal data in certain circumstances, such as when the data is no longer necessary or no longer necessary, or, if you have contested its accuracy, until we can verify its accuracy.

Right to data portability: We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used and machine-readable format. Please note that this right only applies to your personal data that we process automatically, (i) with your consent or (ii) in the context of the performance of a contract with you.

Use of your data after death: You can send us specific instructions regarding the retention, erasure and disclosure of your data after your death.

In addition, if the processing of your personal data is based on your consent, you also have the right to withdraw your consent at any time.

You will not have to pay a fee to access your personal data or to exercise any of the other rights referred to above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to respond to your request in these circumstances.

We may ask you for specific information to help us confirm your identity and respond to your request. We try to respond to all legitimate requests within one month.

9. Contact us for more information

If you have any questions about how we use your personal data or if you wish to exercise any of the above rights, you can contact us by email or registered mail:

·         legal@fair-ezone.com

·         Fair-eZone (Privacy), 20 Bis, rue Louis-Philippe 92200 Neuilly sur Seine, France.

Fair-eZone does not receive clients at its head office address or at any other address.

No request can be treated in person, nor can any customer be received physically at the head office address or at any other address. Any questions or requests will be dealt with remotely by the relevant department as indicated above.

You may also file a complaint with the Commission nationale de l’informatique et des libertés (CNIL).

10. Policy updates

We may amend this Policy from time to time. We ensure that the most recent version is published on the Site. When significant changes are made to the Policy, we will notify you by posting a notice online and/or sending you an email.

The Policy was last updated on December 7^th, 2021.