PRIVACY POLICY

MyneHub Ventures S.L. (“MyneHub”) values your privacy and the protection of your personal data. This Privacy Policy describes how we collect, store, use, protect, and disclose your information when we provide you with our products and services.

Please be aware that because this Policy describes the privacy practices of all our services, some parts of the Policy may not apply to you. Also, if you have a separate contract for any Service, that contract may describe how we process information about you. If a portion or section of this Policy conflicts with local laws or regulation, those laws or regulation will supersede said section.

By using this App and MyneHub’s products and services (collectively, “Services”), you are acknowledging and accepting the practices described in this Privacy Policy. Your use of the Services is also subject to our Terms and Conditions. In this Privacy Policy, the word Services refers to, collectively, the MyneHub mobile application (the “Platform”), the transactional functionalities of the Platform, and any functionalities provided by MyneHub via the Platform. Unless referred to individually in the document, "we", "us", "our" and "MyneHub" refers to MyneHub and "you" and "user" refers to you, the user of MyneHub’s Services.

MyneHub’s Platform is used by third-parties to provide you with additional products and services, such as payment instruments, airtime lending, Fintech credit and/or loan products, among others and our Platform may be used by those third-parties to collect and process your personal data (“Third-Party Services”). This Policy does not apply to those Third-Party Services nor to products, services, websites, and mobile applications not provided by MyneHub. We recommend that you read the privacy policies of such third parties. We are not responsible for the privacy practices or content of any such third parties’ websites, products, or services.

This Privacy Policy may change from time to time. Any updates will be posted on MyneHub’s Platform and website and, where appropriate, notified to you. Your continued use of the Services after we make changes to this Privacy Policy will be deemed acceptance of those changes, so please check this Policy periodically for updates. If at any time you find this Policy unacceptable, you should cease using the Services. This Privacy Policy has been developed and is maintained in accordance with all applicable laws and regulations.

1. GENERAL INFORMATION

The personal data of users of MyneHub’s Services that are collected and processed through:

• MyneHub mobile application (Available on Google Play); or
• https://www.mynehub.com

Will be under the responsibility and in charge, as data controller, of:

• MyneHub Ventures S.L.
• Principe de Vergara 112, Utopicus, floor 2, Madrid 28002
• Email: privacidadMH@mynehub.com

2. ACKNOWLEDGEMENT OF THE PROCESSING OF YOUR INFORMATION

By downloading and using the Platform, registering as a user, using any Third-Party Services, performing transactions using our Platform, using the functionalities available on the Platform, contacting us through our contact details or providing us with personal information to communicate with you, you acknowledge that we will collect, store and use your information under the terms set out in this Privacy Policy and those of the providers of Third-Party Services.

3. TYPES OF INFORMATION COLLECTED AND HOW WE USE IT

The Platform enables us to collect the personal data listed below on our behalf as data controllers and on the behalf of providers of Third-Party Services as data processors. In general, we use the information we collect primarily to:

Please note that this personal data may be processed by MyneHub using artificial intelligence systems, in accordance with applicable laws and this Privacy Policy, as necessary for the provision of Services to you or, otherwise, with your explicit consent. In case that the use of such artificial intelligence systems leads to automated decisions that produce legal effects or similarly affects you significantly, you will be provided with meaningful information about the logic involved and the significance and envisaged consequences to you. In addition, you will be able to exercise your right not to be subject to automated decisions as explained in the Rights section (below).

3.1 Information collected to provide MyneHub Services:

• Registration:
  • Phone Number
  • Device Data
  • Username
  • Password
• Platform Functionality Data
  • Device Information (brand, model, CPU, etc.): understanding the various devices users employ allows MyneHub to optimize the Platform’s performance across different hardware configurations, ensuring a smooth and responsive experience for all users. It helps tailors the Platform’s interface and features to match the capabilities of the user's device, leading to improved user satisfaction.
  • Localization: localization allows the Platform to meet the cultural, linguistic, regulatory, and functional preferences of different target markets, enhancing user experience and compliance. It also allows for the Third-Party Services to be customized to the different locations (points of cash-outs, points of cash-ins, etc.).
  • Installed Apps: knowing which mobile apps are installed in user’s devices helps MyneHub identify popular apps and services among its user base, as necessary to guide integrations or partnerships that enhance the app's value proposition and help in troubleshooting conflicts between apps that could affect the Platform’s functionality.
  • Device Battery Level: monitoring battery level can allow MyneHub to optimize app performance to consume less power, especially in critical battery situations, enhancing user experience by ensuring the Platform does not drain the device's battery excessively.
  • Information Collected Automatically: By accessing and using the Platform, you automatically provide us your IP address and referrer URLs.
  • Firebase (Mobile app): We use Firebase Crashlytics and Firebase Analytics provided by Google and certain functionalities such as Firebase Crashlytics, Firebase Analytics, Google Analytics, Cloud Firestore, Firebase Performance Monitoring, Firebase Dynamic Links, Firebase Authentication, etc. These tools and technologies collect and analyse certain types of information, such as feature usage metrics and statistics, usage history, unique device identifiers and other similar information. The information generated by Firebase may be transmitted to and stored by Google on servers in the United States. We use Firebase to improve our Platform. Please refer to Firebase's privacy policy: https://firebase.google.com/support/privacy.
• Compliance, Fraud Prevention and Security
  • Mobile Number, Sim Card Data, Network, and OS Information: this data is crucial for implementing two-factor authentication and verifying user identity. Analyzing network and OS details can help in detecting anomalies or patterns indicative of fraudulent activities, such as logins from previously unknown networks or devices, which could indicate account compromise. SIM card data enables MyneHub to identify potential SIM swapping attempts, acting as fraud prevention and securing user accounts.
  • Accounts, Apps Usage: information on how and which apps are used can help in detecting unusual patterns that deviate from the user's normal behavior, potentially signaling account takeover or fraudulent transactions.
  • System Location, Mobile Network, and SIM Cards Data: collecting detailed location and network information can support compliance with anti-money laundering (AML) laws by tracking transactions back to specific devices and locations.
  • Contact information: We may access some user personal information, such as name and email address, when the user or any third party communicates with us through our contact information. Personal information provided through our contact information is not stored on any MyneHub server and will be stored on the respective server of our email service. We may use your contact information to send you relevant information about MyneHub and the Platform, including technical notices, updates, security alerts, and support and administrative messages.

3.2 Information collected to provide Third-Party Services:

As detailed above, MyneHub’s Platform is used to provide users with certain Third-Party Services. Regarding these Third-Party Services, MyneHub will process your personal data as data processor, on behalf of the relevant provider of Third-Party Services. By using our Services, you are informed that it will be necessary to collect and share your personal and financial information with third-party institutions offering services and products through the Platform as part of the application process for Third-Party Services. This sharing is integral to providing you with the requested services, enabling these third-parties to determine eligibility, facilitate transactions, perform credit checks, offer personalized financial solutions and send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages. Your data is shared securely and only with institutions that you have agreed to engage with, in alignment with our commitment to your privacy and data protection.

THE PRODUCTS AND SERVICES OFFERED BY THIRD-PARTIES ARE SUBJECT TO THE PRIVACY POLICIES OF SAID THIRD-PARTIES. IF YOU DECIDE TO CONTRACT ANY PRODUCTS OR SERVICES OF THIRD-PARTIES, THOSE THIRD-PARTIES ACT AS INDEPENDENT DATA CONTROLLERS WITH RESPECT TO SUCH PRODUCTS AND SERVICES, NOT MYNEHUB.

Although this Policy does not apply to those Third-Party Services nor to products, services, websites, and mobile applications not provided by MyneHub, the following information may be collected on their behalf through the Platform:

• KYC and Identity Data: during the KYC (Know Your Customer) and eligibility process, we collect and store your personal information, including but not limited to:
  • Full name
  • Date of birth
  • National identification number
  • Identification documents (ID, driver's license)
  • Financial information (bank statements)
  • Utility bills
  • Contact information (address, phone number, email)
  • Emergency contact information
• Digital Wallet Data: When you use Third-party digital wallet services through the Platform, we collect and store data related to your financial transactions, including:
  • Transaction history
  • Wallet balance
  • Payment information
• Other Data: We may also collect other data from third-parties, including:
  • Credit bureau data to evaluate loan applications
  • Utility company data to verify identity

4. GOOGLE PLAY

The Platform will be available for download through Google Play, managed by Google LLC. By using the Platform, you acknowledge and agree that Google's terms of service and privacy policy will also apply in connection with the download, installation, and use of the Platform. Google Play terms of service and privacy policies are alien to MyneHub, so if you have any doubt regarding them you must contact Google LLC at the addresses specified therein. We encourage reviewing both the Google Play terms and conditions and the Google Play privacy policy, in addition to this Privacy Policy before downloading the Platform from Google Play.

By using the Platform, the user agrees that certain personal and usage information may be processed by Google for the purpose of improving the user experience, performing analytics, and providing related services. This may include, but is not limited to, usage data, geographic location, user preferences, and other relevant data. Google's collection, use, and sharing of this information will be subject to its own privacy policies.

5. HOW LONG WE KEEP YOUR DATA

Personal data provided by users through the Platform related to MyneHub’s Services will be retained for the time necessary to provide the functionalities available on the Platform, fulfil the legitimate purposes described in this Policy or until the user decides to close the user account or requests the deletion of their data. Thereafter, MyneHub may retain personal data for a period of [6] years as necessary for the purposes of attending to legal or contractual liabilities that may be applicable or a longer period provided that this is required for compliance with a legal obligation or by order of an authority. Once the retention period has expired, the personal data will be deleted. Therefore, the right of access, the right of deletion, the right of rectification and the right to data portability cannot be asserted after the retention period has expired. Personal data gathered through the Platform on behalf of providers of Third-Party Services will be kept as per their respective privacy policies.

6. HOW WE SHARE INFORMATION

We may share any of the information we collect from or about you when you direct us to do so, if necessary, to provide the MyneHub Services to you, to respond to legal process, to protect our property and the safety of our employees and as necessary for the provision of the Third-Party Services. We may also share information with partners to help market and advertise Third-Party Services. Please see Your Options and Rights Regarding Your Information (below), which explains how you can opt-out of our uses or disclosures of information for marketing or advertising purposes. How we share customer information is further described below.

• Third-Parties offering services in our Platform: As part of the Platform Services, we may share information with Third-Parties offering products and services in our Platform when you decide to engage with them.
• Affiliates: We may share information with other members of our international group of companies (the “Liberty Latin America Group”). A complete list of MyneHub’s affiliates may be found here https://lla.com/our-brands.
• MyneHub Service Providers: We use third-party services to perform certain functions on our Platform. Some of these functions and services include: hosting the mobile application (Google Play), card processing (Evertec), card tokenization (HST), sending e-mails, performing tracking and analytics functions on the Platform (Firebase Crashlytics, Firebase Analytics). These service providers and tools may have access to personal information needed to perform their functions but may not use that information for other purposes. Information shared with these third-party services will be treated and stored in accordance with their respective privacy policies and our Privacy Policy.
• Marketing: By using our services and Platform, you understand we may use your personal information, including name and email address, for the sole purpose of sending marketing communications about the Third-Party Services offered through the Platform. MyneHub respects your privacy and does not share this information with unaffiliated third parties. For information on how to stop receiving marketing communications, please refer to the respective privacy policy of the providers of Third-Party Services. For additional opt-out information, please refer to the Rights section of this Policy.
• Advertising Partners: We may partner with companies that assist us in advertising our services, including partners that use cookies and online tracking technologies to collect information to personalize, retarget, and measure the effectiveness of advertising.
• Sale, Merger or Acquisition: We may change our ownership or corporate organization while providing the Services. We may transfer to another entity or its affiliates or service providers some or all information about you in connection with or during negotiations of any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot guarantee that an acquiring party or the merged entity will have the same privacy practices or treat your information as described in this Policy.
• Protection of MyneHub and Others: We release personal information when release is necessary to comply with the law, enforce or apply our terms and conditions and other agreements, or protect the rights, property, or safety of MyneHub, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
• Anonymous Information: MyneHub uses anonymous information collected automatically by our servers primarily to help us administer and improve the Platform. We may also use aggregated anonymous information to provide information about the Platform to potential business partners and other unaffiliated entities. This information is not personally identifiable.
• Law Enforcement and Governmental Entities: If allowed by and after complying with applicable local laws requirements, we may disclose your information to representatives of a government or to comply with valid legal processes.

7. INTERNATIONAL DATA TRANSFER

We are part of the Liberty Latin America Group and may collect, process, and store your information in various countries. We may also transfer your information within the Liberty Latin America Group and to our service providers. The data privacy laws governing the use and transfer of data in other countries may not be the same as those in your country; however, we will ensure that an adequate level of protection is provided to protect your information. For further information regarding the international transfers of data carried and the safeguards adopted, please contact us via privacidadMH@mynehub.com.

8. PROTECTION OF YOUR INFORMATION

We use administrative, technical, and physical safeguards to protect your privacy and have taken key steps to protect your information, including but not limited to, establishing technological and organizational security controls to protect your information. However, we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose your information. If a breach were to occur, we will notify as required by applicable law.

9. RIGHTS

Depending on your location or residency, you may have all or some of the following rights with respect to the information gather by MyneHub on its behalf. Please contact us privacidadmh@mynehub.com to exercise your rights. For more information regarding the information gathered as data processor on behalf of providers of Third-Party Services, please refer to their respective privacy policies.

• Access and Portability: Request access to personal data we hold about you or request transmission of your data to a third party.
• Rectification: Request that we rectify inaccurate or incomplete personal data we store about you. If you wish to review or correct your data, you can always log in to your account and visit the profile settings section. There you will find options for viewing and updating your information.
• Erasure: Request that we erase personal data when such data is no longer necessary for the purpose for which it was collected when you withdraw consent and no other legal basis for processing exists, or when you believe that your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
• Restriction of Processing: Request that we restrict our processing of personal data if there is a dispute about the accuracy of the data; if the processing is unlawful; if the processing is no longer necessary for the purposes for which it was collected but is needed by you for the establishment, exercise, or defence of legal claims; or if your request to object to processing is pending evaluation.
• Objection to Processing: Object to processing of your personal data based on our legitimate interests (e.g. for marketing communications). We will no longer process the data unless there are compelling legitimate grounds for our processing that override your interests, rights, and freedoms or for the purpose of asserting, exercising, or defending legal claims.
• Transfers: Obtain information about and a copy of the safeguards we use to transfer personal data across borders.
• Complaints: Lodge a complaint about our data collection and processing actions with your jurisdiction’s privacy supervisory authority, in Spain, the Spanish Data Protection Authority (www.aepd.es).
• Rights related to automated decision-making, including profiling: Users may request not to be subject to decisions based exclusively on automated processing activities which produce legal effects or similarly significantly affect them.

Users of the Platform may exercise these rights over their personal data at any time and without limitation by sending their request through our contact information. The request to exercise their rights will be attended and answered as required by law.

10. PROTECTION OF CHILDREN'S PRIVACY

We comply with the requirements of data protection regulations regarding the protection of personal data of minors. Our Services as well as the Third-Party Services offered though the Platform are intended for persons over 18 years of age. We do not collect any information from children under the age of 18. If we become aware that a child under the age of 18 has provided us with personal information, we will take steps to delete that information.

11. THIRD PARTIES

Except as expressly included in this Privacy Policy, this document addresses only the use and disclosure of information MyneHub collects from you to provide you with MyneHub Services as data controller. If you disclose your information to others, whether other users, third-parties or MyneHub vendors, different rules may apply to their use or disclosure of the information you disclose to them. MyneHub does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. MyneHub is not responsible for the privacy or security practices of another Internet platform, including those linked to or from the MyneHub Platform. Please review the privacy policies of third-party websites, applications or services that you access through the Platform.

12. CONTACT

If you have questions or concerns about this Privacy Policy and the treatment and security of your data, please contact our data protection office through our contact forms or via email at privacidadMH@mynehub.com.