Privacy Policy of MeghnaPay, a Digital Wallet of Meghna Bank Limited

This Privacy Policy explains how we, Meghna Bank Limited. ("MeghnaPay," "we", "us", "our", “MGBL”), collect, process and use information of our users (hereinafter addressed as "Users", "you", "your", "yourself", “MeghnaPay Customer”). Your consent to this Agreement is exerted when you sign up for, access, or use the "Services" provided by us. You agree to allow us to use and disclose your personal information entered into our system according to the description of this Agreement.

1. Overview:

This Agreement applies to any use of our website, mobile application, electronic communications or services (the "Platform). The Platform may request you to provide your personal information in details, including but not limited to your National ID/ Passport Number/Driving License, Tax Identification Number (TIN), and/or bank account details, as required for the operation of the Platform and also for reducing the risk of fraudulent activities, money laundering and terrorist financing etc. We process your information with utmost importance, diligence, care and use this information conforming to the terms of this Agreement. The term "information" refers to any confidential and/or individually identifiable information or other information related to any User of the Platform in this Agreement. We shall not rent or sell your information to third parties for their marketing purposes without your explicit consent. In case we need to convey your information to any third party for completing your requested service, we shall share the required information under strict restriction and adhering to this Agreement. If you use any third party website via the Platform or use third party website to access the Platform, you shall be responsible for reviewing the privacy policy statements of those websites. Meghna Bank Limited shall not be responsible for the privacy practice of any third parties.

2. Information:

2.1 Basic Information:

In order to sign up for MeghnaPay account or use MeghnaPay Services, you must provide your name, phone number and other contact details, NID/Driving License/Passport/Birth Registration number applicable, and other required identification information. We may also request you to provide other verification documents before processing any transaction which is not consistent with your regular transaction or is of a very high amount. You agree to cooperate with MGBL in this process by providing all the required information and/or documents. We collect personal information those you provide to us or over the Platform through correspondence, chats, or any other way, or shared by you from other social websites, services and/or applications; or any additional information (personal or otherwise) that you may be asked to provide as and when necessary. We collect public information about your business size, customer base and usual transactions that might be collected from social media platform, other MeghnaPay account holders or other sources for accessing goodwill, trustworthiness and solvency to check your account and business.

2.2 Device Identification:

MeghnaPay collects information from your interaction with our Platform, Services, content and advertising, including but not limited to device ID, device type including the hardware model, operating system and version, unique device identifiers and mobile network information, location, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address, information collected by cookies and other tracking technologies, standard web log information and other identifying information about the computer or device that you use to access your MeghnaPay account shall be tracked for helping us detect possible instances of unauthorized transactions and shall be used by MGBL to provide smooth experience of MeghnaPay services.

MeghnaPay will access your SMS for OTP auto read during Self register and imei reset for verification of the MeghnaPay accountholder against the Mobile SIM inserted in the handset to provide you more secured access to MeghnaPay App. Also MeghnaPay will access your contact information from Phonebook for convenient usage of MeghnaPay App.

2.3 Transaction Information:

For complying with anti-money laundering and counter terrorism obligations under the applicable Laws including but not limited to the Money Laundering Prevention Act 2012 (Amendment on 2015) and Anti-Terrorism Act 2009 (Amendment on 2013), and any other applicable, rules and regulations of the Government of the People's Republic of Bangladesh, your commercial and/or personal identification information shall be recorded. If you send or receive any high amount through the MeghnaPay Services, or are suspected of being engaged in any suspicious transaction, MGBL in collaboration with Bangladesh Post Office and other relevant authorities of the Government may conduct a background check on your business by gathering information about you and your business, its directors, shareholders, partners, officials and employees, as applicable. MGBL, at its sole discretion, reserves the right to periodically retrieve and review a business and/or consumer information and is authorized to close an account based on information obtained during these background check and reviews.

2.4 Web Caches and Website Traffic:

For ensuring smooth and efficient MeghnaPay Services, your IP address, browser, and time related information for accessing the Platform shall be stored in our server; web address of sites that routed you to or from the Platform may also be received. Session cookies, web cookies, pixel tags, web beacons or other similar technologies shall be used to place small text or image files in your computer/device for facilitating User friendly performance of the Platform.

2.5 Contacting Prospective Users:

When a MeghnaPay User attempts to send MeghnaPay Service request to Users who have not yet signed up in MeghnaPay, MeghnaPay may retain the service requested and information provided regarding the prospective User for contacting them for marketing purpose. For example, a text message or Interactive Voice Response ("IVR") may be sent to their number notifying them about the MeghnaPay Service you wanted to share with them.

2.6 Non-Personal Information:

MGBL may collect non-personal information as you use our Platform. When you use our Platform, third-party service providers, e.g. Google Analytics and other partners may also receive and record non-personal information from cookies, server logs, and similar technology from your browser or mobile device, including your IP address. We may combine the collected non-personal information with the personal information. Where we do so, we shall treat the combined information as personal information if the resulting combination may be used to readily identify or locate you in the same manner as personal information alone.

2.7 Aggregate Information:

MGBL collects non-identifying, general, generic and aggregate information to improve the design of the Platform and Services.

2.8 Restriction to Transfer:

The right to use this Platform is personal to the User and is not transferable to any other person or entity. You shall be responsible for protecting the confidentiality of your password(s), if any. It is agreed by you that, although the internet is often a secure environment, sometimes there are interruptions in service or events that are beyond the control of MeghnaPay, and MeghnaPay shall not be responsible for any data lost while transmitting information on the internet. MeghnaPay makes no representation that any Services are available or otherwise suitable for use outside of Bangladesh. If you choose to access the Platform from locations outside of Bangladesh, you do so on your own initiative and appreciating all the associated risks, however, MeghnaPay shall not be responsible for any consequences you may encounter thereof.

3. Use of Collected Information

3.1 Internal Use:

Your information shall be collected, stored and processed in servers located in Bangladesh, which shall be used to provide you with a smooth, safe, efficient and customized experience of the Platform. The provided information shall be used to process your transactions, troubleshoot problems, resolve disputes, provide customer support service, customize your Platform experience and any other issues.

3.2 Communicating with You:

We shall also communicate with you by using the information that you provided to complete processing of MeghnaPay Services or verify any important information or actions like investigating suspicious or illegal transaction, responding to customer service requests, complaints or claims.

3.3 Information Shared with Other MeghnaPay Users

Your basic information like name, phone number, email address, transaction amount and transaction time, etc. may be shared with other MeghnaPay Users or prospective User to whom you send MeghnaPay service request. The information that shall be shared may vary with the service you request and the type of MeghnaPay account you maintain; additional information about your business may be revealed if you are making transactions through a business account. When payments for goods or purchases are made through MeghnaPay, buyer's and seller's address and payment details may be revealed for aiding in delivery and dispute resolution.

3.4 Information Shared with Other Third Parties:

Several third parties like the regulatory authority, mobile operator and other service providers may need access to specific information for completion of your requested MeghnaPay Services. We shall only disclose the required information to third parties if we are under a duty to comply with the legal requirements, enforce our policies, and respond to claims that a listing or other content violates the rights of MeghnaPay or others, or protect anyone's rights, property, or safety. Such information shall be disclosed in accordance with applicable laws and regulations of the country. As stated above, we do not disclose your personal information to third parties for their marketing purposes without your explicit consent.

3.5 Your Use of MeghnaPay Information:

You shall receive information of other MeghnaPay Users when carrying out any transaction with them. You may only use this information for facilitating MeghnaPay Service related communication, action or transaction; this information shall not be used for any other purpose without taking explicit consent of the MeghnaPay user by disclosing the purpose adequately. We may send you email/SMS to verify your account and other transactional emails for operational purposes, such as billing, account management, or system maintenance. You may only stop receiving those emails/SMSs by terminating your account. We may also send you promotions, announcements, surveys, newsletters, developer updates, evaluations, and event information or other marketing or commercial e-mails/SMS. You may opt out of receiving these email/SMS communications from us at any time by unsubscribing, using the unsubscribe button within each email to have your contact information removed from our email list. Notwithstanding anything contained anywhere in this Agreement or the Terms & Condition, MeghnaPay shall not be responsible for any breach of privacy due to correspondence going to an incorrect address or phone number. You agree that we may use your personal information to inform you about our Services and tools, deliver targeted marketing and promotional offers based on your communication preferences, and customize measure and improve our advertising. We may also use and share non-personally identifiable information for our marketing purposes, including, without limitation to marketing on other websites, for e.g. use the information to control the number of times you have seen an ad, deliver ads tailored to your interests, and measure the effectiveness of ad campaigns.

3.6 Surveys and Questionnaires:

When you answer the optional questionnaire or survey, information provided therein may be used for improving MeghnaPay Services, marketing and/or advertising purpose as described in the survey.

3.7 Audit and Legal Compliance:

Your information and transaction history may be viewed by the auditors for confirming the accuracy of our record. However, auditors shall not have the right of using your personally identifiable information for any other purpose. Information related to illegal or suspicious activity carried out from your account shall be made available to law enforcing body, Bangladesh Post Office, Bangladesh Bank, competent courts of law or any other law enforcing agencies with applicable jurisdiction when requested.

3.8 Mergers or Acquisition:

If MeghnaPay merges with other company or is acquired by another company, the successor company will have access to your information maintained by MeghnaPay.

3.9 Public Information:

Any reviews, personal information or comments that you voluntarily post or disclose on public pages (for instance, the questions and answers page, Facebook page etc.) of MeghnaPay will be viewable by the general public. Any comment or other content you post or disclose on such public pages becomes published content including your account and User name and shall not be subjected to the terms and conditions of this Agreement. You shall be deemed to have waived the right to privacy and confidentiality over such information by posting or making such disclosure. MeghnaPay does not have Non-Disclosure and Confidentiality Agreements with these parties who may be able to access such information.

4. Cookies

4.1 Consent:

By using our Platform, using Services provided through the Platform, or receiving our emails, you consent to the use of cookies in accordance with this Agreement.

4.2 Intent:

This Agreement sets out how we, and third parties we authorize, use cookies when you interact through our Platform or the Services offered via the Platform. Our Agreement explains what we do (and don't do) with the information, including any personal data we may collect about you.

4.3 Meaning:

Cookies are unique identifiers, usually made up of small bits of text or code. Cookies are usually stored on your device or in your web browser and they send certain information back to the party who served the cookie. When we refer to cookies, we are actually referring to a broader range of technologies than just cookies, including web beacons, clear gifs, pixels and other similar technologies. When we refer to first-party cookies, we mean cookies that are served by MeghnaPay. When we refer to third party cookies we mean cookies that are served by non- MeghnaPay parties.

4.4 Use of Cookies:

Cookies may be used in order to better understand how Platform work and to optimize online and mobile experiences. Cookies do this by allowing the party serving the cookie to analyze a Platform's performance, to identify certain Users anonymously and remember their preferences, to better understand whether a computer or device (and probably its User) has visited a website previously and to serve personalized advertisements.

4.5 Types of Cookies:

Our Platform primarily uses the following four types of cookies:

4.5.1 Operations based Cookies:

These cookies are essential for the operation of our Platform. They make it possible for you to browse and use our Platform. If you disable these cookies, the Platform will not function correctly.

4.5.2 Performance based Cookies:

These cookies gather information about how visitors use the Platform and monitor Platform performance. For example, performance cookies tell us which pages are popular, monitor traffic to our Platform and compile anonymous analytic information. Performance cookies can also be used to identify and remedy operational problems with the Platform. Problems

4.5.3 Functionality based Cookies:

These cookies are used to recognize and remember your preferences. For example, functionality cookies may use information, such as your location, to make sure that you arrive at a version of our Platform that is specific to your city or region.

4.5.4 Advertising Preferences based Cookies:

We offer you choices about receiving interest-based ads from us. For this, we allow third parties to deliver personalized advertising content on our Platform and/or on third party websites and applications. These third parties use cookies to understand your interest in the advertisements and content delivered to you, as well as to serve you with more relevant advertisements based on your activities on our Platform. For example, third-party cookies could record information about whether you have clicked on certain content or advertisements on our Platform or other websites, or placed an item on our Platform in your shopping cart.

4.6 Control over Third Party Cookies:

We do not have control over, or access to, third-party advertising cookies or the information they contain. Third parties manage any information that they collect via cookies they place in accordance with their privacy policies. You can opt-out of third-party personalized advertising cookies. You will still see ads but they will not be personalized.

4.7 Cookies and Browser settings:

You may be able to avoid certain cookies by configuring your browser settings or opting-out directly with the party that operates and controls the cookie. Please check your browser settings for more information.

4.8 Cookies in E-mails:

Our emails contain cookies that track whether you open our emails and whether you click any links within them. The cookies used in our emails to monitor these behaviors are unique to each email and are not stored on your computer or mobile device.

5. User's Responsibility

The Services and use of the Platform do not include the provision of necessary equipment to access the Platform. To use the Platform, you will require internet connectivity and appropriate telecommunication links. The User shall be responsible for obtaining and maintaining all telephone, computer hardware, software and other equipment needed for access to and use the Platform and all charges related thereto. MGBL shall not be liable for any damages to the user's equipment resulting from the use of this Platform.

6. User Conduct

6.1 The User undertakes without limitation, not to use or permit anyone else to use the Services or Platform:

6.1.1 to upload, send or receive any information for which the User has not obtained all necessary license and/or approvals (from us or third parties); or which constitutes or encourages conduct that would be considered a criminal offence, giving rise to any civil or criminal liability or otherwise be contrary to the law of or infringe the rights of any third party in any country in the world;

6.1.2  to upload, send or receive any material which is technically harmful (including computer viruses, logic bombs, Trojan horses, worms, harmful components, corrupted data, malicious software, harmful data, or anything else which may interrupt, interfere with, corrupt or otherwise cause loss, damage, destruction or limitation to the functionality of any software or computer equipment);

6.1.3 to intercept or attempt to intercept any communications transmitted by way of a telecommunication system;

6.1.4 for a purpose other than which we have designed them or intended them to be used;

6.1.5 for any fraudulent purposes in any way which is calculated to incite hatred against any ethnic, religious or any other minority or is otherwise calculated to adversely affect any individual, group or entity;

6.1.6 to upload, send or receive any material, which is not civil or tasteful;

6.1.7 to upload, send or receive any material, including User content, which is unlawful, harmful, tortious, threatening, abusive, harassing, hateful, racist, homophobic, infringing, pornographic, violent, misleading, racially discriminatory,  grossly offensive, of an indecent, obscene or menacing character, blasphemous or defamatory or of a libelous nature of any person or entity, in contempt of court or in breach of confidence, or which infringes the rights of another person or entity, including copyrights, trademarks, trade secrets, patents, rights of personality, publicity or privacy or any other third party rights;

6.1.8 to cause annoyance, inconvenience or needless anxiety.

6.2 Forbidden uses: The following uses of the Platform are expressly prohibited and you undertake not to do (or to permit anyone else to do) any of the following:

6.2.1 Resell the Platform;

6.2.2 Furnish false data including false names, addresses and contact details and fraudulent use of credit/debit card numbers;

6.2.3 Attempt to circumvent our security or network including accessing data not intended for you, logging into a server or account you are not expressly authorized to access, or probe the security of other networks (such as running a port scan);

6.2.4 Access the Platform in such a way as to, or commit any act that would or does, impose an unreasonable or disproportionately large burden on our infrastructure or that otherwise interrupts or interferes with its functionality, efficiency or operation;

6.2.5 Execute any form of network monitoring which will intercept data not intended for you;

6.2.6 Send unsolicited mail messages, including the sending of "junk mail" or other advertising material to individuals who did not specifically request such material. You are explicitly prohibited from sending unsolicited bulk mail messages. This includes bulk mailing of commercial advertising, promotional, or informational announcements, and political or religious tracts. Such material may only be sent to those who have explicitly requested it. If a recipient asks to stop receiving email of this nature, you may not send that person any further email;

6.2.7 Create or forward "chain letters" or other "pyramid schemes" of any type, whether or not the recipient wishes to receive such mailings;

6.2.8 Send malicious email, including flooding a user or site with very large or numerous emails;

6.2.9 Enter into fraudulent interactions or transactions with us or a Seller (which shall include entering into interactions or transactions purportedly on behalf of a third party where you have no authority to bind that third party or you are pretending to be a third party);

6.2.10 use the Platform (or any relevant functionality of either of them) in breach of this Agreement;

6.2.11 use in an unauthorized manner, or forge, mail header information;

6.2.12 engage in any unlawful or criminal activity in connection with the use of the Platform or any Voucher; or

6.2.13 copy or use any User content for any commercial purposes.

6.3 Any conduct by a User that in MeghnaPay exclusive discretion is in breach of the Agreement or which restricts or inhibits any other User from using or enjoying this Platform is strictly prohibited. The User shall not use this Platform to advertise or perform any commercial, religious, political or non-commercial solicitation, including, but not limited to, the solicitation of Users of this Platform to become users of other online or offline services directly or indirectly competitive or potentially competitive with Agreement.

6.4 MGBL reserves the right to prevent you from using the Platform and to prevent you from making any purchase, if your conduct is found to be in question or contravention of the terms of this Agreement.

7. Your Information is Secured:

We maintain and process your information with the highest level of integrity. Our firewalls, data encryption and computer and network safeguard your information around the clock. Only authorized employees may access our office, network and files for completing the actions needed for smooth functioning of the system. We shall, however, not be responsible for any breach of security or for any actions of any third parties that receive your personal information.

You may always review and change your personal information from the account setting page of your MeghnaPay account. You may also close your account at any time if there is no investigation being conducted against it. After you close your account, we shall mark your account status as 'Closed' and keep your information in our database for future reference.

8. Force Majeure:

Without prejudice to any other provision herein, MeghnaPay shall not be liable for any loss, damage or penalty as a result of any loss of information due to any cause beyond MeghnaPay’s control, including, without limitation, acts of the User, governmental act, any unlawful access to MeghnaPay’s information i.e. hacking or acts of God etc.

9. Severability:

If any provision of this Agreement is held invalid by a court of competent jurisdiction, such invalidity shall not affect the enforceability of any other provisions contained in this Agreement and the remaining portions of this Agreement shall continue in full force and effect. The failure of either party to exercise any of its rights under this Agreement shall not be deemed a waiver or forfeiture of such rights.

10. Governing Law:

These Privacy Policies and its performance shall be governed by and construed in all respects in accordance with the laws of Bangladesh.