Ashirin Privacy Policy

1. This privacy policy (hereinafter: Privacy Policy) has been adopted by Ashirin (hereinafter: Ashirin). The Privacy Policy also applies to members of the Ashirin group, unless such members have adopted a separate privacy policy.

2. The Privacy Policy describes how and for which purposes Ashirin collects, processes and distributes information (including personal information, meaning any information that can be used to identify, contact or locate a specific person) provided by you or collected by Ashirin either on the website www.ashirin.com (hereinafter: Site) or when you use the services or products that Ashirin provides or may provide in the future (hereinafter: Services).

3. By using the Site or the Services, you are giving your consent to this Privacy Policy. Please read this Privacy Policy each time before using the Site or the Services and before submitting any information to Ashirin. Ashirin may change this Privacy Policy unilaterally and without prior notice, but any changes will be posted on the Site.

4. The privacy practices set forth in this Privacy Policy apply to the Site and Services only. If you link to other web sites (including sites that offer or use the Services or are promoted by Ashirin) or use the services of other service providers, please review the privacy policies posted at those web sites or by the relevant service providers.

1. Ashirin collects your information using two approaches. Firstly when voluntarily submitted by you on the Site (e.g. when you create an account), in the process of using the Services or in any communication (e.g. e-mails, skype chats) to Ashirin and secondly when obtained by Ashirin independently when you use the Site or the Services. The latter includes information which can be legally obtained using current technologies, for example information regarding your operating system, web browser, mobile network provider, country of residence, IP address, network connection, the device you use, the mobile payment services that you use, how you use the mobile payment services, what products you purchase etc.

2. The information that Ashirin collects differs between end users of the Services (e.g. consumers) and affiliates (e.g. publishers and developers). For example, from end users Ashirin may collect information such as name, phone number, e-mail address, payment data and statistics, country of residence, mobile network provider, type of mobile phone, operating system, payment behavior etc. From affiliates Ashirin may collect information such as names of representatives, identification details, country of residence, address, e-mail address, phone number, banking details etc.

3. Ashirin may collect and process (including automatically process)
i) your personal or corporate information (e.g. the names of representatives of affiliates, identification data of affiliates) primarily to identify you;
ii) your contact information (e.g. phone number, e-mail address) primarily to provide to you information and offers;
iii) your transaction information (e.g. what product or service you purchased, banking details of affiliates) primarily to correctly process your transactions;
iv) information regarding your preferences (e.g. what products or services you have most frequently purchased) primarily to be able to offer you related products or services;
v) information regarding your trustworthiness (e.g. data about payment behavior and violations) primarily for proper risk assessment, and
vi) your location information (mostly based on your IP address) for determining language preferences and for statistical purposes.

4. Additionally, Ashirin may collect and process the aforementioned information, information related to it and other information regarding you for the following purposes:
- deciding whether and on what terms to provide Services;
- provision of Services and customer support;
- processing and monitoring of transactions, the payment and billing thereof, and performance of other agreed tasks;
- understanding how you use the Services;
- resolution of disputes and enforcement of agreements;
- calculation and collection of fees;
- identification of you and verification of your transactions;
- prevention and investigation of prohibited or illegal activities or fraud;
- customization, updating, maintenance, protection and improvement of the Site and Services;
- provision of information, advertisements (including interest based advertisements), offers, update notices;
- comparison of information for accuracy, identification and verification with third parties;
- statistical, research and reporting purposes;
- to prevent money laundering and terrorist financing;
- other reasonable business-related purposes or purposes related to the above.

5. Ashirin may use your information to offer or advertise to you Services offered by Ashirin, other companies of the Ashirin group or contractors of Ashirin. You may choose to not receive such offers or advertisements by notifying Ashirin thereof.

6. Ashirin does not collect, share or process your sensitive personal information (religious or political views, health related information etc.) in any manner. Ashirin does not knowingly provide Services to, or collect personal information from, children 12 years old or younger.

1. The Site and Services may use cookies and other tracking technology depending on the features offered. Cookies and tracking technology are used for gathering information such as browser type and operating system, country of access, IP address, tracking the number of users, and understanding how you use the Site and the Services. Ashirin uses cookies and tracking technology to customize the Site and Services for users, to assess the use of the Site and Services and to improve the user experience and the overall quality of the Site and Services, but also to combat fraud and other violations. Personal information cannot be collected via cookies and other tracking technology, however, if you previously provided personally identifiable information, cookies may be tied to such information. Aggregate cookie and tracking information may be shared with third parties. Certain data may be stored locally on your device.

2. In the event you do not wish to receive cookies, you may configure your web browser to not accept cookies or to notify you if a cookie is sent to your device. You are free to decline cookies, but you may not be able to use all the features and the functionality of the Site or Services.

3. To find out which specific cookies the Site uses at any given time, please visit a specialized site and perform a cookie check on the Site. To opt out of being tracked by Google Analytics please visit https://tools.google.com/dlpage/gaoptout

1. Ashirin may share your information that Ashirin has collected when:
(1) permitted or required by law; or,
(2) trying to protect against, prevent, investigate actual or potential fraud, security issues, technical issues, unauthorized transactions or other violations; or
(3) trying to enforce the applicable terms of service or other agreements; or
(4) protecting against violations to the rights, property or safety of Ashirin, our users or the public as required or permitted by applicable laws; or
(5) you have given your consent to do so.

2. Ashirin may disclose your information to members of the Ashirin group or contractors of Ashirin (who may be located outside of the African Union) to process it for Ashirin, for the purposes of processing transactions, collecting fees, identifying you, but also for improving your user experience, performing business support functions or other related tasks, based on Ashirin’s instructions and in compliance with the Privacy Policy and any other applicable confidentiality and security requirements.

3. Affiliates (providers of content) whose content you have purchased, may have access to your mobile phone number and transaction history relating to specific content provided by that affiliate, mainly for processing transactions, customer support purposes (including for handling refund requests) and for proper delivery of content. Many of Ashirin’s affiliates are based outside of the African Union, therefore Ashirin cannot guarantee that they follow the same regulations with regard to personal information as required by African Union legislation.

4. Ashirin does not sell, lease, rent or make otherwise available your personal information to third parties for their marketing purposes without your explicit consent.

5. Ashirin may share non-personally identifiable information (e.g. general payment trends, statistics) publicly or with third parties. 

1. Your personally identifiable information is maintained and kept secure by applying physical, electronic and procedural measures conforming to industry standards. Only authorized employees, agents and contractors (who have agreed to keep information secure and confidential) of Ashirin have access to this information on a need to know basis. All emails, advertisements, promotions and newsletters from Ashirin allow you to opt out of further mailings.

2. Ashirin processes information on its servers. We may process your information on a server located outside your country of residence.

3. Ashirin shall maintain the information you have provided if so required or permitted by applicable legal acts for the duration stipulated in the applicable legal acts. 


Effective as of February 05, 2018