Privacy Policy — Virtual Equb

Effective Date: April 9, 2025

1. Introduction

Virtual Equb is a licensed digital financial service provider established to modernize the traditional Equb (rotating savings and credit) system through secure and innovative technology.

This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you interact with our mobile application, web platforms, or support channels.

It is prepared in compliance with the Ethiopian Personal Data Protection Proclamation No. 1321/2024 and applicable financial service regulations.

By creating an account or using the Virtual Equb app, you acknowledge that you have read and agree to this Privacy Policy.

2. Consent and Choice

By using our services, you consent to the collection, use, and sharing of your personal information as described in this Privacy Policy. You may opt-in to receive marketing communications and may opt-out at any time via your account settings or by contacting us at support@virtualequb.com.

We also use cookies for analytics and to improve user experience. You will be prompted to accept or reject non-essential cookies upon your first visit. You can adjust your cookie preferences in your device settings.

3. Scope & Purpose of this Policy

This Policy applies to all services offered by Virtual Equb PLC via:

• Virtual Equb mobile app
• Our official website (https://virtualequb.com)
• Partner integrations (Telebirr, NIB Tera SuperApp, CBE Birr, etc.)

We collect your personal, financial, or device data to deliver, improve, and secure Equb-based financial services, comply with financial regulations and anti-fraud obligations and communicate essential service updates and support users.

4. Data Controller

5. What We Collect

We collect only the minimum data required to deliver our services effectively and securely:

• Personal identity and account information: Full name, date of birth, gender, ID number, photo (if uploaded), address (city, sub-city, woreda, house number), and contact details (phone, email).
• Financial & transaction data: Payment IDs, transaction amounts, timestamps, sender/receiver details, payment method, and related KYC verification data.
• Device & technical data: Device type, OS version, app version, IP address, device identifiers, performance logs, and error/crash data.
• Usage & communication data: App activity (Equb participation, contributions, payout history), in-app support messages, and notification logs.

We do not collect biometric, health, or sensitive demographic data unless required for identity verification or fraud prevention.

6. Legal Bases for Processing

Your data is processed lawfully under one or more of the following bases:

• Contractual necessity – to deliver Equb services you request
• Legal obligation – to comply with financial and AML laws
• Legitimate interest – for fraud prevention, auditing, and platform security
• Consent – for optional data uses (analytics, surveys, or marketing)

7. How We Use Your Information

We use your personal data to:

• Register and verify users (KYC compliance)
• Facilitate payments, contributions, and payouts
• Provide customer support and service updates
• Monitor system performance and prevent misuse
• Fulfill legal and financial reporting requirements

Your data is not sold to third parties and is used only to operate and improve our services.

8. Data Sharing and Disclosure

We share data only under strict confidentiality and lawful necessity:

• Payment processors and banks – to execute transactions
• Regulators or authorities – when required by law
• Cloud service providers – for secure storage and analytics
• Auditors and compliance partners – for risk management

All third parties are contractually bound to data protection standards consistent with PDPP 1321/2024.

9. International Transfers

When transferring data outside Ethiopia, we ensure:

• Adequacy Decision: Transfer to countries with adequate protection
• Standard Contractual Clauses: EU-approved SCCs
• Binding Corporate Rules: Internal data protection standards
• User Consent: Explicit consent for transfers
• Data Minimization: Only necessary data transferred

10. Data Retention

We retain your data only as long as necessary for legitimate business or legal purposes:

• Transaction Data (10 years): Legal requirement for financial records
• Account Data (7 years): Tax and regulatory compliance
• Analytics Data (2 years): Service improvement and fraud prevention
• Support Messages (3-5 years): Quality assurance and legal protection
• Marketing Data (1 year): User consent period

Data is permanently deleted or anonymized after these retention periods.

11. Data Deletion and Account Termination

You may process or request account deletion anytime via the app or by emailing through support@virtualequb.com.

Once verified:

• Your account will be deactivated immediately
• Personal data will be deleted within 30 days, except records retained for legal or anti-fraud compliance

We will notify you when deletion is completed.

12. Security Measures

We apply multiple layers of protection, including:

• End-to-end encryption for sensitive transactions
• Secure authentication and session control
• Firewalls and regular system audits
• Access control for authorized personnel only

Sensitive financial data is never stored in plain text or shared outside licensed financial partners.

13. Automated Processing and Profiling

We use automated systems for:

• Fraud detection using machine learning algorithms
• Payment routing based on risk assessment
• System optimization

You have the right to:

• Request human review of automated decisions
• Contest automated decisions within 30 days
• Receive explanation of automated decision logic

14. Children and Minors

• Age Verification: Users must be 18+ to use the service
• Parental Consent: Required for users under 18
• Data Collection: No data collected from children under 18
• Special Protections: Enhanced security for any minor data
• Deletion Rights: Immediate deletion of any child data discovered
• Reporting: Report child data concerns to support@virtualequb.com

15. Communication and Service Updates

We use your contact information (such as phone number or email address) to send you important service-related messages including transaction alerts, Equb updates, payment confirmations, and security notifications. These communications are necessary for using the app and cannot be opted out of, as they form part of the core service functionality.

We do not send marketing or promotional messages through the app or by SMS/email. If we introduce marketing communications in the future, we will obtain your explicit consent and provide an option to unsubscribe.

16. User Rights

Under the PDPP 1321/2024, you have the right to:

• Right to Information: Know what data we collect and why
• Access and obtain a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your data
• Right to Data Portability: Receive data in structured format
• Right to Object: Object to processing of your data
• Right to Restrict Processing: Limit how we use your data
• Right to Withdraw Consent: Revoke consent at any time

To exercise your rights, contact: support@virtualequb.com

17. Policy Updates

We may periodically revise this Privacy Policy.

Significant updates will be communicated through in-app notifications or email.

Your continued use of the service after changes indicates your acceptance of the updated policy.

18. Data Breach Notification

If a data breach occurs that may affect your personal information, we will:

• Notify affected users within 72 hours of discovery
• Provide details about the breach and potential impact
• Explain steps taken to address the breach
• Offer guidance on protective measures users can take
• Report to relevant authorities as required by law

Contact for breach reports: security@virtualequb.com

19. Cookies and Tracking Technologies

We use the following types of cookies:

• Essential Cookies: Required for app functionality
• Analytics Cookies: Google Analytics, Firebase Analytics
• Preference Cookies: User settings and preferences
• Marketing Cookies: Advertising and promotional content

Cookie Management:

• Accept/Reject: Available in app settings
• Browser Settings: Manage cookies through device browser
• Third-party Opt-out: Available through provider websites

20. Marketing Communication Management

20.1 Opt-out Methods:

• In-app settings: Settings > Notifications > Marketing
• Email: Reply "STOP" to marketing emails
• SMS: Reply "STOP" to marketing SMS
• Website: Unsubscribe link in all communications

• Processing Time: Opt-out processed within 24 hours
• Confirmation: Users receive confirmation of opt-out
• Re-subscription: Users can opt back in anytime
• Contact: For marketing opt-out issues, contact marketing@virtualequb.com

21. Data Subject Request Procedures

21.1 Request Methods:

• Email: privacy-requests@virtualequb.com
• In-app: Settings > Privacy > Data Requests
• Mail: Physical address for written requests

• Required Information: User ID, verification documents
• Processing Timeline: 30 days maximum
• Response Format: Written response with requested data
• Appeal Process: Appeal denied requests within 30 days
• Verification: Identity verification required for all requests
• Fees: No fees for standard requests; fees may apply for excessive requests