1. Introduction

This Privacy Policy explains how PAY PLUS S.A.L ("PAY PLUS", "Company", "we", "our", or "us") collects, uses, stores, processes, shares, and protects personal information obtained from customers, users, agents, merchants, partners, and visitors who access or use the PAY PLUS Wallet, mobile application, website, payment services, money transfer services, foreign exchange services, card services, and any related products and services (collectively, the "Services").

By accessing, registering for, or using the Services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal information as described herein.

2. Scope

This Privacy Policy applies to all personal information collected through:

  • The PAY PLUS mobile application
  • The PAY PLUS website
  • Customer onboarding processes
  • Branches and agent locations
  • Customer support interactions
  • Payment, transfer, card, and wallet services
  • Any other services provided by PAY PLUS

3. Information We Collect

PAY PLUS may collect and process the following categories of information:

A. Personal Identification Information

  • Full name
  • Date and place of birth
  • Nationality
  • Gender
  • Government-issued identification details
  • Passport details
  • Residency information
  • Photographs and selfies
  • Biometric information where legally permitted

B. Contact Information

  • Mobile number
  • Email address
  • Residential address
  • Mailing address

C. Financial Information

  • Wallet account information
  • Bank account information
  • Card information
  • Transaction history
  • Source of funds information
  • Source of wealth information
  • Salary information where applicable

D. Transaction Information

  • Payment records
  • Transfer records
  • Foreign exchange transactions
  • Merchant payments
  • Bill payments
  • Cash-in and cash-out transactions
  • Card transactions

E. Technical Information

  • Device identifiers
  • IP addresses
  • Operating system information
  • Mobile network information
  • Browser information
  • Device location information where permitted

F. Compliance Information

  • AML/CFT documentation
  • Politically Exposed Person (PEP) information
  • Sanctions screening results
  • Risk assessment information
  • Regulatory reporting information

4. Purpose of Collection

PAY PLUS processes personal information for the following purposes:

A. Service Delivery

  • Opening and maintaining accounts
  • Processing transactions
  • Issuing cards
  • Facilitating payments and transfers
  • Providing customer support

B. Identity Verification

  • Customer identification
  • KYC verification
  • Authentication and security verification

C. Legal and Regulatory Compliance

  • Compliance with Lebanese laws and regulations
  • AML/CFT compliance
  • Sanctions screening
  • Fraud prevention
  • Regulatory reporting

D. Security and Risk Management

  • Detecting suspicious activities
  • Preventing fraud and financial crime
  • Managing operational risks
  • Investigating incidents and complaints

E. Product Improvement

  • Enhancing user experience
  • Developing new products and services
  • Conducting internal analysis and reporting

F. Communications

  • Sending notifications and alerts
  • Providing transaction confirmations
  • Sending service-related announcements
  • Responding to inquiries and complaints

5. Legal Basis for Processing

PAY PLUS processes personal information based on one or more of the following grounds:

  • Customer consent
  • Performance of contractual obligations
  • Compliance with legal and regulatory obligations
  • Protection of legitimate business interests
  • Fraud prevention and security purposes

6. Disclosure of Information

PAY PLUS may disclose personal information to:

A. Regulatory Authorities

Including but not limited to:

  • Banque du Liban
  • Special Investigation Commission (SIC)
  • Financial Intelligence Units
  • Courts and governmental authorities
  • Law enforcement agencies

B. Financial Institutions

  • Banks
  • Correspondent banks
  • Payment service providers
  • Card issuers
  • Money transfer operators

C. Service Providers

  • Technology providers
  • Cloud service providers
  • Verification providers
  • Fraud monitoring providers
  • Customer support providers

D. Professional Advisors

  • Auditors
  • External legal counsel
  • Consultants
  • Compliance advisors

E. Business Partners

  • Agents
  • Merchants
  • Card processors
  • Payment processors

Information will only be disclosed where necessary for the provision of Services, legal compliance, risk management, fraud prevention, or legitimate business purposes.

7. Banking Secrecy and Customer Consent

To the extent necessary for the provision of Services, compliance with applicable laws, and the execution of transactions, the customer expressly authorizes PAY PLUS to disclose relevant information to authorized third parties and competent authorities.

The customer acknowledges and agrees that such disclosure may constitute a waiver of banking secrecy protections to the extent required for the purposes described in this Privacy Policy and applicable agreements.

8. International Transfers of Information

Personal information may be transferred, processed, or stored outside Lebanon where required for:

  • Payment processing
  • Card services
  • Technology hosting
  • Fraud prevention
  • Regulatory compliance
  • Service delivery

PAY PLUS shall take reasonable measures to ensure appropriate protection of personal information when transferred internationally.

9. Data Retention

PAY PLUS retains personal information for as long as necessary to:

  • Provide Services
  • Comply with legal obligations
  • Meet regulatory requirements
  • Resolve disputes
  • Prevent fraud
  • Enforce contractual rights

Information may continue to be retained after account closure where required by law or regulatory obligations.

10. Data Security

PAY PLUS implements appropriate technical, administrative, and organizational safeguards to protect personal information against:

  • Unauthorized access
  • Accidental loss
  • Alteration
  • Disclosure
  • Destruction
  • Misuse

These measures may include:

  • Encryption
  • Access controls
  • Authentication procedures
  • Security monitoring
  • Employee confidentiality obligations

While PAY PLUS strives to protect personal information, no electronic transmission or storage method can be guaranteed to be completely secure.

11. Cookies and Similar Technologies

PAY PLUS may use cookies, device identifiers, analytics tools, and similar technologies to:

  • Improve platform performance
  • Enhance user experience
  • Analyze usage patterns
  • Prevent fraud
  • Maintain security

Users may modify device or browser settings regarding cookies; however, certain functionalities may be affected.

12. Customer Rights

Subject to applicable laws and regulations, customers may request:

  • Access to personal information
  • Correction of inaccurate information
  • Updating of information
  • Clarification regarding processing activities

Certain requests may be restricted where compliance obligations, legal requirements, or security concerns apply.

13. Marketing Communications

PAY PLUS may send promotional communications regarding products, services, offers, and campaigns.

Customers may opt out of marketing communications at any time, provided that service-related communications may continue where necessary.

14. Children's Privacy

PAY PLUS does not knowingly provide Services to minors except where legally permitted and properly authorized.

If PAY PLUS becomes aware that information has been collected contrary to applicable requirements, appropriate corrective measures will be taken.

15. Third-Party Websites and Services

The Services may contain links to third-party websites or applications.

PAY PLUS is not responsible for the privacy practices, content, or security of third-party platforms and encourages users to review their privacy policies.

16. Changes to this Privacy Policy

PAY PLUS reserves the right to amend this Privacy Policy at any time.

Updated versions may be published through the application, website, or other communication channels and shall become effective upon publication unless otherwise stated.

17. Contact Information

For questions, requests, complaints, or inquiries regarding this Privacy Policy, customers may contact:

PAY PLUS Customer Support

Address: El Emir Bachir St, Azariyeh Bldg, Block A2-1, 4th Flr, Downtown, Beirut - Lebanon

Telephone: 01988881

Email: [email protected]

By accessing or using the Services, you acknowledge that you have read, understood, and agreed to this Privacy Policy.