Privacy Policy

Our management has developed this Privacy Statement (Policy) to express our firm commitment to aid our users better understand what information we collect about them and what may happen to that information.

This Terms of Use agreement was last updated: 06 November, 2024

This Privacy Policy and Terms of Use (hereinafter “Agreement”) explains how Sheba Fintech Limited ("Sheba Pay," "we," "us," or "our") collects, processes, and uses the information of users ("you," "your," or "user"). Your use of Sheba Pay constitutes your consent to this Agreement, so please review it carefully.

1. Definitions and Interpretation

Definitions:

“Account” A unique account created for you to access Sheba Pay services.
“Affiliate” An entity controlled by or under common control with Sheba Fintech Limited or its parent company.
“Application” The Sheba Pay mobile application.
“Device” Any electronic device used to access Sheba Pay, such as a smartphone, tablet, or computer.
“Personal Data” or “Data” shall mean and include Information that can identify you as an individual, financial institution, transaction related information, and any such data that has ever been transacted while using the service and/or in association with the rendering of the service through the account.
“Service” Services provided by Sheba Pay through the Application.
“User” The individual using Sheba Pay services.
“Platform” The Sheba Pay website, mobile app, and related digital interfaces.

2. Information We Collect

2.1 Basic Information:

To sign up for a Sheba Pay account or use Sheba Pay Services, you must provide your name, phone number, and other contact details, including Phone Number/NID/Driving License/Passport/Birth Registration number, as applicable, and any other required identification information as per regulatory and legal requirement of Bangladesh. We may also request you to provide additional verification documents before processing any transaction that is inconsistent with your regular transaction patterns or is of a significantly high amount. You agree to cooperate with Sheba Pay in this process by providing all required information and/or documents accordingly.

We collect personal information that you provide to us through correspondence, chats, or other means, as well as information shared by you from other social websites, services, and/or applications. We may also collect any additional information (personal or otherwise) that you may be asked to provide as needed.

Additionally, we may collect public information about your business size, customer base, and usual transactions that might be available from social media platforms, other Sheba Pay account holders, or other sources to assess goodwill, trustworthiness, and solvency for checking your account and business.

2.2 Device Identification:

Sheba Pay collects information from your interactions with our Platform, Services, content, and advertising, including but not limited to device ID, device type (including hardware model), operating system and version, unique device identifiers, mobile network information, location, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address, and information collected by cookies and other tracking technologies. This identifying information about the computer or device you use to access your Sheba Pay account will be tracked to help us detect possible instances of unauthorized transactions and to enhance your experience with Sheba Pay services.

2.3 Transaction Information:

To comply with anti-money laundering and counter-terrorism obligations under applicable laws and amendments, including but not limited to the Money Laundering Prevention Act 2012 and Anti-Terrorism Act 2009, as well as any other applicable rules and regulations of the Government of the People’s Republic of Bangladesh, and to improve your service experience, your commercial and/or personal transaction information shall be recorded. If you send or receive an unusually high amount through Sheba Pay Services, or if you are suspected of engaging in any suspicious transactions, Sheba Pay, in collaboration with the relevant authorities, may conduct a background check on your business. This may involve gathering information about you, your business, its directors, shareholders, partners, officials, and employees, as applicable. Sheba Pay reserves the right to periodically retrieve and review your data and may close an account based on information obtained during these background checks and reviews.

2.4 Web Cache and Website Traffic:

To ensure smooth and efficient Sheba Pay Services, your IP address, browser, and time-related information for accessing the Platform will be stored on our servers. We may also receive web addresses of sites that routed you to or from the Platform. Session cookies, web cookies, pixel tags, web beacons, or other similar technologies will be used to place small text or image files on your computer/device to facilitate user-friendly performance of the Platform.

2.5 Contacting Prospective Users:

When a Sheba Pay user attempts to send a service request to users who have not yet signed up for Sheba Pay, we may retain the service requested and information provided regarding the prospective user for marketing purposes. For example, a text message or Interactive Voice Response (“IVR”) may be sent to their number notifying them about the Sheba Pay service you wanted to share with them.

2.6 Non-Personal Information:

Sheba Pay may collect non-personal information as you use our Platform. When you use our Platform, third-party service providers, such as Google Analytics and other partners, may also receive and record non-personal information from cookies, server logs, and similar technology from your browser or mobile device, including your IP address. We may combine the collected non-personal information with personal information. Where we do so, we will treat the combined information as personal information if the resulting combination can be used to readily identify or locate you in the same manner as personal information alone.

2.7 Aggregate Information:

Sheba Pay collects non-identifying, general, generic, and aggregate information to improve the design of the Platform and Services.

2.8 Accessing and Updating Your Information:

You may update your information through your account profile settings. If you believe that the personal information, we hold about you is incorrect, incomplete, or inaccurate, you may request us to amend it accordingly. We shall be at our liberty to preserve and review the update/modification history. However, recognizing the fact that the service you will be using has significant regulatory and legal implications, some personal information/data shall always adhere to your National Identity Card and all other regulatory identification and/or charter documents (“Identification Document”), any modifications/updates altering such mentioned data may be rejected by Sheba and modified as per Identification Documents.
You may request access to any personal information we hold about you at any time by contacting us. Where we hold information that you are entitled to access, we will try to provide you with means to access it. You may be charged a fee to cover the administrative and other associated costs in providing the information as per Sheba Pay's policy. Please note that there may be instances where access to personal information may not be granted, for example, if it would potentially interfere with the privacy of others or result in a breach of confidentiality.

2.9 Restriction to Transfer:

The right to use this Platform is personal to the user and is not transferable to any other person or entity. You shall be responsible for protecting the confidentiality of your password(s), if any. It is agreed that, although the internet is often a secure environment, interruptions in service or events that are beyond the control of Sheba Pay may occur, and Sheba Pay shall not be responsible for any data lost while transmitting information on the internet. Sheba Pay makes no representation that any services are available or otherwise suitable for use outside Bangladesh. If you choose to access the Platform from locations outside Bangladesh, you do so at your own initiative and are responsible for the consequences thereof.

2.10 User Contact List Information:

Sheba Pay may use the information you provide, including the contact list from your device, for various purposes. However, the information contained in the contact list is not stored in Sheba Pay’s database and is only used to perform any instructions given by the user.

3. Use of Collected Information

3.1 Internal Use:

Your information shall be collected, stored, and processed on servers located in Bangladesh to provide you with a smooth, safe, efficient, and customized experience on the Platform. The information provided shall be used to process your transactions, troubleshoot problems, resolve disputes, provide customer support services, customize your Platform experience, and address any other issues.

3.2 Communicating with You:

We shall communicate with you using the information you provided to complete the processing of Sheba Pay Services or verify important information or actions, such as investigating suspicious or illegal transactions, and responding to customer service requests, complaints, or claims.

3.3 Information Shared with Other Users:

Your basic information, such as name, phone number, email address, transaction amount, and transaction time, may be shared with other Sheba Pay users or prospective users to whom you send service requests. The information shared may vary based on the service requested and the type of Sheba Pay account maintained. Additional information about your business may be revealed if you are making transactions through a business account. When payments for goods or purchases are made through Sheba Pay, the buyer’s and seller’s addresses and payment details may be revealed to aid in delivery and dispute resolution.

3.4 Information Shared with Third Parties:

Several third parties, such as regulatory authorities, mobile operators, and other service providers, may need access to specific information to complete your requested Sheba Pay Services. We shall only disclose required information to third parties if we are under a duty to comply with legal requirements, enforce our policies, respond to claims that a listing or other content violates the rights of Sheba Pay or others, or protect anyone’s rights, property, or safety. Such information shall be disclosed in accordance with applicable laws and regulations. We do not disclose your personal information to third parties for their marketing purposes without your explicit consent.

3.5 Your Use of User Information:

You shall receive information of other Sheba Pay users when carrying out transactions with them. You may only use this information to facilitate Sheba Pay service-related communication, actions, or transactions; this information shall not be used for any other purpose without obtaining explicit consent from the Sheba Pay user and adequately disclosing the purpose.

We may send you emails/SMS to verify your account and for other operational purposes, such as billing, account management, or system maintenance. You may only stop receiving these emails/SMS by terminating your account. We may also send you promotions, announcements, surveys, newsletters, developer updates, evaluations, and event information, or other marketing or commercial emails/SMS. You may opt out of receiving these communications at any time by unsubscribing or using the unsubscribe button within each email to have your contact information removed from our email list. Notwithstanding anything contained in this Agreement or the Terms & Conditions, Sheba Pay shall not be responsible for any breach of privacy due to correspondence sent to an incorrect address or phone number.

You agree that we may use your personal information to inform you about our services and tools, deliver targeted marketing and promotional offers based on your communication preferences, and customize, measure, and improve our advertising.

We may also use and share non-personally identifiable information for marketing purposes, including marketing on other websites, for example, using the information to control the number of times you have seen an ad, deliver ads tailored to your interests, and measure the effectiveness of ad campaigns.

3.6 Surveys and Questionnaires:

When you answer an optional questionnaire or survey, the information provided may be used for improving Sheba Pay Services, marketing, and/or advertising purposes as described in the survey.

3.7 Audit and Legal Compliance:

Your information and transaction history may be viewed by auditors for confirming the accuracy of our records. However, auditors shall not have the right to use your personally identifiable information for any other purpose. Information related to illegal or suspicious activity carried out from your account shall be made available to law enforcement bodies, Bangladesh Post Office, Bangladesh Bank, competent courts of law, or any other law enforcement agencies with applicable jurisdiction when requested.

3.8 Mergers or Acquisitions:

If Sheba Pay merges with another company or is acquired by another company, the successor company will have access to your information maintained by Sheba Pay.

3.9 Public Information:

Any reviews, personal information, or comments that you voluntarily post or disclose on public pages (such as the questions and answers page, Facebook page, etc.) of Sheba Pay will be viewable by the general public. Any comment or content you post or disclose on such public pages becomes published content, including your account and username, and shall not be subject to the terms and conditions of this Agreement. You shall be deemed to have waived the right to privacy and confidentiality over such information by posting or making such disclosures. Sheba Pay does not have Non-Disclosure and Confidentiality Agreements with these parties who may be able to access such information.

4. Sharing and Disclosure of Information

4. Sharing and Disclosure of Information

a. With Service Providers and Partners

We share data with trusted third parties who assist with payment processing, data storage, analytics, and security services. These parties are required to protect your information under strict confidentiality agreements.

b. Legal Compliance and Investigations

We may share information with regulatory authorities, law enforcement agencies, or government bodies if required by law or to protect the safety of users. This includes cooperating with investigations or legal processes.

c. Other Users in Transactions

When engaging in transactions with other users, we may share necessary details like your name and transaction information to facilitate services and resolve disputes.

d. User Consent

We may share data for other purposes with your explicit consent, such as for marketing offers.

5. Cookies:

5.1 Consent:

By using our Platform or Services provided through the Platform, or receiving our emails, you consent to the use of cookies in accordance with this Agreement.

5.2 Intent:

This Agreement sets out how we, and third parties we authorize, use cookies when you interact through our Platform or the Services offered via the Platform. Our Agreement explains what we do (and don’t do) with the information, including any personal data we may collect about you.

5.3 Meaning:

Cookies are unique identifiers, usually made up of small bits of text or code. Cookies are usually stored on your device or in your web browser and they send certain information back to the party who served the cookie. When we refer to cookies, we are actually referring to a broader range of technologies than just cookies, including web beacons, clear gifs, pixels, and other similar technologies. When we refer to first-party cookies, we mean cookies that are served by Nagad. When we refer to third-party cookies, we mean cookies that are served by non-Nagad parties.

5.4 Use of Cookies:

Cookies may be used in order to better understand how the Platform works and to optimize online and mobile experiences. Cookies do this by allowing the party serving the cookie to analyze the Platform’s performance, identify certain Users anonymously, remember their preferences, better understand whether a computer or device (and probably its User) has visited a website previously, and serve personalized advertisements.

5.5 Types of Cookies:

Our Platform primarily uses the following four types of cookies:

5.5.1 Operations based Cookies:

These cookies are essential for the operation of our Platform. They make it possible for you to browse and use our Platform. If you disable these cookies, the Platform will not function correctly.

5.5.2 Performance based Cookies:

These cookies gather information about how visitors use the Platform and monitor Platform performance. For example, performance cookies tell us which pages are popular, monitor traffic to our Platform, and compile anonymous analytic information. Performance cookies can also be used to identify and remedy operational problems with the Platform.

5.5.3 Functionality based Cookies:

These cookies are used to recognize and remember your preferences. For example, functionality cookies may use information, such as your location, to ensure that you arrive at a version of our Platform that is specific to your city or region.

5.5.4 Advertising Preferences based Cookies:

We offer you choices about receiving interest-based ads from us. For this, we allow third parties to deliver personalized advertising content on our Platform and/or on third-party websites and applications. These third parties use cookies to understand your interest in the advertisements and content delivered to you, as well as to serve you with more relevant advertisements based on your activities on our Platform. For example, third-party cookies could record information about whether you have clicked on certain content or advertisements on our Platform or other websites, or placed an item on our Platform in your shopping cart.

5.6 Control over Third Party Cookies:

We do not have control over, or access to, third-party advertising cookies or the information they contain. Third parties manage any information that they collect via cookies they place in accordance with their privacy policies. You can opt-out of third-party personalized advertising cookies. You will still see ads, but they will not be personalized.

5.7 Cookies and Browser Settings:

You may be able to avoid certain cookies by configuring your browser settings or opting-out directly with the party that operates and controls the cookie. Please check your browser settings for more information.

5.8 Cookies in E-mails:

Our emails contain cookies that track whether you open our emails and whether you click any link within them. The cookies used in our emails to monitor these behaviors are unique to each email and are not stored on your computer or mobile device.

6. Security of Information

We use encryption, secure network protocols, and regular audits to safeguard your data. Access to user data is restricted to authorized personnel only. However, no platform is completely secure, so users should protect their login credentials and promptly report unauthorized access.

7. User Rights and Data Management

Users have the following rights regarding data:

a. Access and Update Information: Modify personal information through account settings.However, recognizing the fact that the service you will be using has significant regulatory and legal implications, some personal information/data shall always adhere to your National Identity Card and all other regulatory identification and/or charter documents (“Identification Document”), any modifications/updates altering such mentioned data may be rejected by Sheba and modified as per Identification Documents.
b. Data Deletion: Request data deletion, subject to legal and regulatory requirements.
c. Withdraw Consent: Opt-out of marketing communications anytime.

8. Children’s Privacy

Sheba Pay does not knowingly collect data from individuals under 18. If we discover that a minor has provided us with personal information, we will delete it promptly.

9. Public Information and User-Generated Content

Any content users post in public areas (e.g., comments, reviews) becomes publicly accessible and is not covered by privacy protections. Users should avoid posting sensitive data in public forums.

10. Data Retention and Storage

We retain user data for as long as necessary to fulfill purposes outlined in this Agreement or as required by law. After account closure, data may be retained for record-keeping or compliance, following Bangladesh’s legal standards. Any data collected can be stored for a period of 5 (five) years. Data shall be stored in any location as per discretion of Sheba as per compliance with applicable legal and regulatory requirements.

11. Force Majeure

Sheba Pay is not liable for data loss or service interruptions caused by events beyond its control, such as natural disasters, cyberattacks, or regulatory changes.

12. Intellectual Property

Sheba Fintech Limited owns all intellectual property on the Sheba Pay platform, including trademarks, logos, design, and technology. Unauthorized use, copying, or distribution is strictly prohibited.

13. Limitation of Liability

Sheba Pay, its affiliates, and partners are not liable for indirect, incidental, or consequential damages arising from platform use or inability to use the platform. Users acknowledge that platform functionality may depend on third-party software and internet connectivity.

14. Governing Law and Jurisdiction

This Agreement is governed by Bangladesh law. Any disputes arising under this Agreement will be subject to the exclusive jurisdiction of the Dhaka courts.

15. Updates to This Agreement

Sheba Pay may periodically update this Agreement to reflect changes in practices, laws, or services. Users will be notified of significant changes through the app or email, and continued use signifies acceptance.

16. User Conduct and Responsibilities

16.1 User Information Security:

Sheba Pay is committed to maintaining the integrity and security of your information. We employ advanced firewalls, data encryption, and computer network safeguards to protect your information around the clock. Access to your personal information is restricted to authorized personnel only, who require it for the operation of our services. However, we shall not be liable for any breach of security or for any actions taken by third parties who gain unauthorized access to your personal information.

You can review and update your personal information at any time through your account settings. If you wish to close your account and there are no ongoing investigations, you may do so. Upon closure, your account will be marked as ‘Closed,’ and your information will be retained in our database for future reference.

16.2 User Conduct:

By using the Sheba Pay Platform and Services, you agree not to engage in any of the following prohibited activities:

a. Upload, send, or receive any information for which you do not have the necessary licenses or approvals or that would violate the rights of any third party or the law.
b. Introduce harmful software such as viruses, Trojan horses, or any other malware that could disrupt or damage our systems.
c. Attempt to intercept communications over the telecommunication system.
d. Use the Platform for purposes other than those intended by Sheba Pay.
e. Engage in fraudulent activities, including those intended to incite hatred or harm against any individual or group.
f. Upload or share content that is unlawful, harmful, threatening, abusive, or otherwise objectionable. g. Cause annoyance or inconvenience to other users.

16.3 Forbidden Uses:

The following actions are expressly prohibited:
a. Reselling the Platform or any services offered by Sheba Pay.
b. Providing false information, including names and addresses, or engaging in fraudulent use of payment methods.
c. Circumventing security measures or accessing unauthorized data.
d. Engaging in network monitoring that intercepts data not intended for you.
e. Sending unsolicited bulk messages or spam to users.
f. Engaging in fraudulent transactions or activities that misrepresent your authority.
g. Using the Platform for any unlawful purposes or in violation of this Agreement.

Any conduct that, in Sheba Pay's exclusive discretion, breaches this Agreement or restricts other users from enjoying the Platform is strictly prohibited. Sheba Pay reserves the right to prevent access to the Platform or restrict purchases if your conduct is found to be in violation of these terms.

17. Contact Information

For questions or requests regarding this Privacy Policy and Terms of Use, please contact us at:
Email: info@sheba.xyz
Phone: 16516

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