This policy explains the privacy of the personal information we may collect from you and the purposes for which it will be used. By using this website/application, you agree to the data practices described in this policy.

Who owns this website/application?

The website/application is owned by Zaho Electronic Payment Services – Ganzour, Tripoli, Libya. Registered trade name: Hawelli (حوّلي).

What information do we collect and how do we use it?

Depending on the services you use through the website/application, we may collect different types of information. These types and their uses are explained below:

Information you provide to us

We collect and process information you may provide for specific purposes, such as your name, email, location, national ID, passport number, and phone number.

We use these details to provide information about any product or service you request from us and to communicate with you. If you contact us through some services on the website/application, we may request additional information to provide a more tailored response to your needs.

Who do we share your personal data with?

We share your personal data only with the following entities and for the purposes mentioned above:

• Business and banking partners (e.g., local cards).
• Financial, judicial, or governmental authorities, as required by law.
• Certain regulated professionals (e.g., lawyers and auditors).

Why and on what basis do we use your personal data?

(A) To comply with legal and regulatory obligations

We use your personal data to meet various legal and regulatory requirements, including:

• Anti-money laundering and combating terrorism financing.
• Compliance with international sanctions and embargo laws.
• Tax compliance and reporting obligations.
• Adherence to banking and financial regulations, including:
  • Implementing security measures to prevent misuse and fraud.
  • Monitoring transactions outside your usual activity.
  • Assessing credit risk and repayment capacity.
  • Risk monitoring and reporting.
  • Responding to official requests from competent public or judicial authorities.

(B) To perform a contract with you or take pre-contractual measures upon your request

We use your personal data to conclude and execute contracts with you, including:

• Providing information about our products and services.
• Assisting you and responding to your requests.
• Assessing the conditions under which we can provide a product or service to you.
• Providing products or services to corporate clients you are associated with.

(C) For our legitimate interests

We use your personal data to develop our products and services, improve risk management, and defend our legal interests, including:

• Transaction verification.
• Fraud prevention.
• IT management (infrastructure, business continuity, cybersecurity).
• Creating statistical models through transaction analysis (e.g., credit risk assessment).

In these cases, data is aggregated and anonymized to provide general market insights.

Customizing our commercial offers by:

• Improving the quality of banking, financial, and insurance services.
• Offering products and services suitable to your profile.

This is done through:

• Segmenting customers and interested parties.
• Analyzing usage patterns and preferences (branch visits, emails, website visits, etc.).
• Sharing data with another company in the same group if you are or may become a client.
• Tailoring offers based on the products or services you already have.
• Monitoring transactions to detect unusual activities (e.g., unusually large deposits).

(D) Respecting your choices when we ask for your consent

In some cases, we require your consent to process your data, such as:

• When processing involves automated decisions that legally or significantly affect you.
• When data is processed for purposes other than those mentioned above, where we notify you and request consent if necessary.

How long do we keep your personal data?

We retain your personal data for the longer of:

• The period required by applicable laws and regulations, or
• The period necessary for operational purposes (e.g., account management, customer relationship management, responding to disputes or regulatory authorities).

For clients, most data is retained for the duration of the contractual relationship and up to 10 years after its termination.

Website/Application Usage Information

We collect and store some information every time you interact with us. We gather usage data during your visit to our website/application, including date, time, pages viewed or searched, and other browsing activity.

We may also use this information to generate statistical data about website/application usage, which can be used or shared with third parties for marketing or business strategy purposes, without identifying any individual.

We collect usage information to help us:

• Develop and provide services and information that better meet your needs.
• Inform you about events, services, and products we believe may interest you.
• Communicate with you if you have agreed to it.

IP Addresses

We use IP addresses to analyze trends, track user movement, and collect general demographic information for analytical purposes. IP addresses are not linked to personally identifiable information.

Cookies

When visiting our website/application, we collect standard internet log information and visitor behavior patterns. This is to understand the number of visitors to different sections of the website/application. Data is collected in a way that does not identify any individual.

Our visitor analysis tool uses cookies, which are text files placed on your device to collect information. You can choose to accept or reject cookies via your browser settings.

Links to Other Sites

This website/application may contain links to other sites. A link to a third-party site does not necessarily imply endorsement of its content. You should use your judgment to evaluate the suitability of information or services on those sites. Lack of a link does not imply a site is inappropriate.

Linked sites are reviewed regularly based on customer usage and feedback.

We are not responsible for the content of any linked site, nor for the consequences of using the information or services therein. We also do not guarantee that links will always work.

Third-party sites may have terms and conditions different from ours; do not assume our terms apply to them.

Third-party Content

We may display external content embedded from other sites such as YouTube or social media platforms. This content is not published directly on our website/application but is displayed via tools and services provided by those sites. We are not responsible for this content.

Virus Protection and Security

We regularly test our website/application during development, but you should take precautions to ensure that your access does not expose you to risks such as viruses or malware. It is always recommended to use antivirus software on any files downloaded from the internet.

Changes to This Policy

The privacy policy may change from time to time as we develop services and information on the website/application. Reviewing this page periodically ensures you are always aware of what information we collect, how we use it, and the circumstances under which we may share it with third parties.

You should review the privacy policy each time you use the website/application, even if you have visited it before, to ensure you are aware of the latest changes.

How to Contact Us

If you have any questions regarding the use of your personal data under this statement, please contact our Data Protection Officer: