Privacy Policy

PRIVACY NOTICE
Last updated May 8, 2023
This privacy notice for mmopass (“Company,” “we,” “us,” or “our”), describes how and why we
might collect, store, use, and/or share (“process”) your information when you use our services
(“Services”), such as when you:
■ Visit our website at https://trymmo.com/ or any website of ours that links to this privacy
notice
■ Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights
and choices. If you do not agree with our policies and practices, please do not use our Services.
If you still have any questions or concerns, please contact us at [email protected]

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details
about any of these topics by scrolling down to each each key point or by using our table of
contents below to find the section you are looking for.

What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on
how you interact with mmopass and the Services, the choices you make, and the products
and features you use. Click here to learn more.

Do we process any sensitive personal information?
We do not process sensitive personal information.

Do we receive any information from third parties?
We do not receive any information from third parties.

How do we process your information?
We process your information to provide, improve, and administer our Services, communicate with
you, for security and fraud prevention, and to comply with law.
We may also process your information for other purposes with your consent. We process your
information only when we have a valid legal reason to do so. Scroll down to learn more.

In what situations and with which parties do we share personal information?
We may share information in specific situations and with specific third parties. Scroll down to
learn more.

How do we keep your information safe?
We have organizational and technical processes and procedures in place to protect your personal
information. However, no electronic transmission over the internet or information storage
technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that
hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security
and improperly collect, access, steal, or modify your information. Scroll down to learn more.

What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you
have certain rights regarding your personal information. Click here to learn more.

How do you exercise your rights?
The easiest way to exercise your rights is by filling out our data subject request form available
here: (teamDecision) or by contacting us. We will consider and act upon any request in
accordance with applicable data protection laws.

Want to learn more about what mmopass does with any information we collect?
Send us an email at [email protected]

WHAT INFORMATION DO WE COLLECT?
HOW DO WE PROCESS YOUR INFORMATION?
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
HOW DO WE HANDLE YOUR SOCIAL LOGINS?
HOW LONG DO WE KEEP YOUR INFORMATION?
HOW DO WE KEEP YOUR INFORMATION SAFE?
WHAT ARE YOUR PRIVACY RIGHTS?
CONTROLS FOR DO-NOT-TRACK FEATURES
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
DO WE MAKE UPDATES TO THIS NOTICE?
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the
Services, express an interest in obtaining information about us or our products and Services,
when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You.
The personal information that we collect depends on the context of your interactions with us and
the Services, the choices you make, and the products and features you use. The personal
information we collect may include the following:

■ names
■ phone numbers
■ email addresses
■ mailing addresses
■ usernames
■ passwords
■ contact or authentication data
■ billing addresses

Sensitive Information. We do not process sensitive information.
Payment Data. We may collect data necessary to process your payment if you make purchases,
such as your payment instrument number (such as a credit card number), and the security code
associated with your payment instrument.

All payment data is stored by PayPal, RazorPay, CoinBase, Skrill, coinGate and .
You may find their privacy notice link(s) here:
https://www.paypal.com/uk/webapps/mpp/ua/privacy-full,
https://razorpay.com/privacy/,
https://www.coinbase.com/legal/privacy,
https://www.skrill.com/en/footer/privacypolicy/,
https://coingate.com/privacy
and ……

Social Media Login Data.
We may provide you with the option to register with us using your existing social media account
details, like your Facebook, Twitter, or other social media account.
If you choose to register in this way, we will collect the information described in the section called
“HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.

Al personal information that you provide to us must be true, complete, and accurate, and you
must notify us of any changes to such personal information.
Information automatically collected
In Short:
Some information — such as your Internet Protocol (IP) address and/or browser and device
characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This
information does not reveal your specific identity (like your name or contact information) but
may include device and usage information, such as your IP address, browser and device
characteristics, operating system, language preferences, referring URLs, device name, country,
location, information about how and when you use our Services, and other technical information.
This information is primarily needed to maintain the security and operation of our Services,
and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

= Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and
performance information our servers automatically collect when you access or use our Services
‘and which we record in log files. Depending on how you interact with us, this log data may
include your IP address, device information, browser type, and settings and information
about your activity in the Services (such as the date/time stamps associated with your usage,
pages and files viewed, searches, and other actions you take such as which features
you use), device event information (such as system activity, error reports (sometimes called “crash
dumps”), and hardware settings).

= Device Data. We collect device data such as information about your computer, phone, tablet, or
other device you use to access the Services. Depending on the device used, this
device data may include information such as your IP address (or proxy server), device and
application identification numbers, location, browser type, hardware model, Internet service
provider and/or mobile carrier, operating system, and system configuration information.

= Location Data. We collect location data such as information about your device’s location, which
can be either precise or imprecise. How much information we collect depends on the
type and settings of the device you use to access the Services. For example, we may use GPS
and other technologies to collect geolocation data that tells us your current location
(based on your IP address). You can opt out of allowing us to collect this information either by
refusing access to the information or by disabling your Location setting on your device.
However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact
with our Services, including:

= To facilitate account creation and authentication and otherwise manage user accounts. We may
process your information so you can create and log in to your account, as well
‘as keep your account in working order.

= To deliver and facilitate delivery of services to the user. We may process your information to
provide you with the requested service.

= To respond to user inquiries/offer support to users. We may process your information to
respond to your inquiries and solve any potential issues you might have with the
requested service.

= To send administrative information to you. We may process your information to send you details
about our products and services, changes to our terms and policies, and other
similar information.

= To fulfill and manage your orders. We may process your information to fulfill and manage your
orders, payments, returns, and exchanges made through the Services.

= To request feedback. We may process your information when necessary to request feedback
and to contact you about your use of our Services.

= To send you marketing and promotional communications. We may process the personal
information you send to us for our marketing purposes, if this is in accordance with your
marketing preferences. You can opt out of our marketing emails at any time. For more information,
see “WHAT ARE YOUR PRIVACY RIGHTS?” below).

= To deliver targeted advertising to you. We may process your information to develop and display
personalized content and advertising tailored to your interests, location, and more.

= To protect our Services. We may process your information as part of our efforts to keep our
Services safe and secure, including fraud monitoring and prevention.

= To Identify usage trends. We may process information about how you use our Services to better
understand how they are being used so we can improve them.

= To determine the effectiveness of our marketing and promotional campaigns. We may process
your information to better understand how to provide marketing and promotional
‘campaigns that are most relevant to you.

= To save or protect an individual’s vital interest. We may process your information when
necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have
a valid legal reason (1.e., legal basis) to do so under applicable law, like with your
consent, to comply with laws, to provide you with services to enter into or fulfill our contractual
obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you :

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal
bases we rely on in order to process your personal information. As such, we may rely on
the following legal bases to process your personal information:

= Consent. We may process your information if you have given us permission (i.e., consent) to use
your personal information for a specific purpose. You can withdraw your consent at
any time. Click here to learn more.

= Performance of a Contract. We may process your personal information when we believe it is
necessary to fulfill our contractual obligations to you, including providing our Services or
at your request prior to entering into a contract with you

= Legitimate Interests. We may process your information when we believe it is reasonably
necessary to achieve our legitimate business interests and those interests do not outweigh
your interests and fundamental rights and freedoms. For example, we may process your personal
information for some of the purposes described in order to:

Send users information about special offers and discounts on our products and services
Develop and display personalized and relevant advertising content for our users
Analyze how our services are used so we can improve them to engage and retain users
Support our marketing activities,
Diagnose problems and/or prevent fraudulent activities
Understand how our users use our products and services so we can improve user
experience

= Legal Obligations. We may process your information where we believe it is necessary for
compliance with our legal obligations, such as to cooperate with a law enforcement body or
regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in
litigation in which we are involved.

= Vital Interests. We may process your information where we believe it is necessary to protect
your vital interests or the vital interests of a third party, such as situations involving
Potential threats to the safety of any person.

If you are located in Canada this section applies to you :

We may process your information if you have given us specific permission (i.e., express consent)
to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. Click here to
learn more.

In some exceptional cases, we may be legally permitted under applicable law to process your
information without your consent, including, for example:

= If collection is clearly in the interests of an individual and consent cannot be obtained in a timely
way

=For investigations and fraud detection and prevention

= For business transactions provided certain conditions are met

= If it is contained in a witness statement and the collection is necessary to assess, process, or
settle an insurance claim

= For identifying injured, ill, or deceased persons and communicating with next of kin

= If we have reasonable grounds to believe an individual has been, is, or may be victim of financial
abuse

= If it is reasonable to expect collection and use with consent would compromise the availability
or the accuracy of the information and the collection is reasonable for purposes related
to investigating a breach of an agreement or a contravention of the laws of Canada or a province

= If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court
relating to the production of records

= If it was produced by an individual in the course of their employment, business, or profession
and the collection is consistent with the purposes for which the information was produced

= If the collection is solely for journalistic, artistic, or literary purposes

= If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the
following third parties.

We may need to share your personal information in the following situations:

= Business Transfers. We may share or transfer your information in connection with, or during
negotiations of, any merger, sale of company assets, financing, or acquisition of all or a
Portion of our business to another company.

= Affiliates. We may share your information with our affiliates, in which case we will require those
affiliates to honor this privacy notice. Affliates include our parent company and any
subsidiaries, joint venture partners, or other companies that we control or that are under common
control with us.

= Business Partners. We may share your information with our business partners to offer you
certain products, services, or promotions.

= Other Users. When you share personal information (for example, by posting comments,
contributions, or other content to the Services) or otherwise interact with public areas of the
Services, such personal information may be viewed by all users and may be publicly made
available outside the Services in perpetuity. If you interact with other users of our Services
and register for our Services through a social network (such as Facebook), your contacts on the
social network will see your name, profile photo, and descriptions of your activity.
Similarly, other users will be able to view descriptions of your activity, communicate with you
within our Services, and view your profile.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your
information.

‘We may use cookies and similar tracking technologies (like web beacons and pixels) to access or
store information. Specific information about how we use such technologies and how you
can refuse certain cookies is set out in our Cookie Notice.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social media account, we may
have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account
details (like your Facebook or Twitter logins). Where you choose to do this, we will receive
certain profile information about you from your social media provider. The profile information we
receive may vary depending on the social media provider concerned, but will often include
your name, emaill address, friends list, and profile picture, as well as other information you choose
to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy
notice or that are otherwise made clear to you on the relevant Services. Please note that we
do not control, and are not responsible for, other uses of your personal information by your thirdparty social media provider. We recommend that you review their privacy notice to
understand how they collect, use, and share your personal information, and how you can set your
privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this
privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out
in this privacy notice, unless a longer retention period Is required or permitted by law (such
as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping
your personal information for longer than three (3) months past the start of the idle period of
the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will
either delete or anonymize such information, or, if this is not possible (for example,
because your personal information has been stored in backup archives), then we will securely
store your personal information and isolate it from any further processing until deletion is
possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE ?

In Short: We aim to protect your personal information through a system of organizational and
technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures
designed to protect the security of any personal information we process. However,
despite our safeguards and efforts to secure your information, no electronic transmission over the
Internet or information storage technology can be guaranteed to be 100% secure, so we
‘cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will
not be able to defeat our security and improperly collect, access, steal, or modify your
Information. Although we will do our best to protect your personal information, transmission of
personal information to and from our Services is at your own risk. You should only access the
Services within a secure environment.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and
Canada, you have rights that allow you greater access to and control over your personal
information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data
protection laws.
These may include the right
(i) to request access and obtain a copy of your Personal information,
(ii) to request rectification or erasure;
(iii) to restrict the processing of your personal information; and
(iv) if applicable, to data portability

In certain circumstances, you may also have the right to object to the processing of your personal
information. You can make such a request by contacting us by using the contact details provided
in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE ?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal
information, you also have the right to complain to your local data protection supervisory
authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/
bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are
available her jwww.edoeb.admin.ch/edoeb/en/home. html.

Withdrawing your consent: If we are relying on your consent to process your personal information,
which may be express and/or implied consent depending on the applicable law, you
have the right to withdraw your consent at any time. You can withdraw your consent at any time
by contacting us by using the contact details provided in the section “HOW CAN YOU
CONTACT US ABOUT THIS NOTICE ?” below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its
withdrawal nor, when applicable law allows, will it affect the processing of your personal
information ‘conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our
marketing and promotional communications at any time by clicking on the unsubscribe link in
the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that we
send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT
US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists.
However, we may still communicate with you — for example, to send you service-related
messages that are necessary for the administration and use of your account, to respond to
service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your
account, you can:
= Log in to your account settings and update your user account.
= Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and
information from our active databases. However, we may retain some information in our files to
prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/
or comply with applicable legal requirements.

Cookies and Similar technologies:
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to
set your browser to remove cookies and to reject cookies. If you choose to remove cookies or
reject cookies, this could affect certain features or services of our Services. To opt out of interestbased advertising by advertisers on our
Services visit (teamDecision).

If you have questions or comments about your privacy rights, you may email us at
[email protected]

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a DoNot-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to
have data about your online browsing activities monitored and collected. At this stage no uniform
technology standard for recognizing and implementing DNT signals has been finalized. As
such, we do not currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a standard for online tracking
is
adopted that we must follow in the future, we will inform you about that practice in a revised
version of this privacy notice.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS ?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to
your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users
who are California residents to request and obtain from us, once a year and free of
charge, information about categories of personal information (if any) we disclosed to third parties
for direct marketing purposes and the names and addresses of all third parties with which
we shared personal information in the immediately preceding calendar year. If you are a California
resident and would like to make such a request, please submit your request in writing to
us using the contact information provided below

If you are under 18 years of age, reside in California, and have a registered account with Services,
you have the right to request removal of unwanted data that you publicly post on the
Services. To request removal of such data, please contact us using the contact information
provided below and include the email address associated with your account and a statement that
you reside in California. We will make sure the data is not publicly displayed on the Services, but
please be aware that the data may not be completely or comprehensively removed from all
‘our systems (@.g., backups, etc.).

CCPA Privacy Notice
‘The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory
purpose and
(2) every individual who is domiciled in the State of California who is outside the State of
California for a temporary or transitory purpose
All other individuals are defined as “non-residents.”
If this definition of “resident” applies to you, we must adhere to certain rights and obligations
regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:

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We may also collect other personal information outside of these categories through instances
where you interact with us in person, online, or by phone or mail in the context of:
= Receiving help through our customer support channels;
= Participation in customer surveys or contests; and
= Faclitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information ?

More information about our data collection and sharing practices can be found in this privacy
notice.
You may contact us by email at [email protected] by visiting http:/www.mmopass1.com/
contact_us , or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out we may deny a request if the
authorized agent does not submit proof that they have been validly authorized to act on
your behalf.

Will your information be shared with anyone else ?

‘We may disclose your personal information with our service providers pursuant to a written
contract between us and each service provider. Each service provider is a for-profit entity that
processes the information on our behalf.

‘We may use your personal information for our own business purposes, such as for undertaking
internal research for technological development and demonstration. This is not considered to
be “selling” of your personal information.

mmopass has not disclosed or sold any personal information to third parties for a business or
commercial purpose in the preceding twelve (12) months.
mmopass will not sell personal Information in the future belonging to website visitors, users,
and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

Depending on the circumstances, you have a right to know:
= whether we collect and use your personal information;
= the categories of personal information that we collect;
= the purposes for which the collected personal information is used;
= whether we sell your personal information to third parties;
= the categories of personal information that we sold or disclosed for a business purpose;
= the categories of third parties to whom the personal information was sold or disclosed for a
business purpose; and
=the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information
that is de-identified in response to a consumer request or to re-identify individual data to
verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same
person about whom we have the information in our system. These verification efforts require
Us to ask you to provide information so that we can match it with information you have previously
provided us. For instance, depending on the type of request you submit, we may ask you to
provide certain information so that we can match the information you provide with the information
we already have on file, or we may contact you through a communication method (eg.
phone or email) that you have previously provided to us. We may also use other verification
methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority
to make the request. To the extent possible, we will avoid requesting additional information
from you for the purposes of verification. However, if we cannot verify your Identity from the
information already maintained by us, we may request that you provide additional information for
the purposes of verifying your identity and for security or fraud-prevention purposes. We will
delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

= You may object to the processing of your personal information.
= You may request correction of your personal data if it is incorrect or no longer relevant, or ask to
restrict the processing of the information.
= You can designate an authorized agent to make a request under the CCPA on your behalf. We
may deny a request from an authorized agent that does not submit proof that they have
been validly authorized to act on your behalf in accordance with the CCPA.
= You may request to opt out from future selling of your personal information to third parties.
Upon receiving an opt-out request, we will act upon the request as soon as feasibly
Possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at [email protected], by https://trymmo.com/ or by referring to the contact details at the bottom of this
document. If you have a complaint about how we handle your data, we would like to hear from
you.

12. DO WE MAKE UPDATES TO THIS NOTICE ?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an
updated “Revised” date and the updated version will be effective as soon as it is accessible

If we make material changes to this privacy notice, we may notify you either by
prominently posting a notice of such changes or by directly sending you a notification. We
‘encourage you to review this privacy notice frequently to be informed of how we are protecting
your Information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

Ifyou have questions or comments about this notice, you may email us at [email protected]

deira

Dubai, Dubai 00000
United Arab Emirates

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the
personal information we collect from you, change that information, or delete it. To request to
review, update, or delete your personal information, please visit:
[email protected]