YWO APP Privacy Policy

1. Your Privacy Matters

Thank you for your interest in our services. In order to provide you with our mobile application and related financial services, we are required to collect and process certain personal data about you and your activity.

This Privacy Policy applies to all personal data collected through the YWO mobile application ("App"), our official website (www.ywo.com), client portal, and any other online services, communications, or marketing channels operated by or on behalf of YWO (CM) Ltd (collectively, the "Services").

Where we provide services via affiliated entities, these companies act as data processors or joint controllers strictly in accordance with this Privacy Policy and applicable data protection laws.

By entrusting us with your personal data, we want to assure you of our commitment to keeping such information private. We have taken measurable steps to protect the confidentiality, security, and integrity of your data. We encourage you to review the following information carefully.

2. Grounds for Data Collection

Processing of your personal information (meaning any data that may potentially allow your identification; hereinafter "Personal Information") is necessary for the performance of our contractual obligations towards you, providing you with our services, protecting our legitimate interests, and complying with legal and financial regulatory obligations.

When you use our mobile application ("App"), or any related YWO (CM) Ltd ("YWO") services, you consent to the collection, storage, use, disclosure, and other uses of your Personal Information as described in this Privacy Policy.

This Policy ensures compliance with applicable data protection laws and Google Play's User Data, Personal and Sensitive User Data, and Account Deletion requirements.

3. How Do We Receive Information About You?

We receive your Personal Information from various sources:

• When you voluntarily provide us with personal details to create a YWO account (e.g., your name and email address);
• When you use or access our mobile application and related services (e.g., your financial transactions, deposits or withdrawals);
• From third-party providers and services, such as credit reference agencies, fraud prevention agencies, identity verification vendors, banks, authentication service providers, and public registers;
• Automatically through your device, including IP address, operating system, device model, and approximate location, for security and fraud prevention purposes.
• When you contact us through online forms, live chat, or by email, we collect the information you provide (such as name, email address, and message content) to respond to your inquiry or support request.

4. What Type of Information Do We Collect?

To provide you with our App and related services, we collect the following categories of information:

4.1. Personal Information

We collect the following Personal Information about you:

• Registration information – your name, email address, phone number, occupation, country of residency, and your age (to verify you are over 18 and eligible to participate in our service);
• Verification information – identification and address documents uploaded through the App (e.g., ID, passport, proof of residence);
• Financial information – since our services include financial transactions, we obtain financial details such as your payment details (e.g., bank account details and financial transactions performed through our services);
• Communication information – any data you provide when contacting support;
• Technical and device information – we collect technical details automatically when you use our services, including your IP address, MAC address, device approximate location, language preferences;
• Usage data – information about your activity within the App, session duration, and feature interactions.

4.2. Non-Personal Information

We may collect anonymized or aggregated data regarding your device or usage patterns to improve the App's functionality and user experience.

5. Tracking Technologies

When you use our App, we may use (and authorize third parties to use) cookies, pixels, and other similar technologies to collect information about your activity, device and preferences. These technologies help us enhance navigation, improve performance, conduct analytics, and personalize your experience. We may merge this data with other information we collect from additional sources.

Our App may also use third-party Software Development Kits (SDKs) for analytics, crash reporting, or authentication. These SDKs process limited technical data and are implemented in line with Google Play's privacy requirements. No personal or sensitive user data is sold or used for advertising.

5.1. Cookies and Website Tracking

When you visit our website or access the Client Portal through a web browser, we may use cookies and similar tracking technologies to enhance your browsing experience, analyze website traffic, and personalize content.

You can manage your cookie preferences through your browser settings or by adjusting preferences in the cookie consent banner displayed on our website. For more detailed information about how cookies are used, please refer to our Cookie Policy.

6. How Do We Use the Information We Collect?

• Provision of service – to provide and improve our services;
• Verification – to verify your identity and fulfill Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements;
• Marketing purposes – to send service updates, announcements, or marketing communications only where you have provided explicit consent (for example, via email or push notifications). You may withdraw your consent at any time by contacting us at support@ywo.com ;
• Financial purposes – to facilitate deposits, withdrawals, and other financial transactions securely and efficiently;
• Analytics, surveys, and research – to develop, evaluate, and improve our services;
• Protecting our interests – to investigate fraud, protect the security of our services, and defend against legal claims;
• Enforcing policies – to enforce our policies, including but not limited to our Terms or Client Agreement;
• Legal and regulatory compliance – to comply with our legal obligations, including those relating to anti-money laundering, sanctions screening, and financial supervision;
• User experience – to monitor performance, ensure the stability and security of the App, and improve the overall user experience.

We do not sell personal or sensitive user data under any circumstances.

7. With Whom Do We Share Your Personal Information?

We may share your information with:

• Internal parties – we share information with companies in our group and employees who need it to provide services to you;
• Financial providers and payment processors – we share relevant financial data to facilitate deposits, withdrawals and risk assessments in accordance with applicable financial regulations;
• Business partners – we share information with trusted third-party service providers, that assist in operating, improving, or securing our services, such as hosting, storage, analytics, and IT infrastructure partners;
• Marketing and analytics providers – when you visit our website or interact with our promotional materials, limited technical and engagement data may be shared with analytics and marketing platforms (e.g., Google Analytics, Meta Ads) strictly for performance measurement and campaign optimization. Such sharing is pseudonymized and does not include sensitive financial or identification data.
• Legal and regulatory entities – we may disclose personal data to regulatory authorities, law enforcements agencies, courts or other governmental bodies where required by law or regulation;
• Mergers and acquisitions – if we engage in a business transaction such as a merger or acquisition, your information may be shared with relevant parties subject to confidentiality obligations;
• Third-party SDK providers – when used within the App (e.g., for analytics or crash reporting), such providers receive only the minimum amount of non-identifiable technical data necessary for their function and must comply with Google Play's privacy, data security, and non-sale requirements.

All third parties are required to maintain strict confidentiality and use your data only for lawful purposes.

8. How We Protect Your Information

We implement administrative, technical, and physical safeguards to prevent unauthorized access, use, or disclosure of your personal information.

All communications between your device and our servers are encrypted using modern cryptography (HTTPS/TLS).

Access to personal data is limited to authorized staff and service providers who require it for operational reasons.

While we strive to protect your information, no online service is entirely risk-free. You should be aware that there is always some risk involved in transmitting information over the internet and always protect your login credentials and use secure passwords.

9. Retention

We retain your personal information as long as necessary to provide our App and services, comply with legal obligations, resolve disputes, and enforce our policies. Retention periods depend on the type of data and legal requirements.

Under applicable regulations, we maintain records containing client personal data, trading information, account opening documents, communications, and other relevant details as required by law.

Once the retention period expires, your data will be securely deleted or anonymized according to legal and regulatory requirements.

10. Account Deletion

If you have created an account within the App, you may request its permanent deletion by emailing support@ywo.com

Once verified, we will delete your account and all associated data unless specific information must be retained to comply with legal or regulatory obligations (for example, anti-money laundering requirements).

Temporary account deactivation, disabling, or "freezing" the App account does not qualify as account deletion.

11. User rights

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

• Access, correct, or delete your data;
• Restrict or object to processing;
• Withdraw consent (for example, for marketing);
• Request data portability.

You can exercise these rights by contacting support@ywo.com

12. Permissions and Disclosures

The App may request access to certain device features that are required for its secure and lawful operation, such as the camera (for liveness or documents uploads), storage (for file access), or approximate location (for fraud prevention).

12.1. Prominent disclosure:

Before any personal or sensitive user data is accessed, collected, or used, the App provides a clear, in-app disclosure explaining:

• The type of data being accessed;
• How and why the data is used and/or shared; and
• Whether any third-party SDKs are involved in the process.

12.2. Consent:

• Any such data access occurs only after the user provides explicit, affirmative consent, such as tapping "Allow" or checking a consent box.
• The App does not interpret navigation away, back-button presses, or inactivity as consent.
• Consent dialogs are displayed clearly within the App during normal use and before any data is collected or transmitted. Users can revoke these permissions at any time through their device settings.
• If third-party SDKs are used in the App, YWO ensures that they comply with Google Play's data access and consent requirements and that users are informed about such access within the App.

13. Children's Privacy

Our App is not directed to individuals under the age of 18. We do not knowingly collect or store data from minors.

If we become aware that personal data from a minor has been submitted through the App, we will promptly delete such information and take reasonable steps to remove it from our records.

We do not design, market, or configure our App, including any third-party SDKs, for use by children or for child-directed services.

If you believe that a minor has provided us with personal information, please contact us at support@ywo.com so that we can take appropriate action.

14. Group Entities and Data Responsibility

In some cases, your personal data may be processed jointly with other companies within the YWO Group, including YWO (PTY) Ltd (South Africa) and Novera Payments Ltd (Seychelles), depending on the jurisdiction and nature of the service provided.

Each entity processes data only to the extent necessary for providing regulated or payment-related services under its license and remains bound by the same privacy and confidentiality standards described in this Policy.

15. International Data Transfers

Your Personal Information may be transferred to, stored, and processed in countries where our servers or service providers are located.

We ensure all transfers comply with applicable data protection requirements and are covered by appropriate safeguards.

Where required by applicable law, we implement contractual or organizational safeguards to ensure an adequate level of data protection across all jurisdictions.

16. Updates to This Policy

This Privacy Policy may be updated periodically. The latest version will always be available within the App. In case of significant changes, we will notify you through the App or by email before the changes take effect. By continuing to use our services after updates take effect, you agree to the revised Privacy Policy.

17. How to Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your data, please contact us at support@ywo.com