Privacy Policy of OK Dollar Mobile Application

About OK Dollar

OK Dollar is a mobile payment wallet that allows you to make fast money transfers, access deals, and make payments on the go. You can also recharge mobile numbers of all telecom operators and DTH services, purchase movie tickets, and share bills at restaurants.

OK Dollar also provides options to pay corporation taxes and electricity bills. Users can enter their unique Customer Identification Number, after which the application fetches the relevant information and displays it to the user, allowing them to pay pending bills.

OK Dollar also enables payments to merchants who have an OK Dollar QR code. The money will be deducted from the user's wallet and transferred to the merchant's wallet instantaneously.

OK Dollar also provides features that allow users to transfer money from their OK Dollar wallet to third-party bank payment wallets. The improved user interface provides users with a better experience when performing transactions and using other services available through the application.

About This Policy and Your Privacy

This Privacy Policy explains how we collect, use, hold, process, and protect your personal information while ensuring the quality, integrity, confidentiality, and security of your personal information in accordance with applicable laws and regulations.

By using the OK Dollar Mobile Application, you acknowledge that your information may be processed for the purpose of providing our services, maintaining account security, preventing fraud, complying with applicable laws and regulatory requirements, and improving the security and functionality of the application.

What Is Personal Information?

Personal information includes any information or opinion about an identified individual or an individual who can reasonably be identified from that information. The information or opinion will still be considered personal information regardless of whether it is true and whether or not we have kept a record of it.

For easy and fast payment processing, the application may request permission to access contacts. These contacts may primarily be used to facilitate mobile-to-mobile wallet payments and support secure payment-related services.

We may store contact list details in the user's local database. Such information is not intended to be shared with other applications on the smartphone or used for unrelated commercial purposes.

Where required for security enhancement, fraud prevention, transaction monitoring, analytics, or other legitimate purposes within the OK Dollar system, contact information may also be transmitted to and processed on our secure servers in accordance with applicable requirements.

Analytics and related security processing may be used to identify potential misuse of OK Dollar services, financial fraud, money laundering, unauthorized transactions, or other activities that may pose a risk to users or the OK Dollar payment system.

Examples of Personal Information

Some examples of personal information that we may collect, process, or hold include:

• Name
• Mailing or street address details
• Personal contact details, such as telephone numbers, email addresses, or social media platform usernames used to create or manage an OK Dollar account
• Government-issued identifiers, such as National Registration Card (NRC) number, driver's license number, or Taxpayer Identification Number (TIN)
• Bank account numbers and payment card information used to perform transactions through OK Dollar
• Photographs, videos, or audio recordings collected or provided for different services available through OK Dollar
• Information required for KYC (Know Your Customer) and account verification
• Device, network, application, and security-related information used to protect the OK Dollar account and services
• Location or network-related information required to provide location-based services and enforce applicable security and access restrictions

Payment card information may be retained where necessary to track transactions, investigate disputes, or handle payment failures. We do not store the user's Transaction PIN, CVV/CVC, or One-Time Password (OTP).

Where applicable and permitted by law, certain sensitive information may be processed for specific services, regulatory requirements, account verification, or security purposes.

App Permissions

To make payments easier and provide the services available through OK Dollar, users may be asked to provide the following permissions.

Location-Based Security and Access Restriction

Location or network-related information may also be used as part of OK Dollar's security controls.

To protect users, transactions, and the OK Dollar payment ecosystem, the application may determine whether the application is being accessed from within Myanmar.

This security check may occur:

• After the user enters their mobile number on the Login Screen
• After the user reaches the Dashboard Screen or while using the application

If access from outside Myanmar is detected, OK Dollar may display a security restriction popup. The user will be required to exit the application and will not be permitted to continue using OK Dollar while the restriction applies.

VPN Detection

As part of our security and fraud-prevention measures, OK Dollar may perform technical checks to determine whether the user's device or network connection is using a VPN.

VPN detection may be used to help protect:

• User accounts
• Payment transactions
• Wallet balances
• Financial information
• The integrity of the OK Dollar platform
• The application against unauthorized or potentially fraudulent access

If VPN usage is detected, OK Dollar may restrict access to the application and display a security restriction popup.

This security check may be performed on the Login Screen and/or Dashboard Screen.

Developer Mode Detection

As part of the application's security controls, OK Dollar may check whether Developer Mode is enabled on the user's device.

Developer Mode may enable device-level functionality, such as debugging or other development-related capabilities, that could increase security risks for a financial application.

If Developer Mode is detected as enabled, OK Dollar may restrict access to the application.

This check may be performed:

• After the user enters their mobile number on the Login Screen
• After the user reaches the Dashboard Screen or while using the application

If Developer Mode is detected, OK Dollar may display a security restriction popup.

When Developer Mode is detected, the user will be required to exit the application and will not be permitted to continue using OK Dollar while the restriction applies.

Application Security and Access Restrictions

OK Dollar implements security controls to protect user accounts, financial transactions, personal information, and the overall payment ecosystem.

Access to the application may be restricted when one or more of the following security conditions are detected:

1. The user is accessing OK Dollar from outside Myanmar.
2. VPN is detected.
3. Developer Mode is enabled on the user's device.

Login Screen

Security checks may be performed after the user enters their mobile number and before the user is allowed to proceed with the application.

If a restricted condition is detected, OK Dollar may display a security restriction popup. The user will not be permitted to proceed while the restriction applies.

Dashboard Screen

Security checks may also be performed after the user reaches the Dashboard.

If a restricted condition is detected at this stage, OK Dollar may display the same or a similar security restriction popup.

The user will not be permitted to continue using the application while the restriction applies.

These security measures are intended to protect the user, the user's OK Dollar account, transactions, and the OK Dollar payment ecosystem.

How Do We Use Personal Information?

We may use personal information for purposes including:

• Providing and maintaining OK Dollar services
• Processing payments and money transfers
• Processing wallet transactions
• Facilitating merchant and agent transactions
• Performing KYC and account verification
• Verifying user identity and devices
• Providing customer support
• Preventing fraud and unauthorized transactions
• Detecting suspicious or potentially fraudulent activity
• Preventing misuse of OK Dollar services
• Detecting and preventing financial fraud and money laundering
• Maintaining application and transaction security
• Performing security checks relating to location, VPN usage, Developer Mode, and device/network conditions
• Providing location-based services
• Improving application performance and user experience
• Performing analytics and service improvement
• Meeting regulatory, legal, and compliance requirements
• Responding to lawful requests from competent authorities
• Investigating transaction disputes, payment failures, and security incidents

How Do We Hold and Protect Your Personal Information?

Much of the information we hold about you will be stored electronically.

We store some of your information in secure data centres located in Yangon, Myanmar. We may also store information in other data centres or data centres operated by our contracted service providers, including cloud storage providers. Some of these data centres may be located outside Myanmar in the Asia Pacific region.

Some information we hold about you may also be stored in paper files where necessary.

We use a range of physical, electronic, technical, and organizational security measures to protect the security, confidentiality, and integrity of the personal information we hold, both in Myanmar and overseas.

For example:

• Access to our information systems is controlled through identity and access management controls.
• Employees and contracted service providers are bound by internal information-security requirements and are required to keep information secure.
• Employees are required to complete relevant training regarding privacy and information security.
• We regularly monitor and review our security controls and compliance with applicable requirements and industry practices.
• We apply appropriate security controls to protect information against unauthorized access, disclosure, alteration, loss, or misuse.

Although we take reasonable measures to protect personal information, no electronic transmission, storage system, or security mechanism can be guaranteed to be completely secure.

International Storage and Processing

Some information may be stored or processed outside Myanmar, including in the Asia Pacific region, through our contracted service providers or cloud infrastructure providers.

Where personal information is transferred, stored, or processed outside Myanmar, we take reasonable measures to protect the information and handle it in accordance with applicable legal, regulatory, contractual, and security requirements.

Data Retention

We retain personal information for as long as reasonably necessary to:

• Provide OK Dollar services
• Maintain transaction and account records
• Meet legal and regulatory requirements
• Comply with applicable Central Bank of Myanmar requirements
• Resolve disputes and investigate transaction issues
• Prevent fraud and financial crime
• Maintain appropriate security and audit records

The retention period may vary depending on the type of information and the applicable legal or regulatory requirements.

How to Delete Your Account

To request deletion or closure of your OK Dollar account, you should contact customer care through:

Direct deletion of the account by the customer through the application may not be available where account retention is required by applicable instructions, rules, or requirements of the Central Bank of Myanmar or other applicable authorities.

Where information is required to be retained for legal, regulatory, security, fraud-prevention, dispute-resolution, or transaction-record purposes, such information may continue to be retained for the applicable retention period even after account closure.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• Changes to our services
• Changes to application functionality
• New security requirements
• Changes in applicable laws or regulations
• Changes in regulatory requirements
• Changes to our information-processing practices
• Improvements to privacy and security controls

When this Privacy Policy is updated, the revised version may be made available through the OK Dollar Mobile Application.

Users are encouraged to periodically review this Privacy Policy for the latest information regarding our privacy and security practices.

Contacting Us

If you have any questions about this Privacy Policy, the privacy practices of the OK Dollar website or OK Dollar Mobile Application, or your dealings with the website or application, please contact us at: