1. Information We Collect

1.1. General Principle

mPass is designed to operate without collecting personal data such as your name, email address, phone number, or other direct identifiers.

1.2. Information You Provide

1.2.1. Account Authorization Data

a. When you authorize mPass to connect to a Publisher platform, we receive the secure authentication information required to log in (e.g., tokens or credentials necessary to establish a secure connection).

b. We do not receive your login credentials or any personally identifiable information from Publishers.

1.2.2. Settings & Preferences

a. We may collect app-level settings such as:

(i) Spending limits;

(ii) Approval settings;

(iii) Notification preferences.

b. This information is stored only within your mPass account environment and is not linked to your identity.

1.3. Information Automatically Collected

1.3.1. System-Generated ID Number (Non-Personal Identifier)

We assign an ID Number to your account. This ID does not relate to your real-world identity and cannot be used to identify you.

1.3.2. Transaction Information

a. We process transaction-level data related to your use of digital services/products, which is: (i) provided to us by Publishers or the Mobile Operator (MO), or (ii) generated/verified through your use of the mPass App.

b. This may include:

(i) Aggregated amounts recorded for services/products;

(ii) Daily and monthly summaries of usage;

(iii) Individual transaction records for digital services/products (such as service name, date/time, price, and status).

c. All transaction data is associated only with your system-generated ID Number. We do not store your payment card numbers in mPass.

1.3.3. Usage Data

a. We may collect technical and interaction data such as:

(i) Features accessed;

(ii) Time spent in the App;

(iii) Device information and analytics;

(iv) Error logs and performance metrics.

b. This information helps us improve reliability, performance, and security.

1.4. Optional Information

1.4.1. Product Viewing History

a. We may record products displayed from Publishers that you view within the App to improve recommendations or user experience.

b. This information is still associated only with your system-generated ID Number.

1.5. Sensitive Information

We do not collect any sensitive personal information (e.g., identification documents, biometrics, financial information, health data). If sensitive data is ever required for a specific feature, we will request your explicit consent and provide clear justification.

2. How We Use the Information

2.1. We use the information described above to:

2.1.1. Verify your account and maintain your mPass session.

2.1.2. Communicate with our partner systems and Publishers to retrieve usage and payment status.

2.1.3. Communicate with Publisher systems to retrieve your digital product usage and payment status.

2.1.4. Track usage on digital services you access.

2.1.5. Improve App performance, stability, and security.

2.1.6. Detect and prevent fraudulent or abnormal activity.

2.1.7. Provide customer support.

2.1.8. Comply with applicable laws, regulations, accounting, auditing, invoicing, financial reporting, and tax obligations.

2.1.9. Assist with dispute handling, including validating usage, transactions, and payment records as required to resolve issues.

2.2. We do not use the information to identify you personally.

3. How We Share Information

3.1. General Policy

We do not sell user data. We do not share personal data because mPass does not collect personal data.

3.2. Sharing Information with MO (Account Provider)

3.2.1. Information associated with your ID Number may be shared with MO for account acquisition, verification, or syncing user status based on the ID Number.

3.2.2. We may share ID-linked usage and record information so that MO may:

a. Verify account status;

b. Collect payments on its own platform (outside the App);

c. Perform reconciliation and settlement with us.

We may share ID-linked information to:

- Authenticate access;

- Retrieve usage information;

- Process digital product status;

- Support settlement and reconciliation with Publishers.

3.3. Sharing Information with Publishers

3.3.1. We may share ID-linked information to:

a. Authenticate access;

b. Retrieve usage data;

c. Process digital product payments;

d. Support settlement and reconciliation with Publishers.

3.4. Service Providers

We may use third-party service providers for hosting, analytics, error tracking, or security services. They process only the limited data required to operate the App and are bound by confidentiality obligations.

3.5. Legal Requirements

We may disclose information if required by law, regulation, or a government authority.

3.6. With Your Consent

Any other sharing will occur only with your explicit consent.

4. Data Retention

4.1. We retain information only as long as necessary for:

4.1.1. Providing the App's core functions;

4.1.2. Compliance with legal obligations;

4.1.3. Resolving disputes;

4.1.4. Ensuring security.

4.2 Usage and transaction data linked to the ID Number may be retained for audit and reconciliation purposes.

4.3 We do not store personal data, so no personal profile exists to delete.

5. Security

5.1. We implement administrative, technical, and organizational safeguards to protect your information, including:

5.1.1. Encryption in transit and at rest.

5.1.2. Secure authentication protocols.

5.1.3. Strict access controls and monitoring.

5.2. While we strive to protect your data, no method of transmission or storage is completely secure. You use the App at your own risk.

6. Third-Party Links

The App may display content or links to Publisher platforms or third‑party services. This Privacy Policy does not apply to their data practices. We recommend reviewing their privacy policies.

7. Children's Privacy

7.1. mPass is not intended for children under the age of 13.

7.2. We do not knowingly collect personal information from children. If we learn that such data has been collected, we will delete it promptly.

8. International Transfers

8.1. Your ID Number and relevant usage data may be transferred to systems operated by MO or Publishers located outside your country.

8.2. We take steps to ensure all transfers comply with applicable data protection laws.

9. Your Rights

9.1. Since mPass does not collect personal data, traditional data privacy rights (access, deletion, correction) may not apply.

9.2. However, you may contact us to:

9.2.1. Request deletion of your App account.

9.2.2. Request clarification about data processing.

9.2.3. Request deletion of ID-linked records where legally permissible.

10. Changes to This Privacy Policy

10.1. We may update this Privacy Policy from time to time.

10.2. Material changes will be notified through the App or our website.

10.3. The "Last Updated" date above indicates the latest revision.

11. Contact Us

If you have questions or requests regarding this Privacy Policy, please contact us at: support@monetanetwork.com.