Privacy Policy

Online Money Transfer (OMT) SAL (hereinafter referred to as “OMT”) is an electronic money transfer company regulated by the Central Bank of Lebanon and duly incorporated under the laws of Lebanon. For more information about OMT’s business and services, you can lodge to our website.

In this policy, any reference to “you” or “your” and other wording referring to you is a reference to you as Data Subject of OMT; the reference to “we”, “us”, or “our” or other wording referring to us is a reference to us as OMT.

This policy applies when you visit or use our website, mobile application, social media platforms, telephone services and OMT PAY Account as well as when you visit our branches and agents or when you have other interactions with us (the “Services”).

By using the Services, you consent to our collection, use and disclosure of your Data in accordance with the terms of this policy. You may withdraw such consent at any time; however this will not affect the lawfulness of the processing based on your consent prior to the withdrawal.

This policy (and any updated policy when applicable) can be found at www.omt.com.lb/en/privacy_policy if you are a Data Subject client.

1. Definitions

Connected Persons means Data Subject’s introducers, authorized representatives/signatories, recipients, agents, lawyers, family members, associates, employers, partners, trustees, counterparties, owners of beneficial economic rights and other providers of services or transaction to you or parties subject of your transactions made by using of our services.

Data means Personal Data and when applicable in accordance with the Section entitled Processing of Sensitive Data herein, Sensitive Data.

Data Subject means a living, identified or identifiable individual about whom we hold Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Data.

Data Subject Consent means any freely given, specific, informed, and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of Data relating to him or her.

Personal Data means any information relating to you as an identified or identifiable Data Subject; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processor means a natural or legal person, public authority, agency, or other body which processes Data on behalf of the controller.

Sensitive Data means personal data of Data Subject which may reveal information about your racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life, genetic or biometric data, financial and payment information, SMS and call-related data, microphone, camera, and other sensitive device or usage data. Such processing is prohibited unless made in conformity with the exceptions to the prohibitions as determined in applicable privacy and data protection laws and regulations and reflected herein.

2. Data Collection by OMT. OMT collects the Data in a transparent way and applies the needed measures to protect the collected and processed Data and to protect such Data against unauthorized or unlawful processing and against accidental loss, destruction, misuse, or damage, using appropriate technology.

• We obtain your Data mainly from you when you use our Services, or when you contact us for any reason, or in connection with payment services such as transfers or payment services, wallet and prepaid cards.

• OMT collects Data when you ask us, one of our agents, our partners, our sister companies or others to provide you with any of our services; (b) you submit, in person or online, information on applications or other forms to us, our agents, our partners, our sister companies or others; or (c) you otherwise submit information to us, our agents, our partners, our sister companies or others, or (d) when you enter in transactions with us, our agents, our partners, our sister companies, or others.

• OMT collects Data in connection with electronic services such as about the domain and host from which you access the Internet, your computer’s Internet address, the browser and operating system software you use, the date and time you access any of our Services and the Internet address of the site from which you linked to one of our Services. In common with many commercial organizations, we monitor the use of our Services by collecting aggregate information. We may automatically collect non-personal information about you such as the type of internet browsers you use, the pages you visit or the website which directed you to one of our Services. You cannot be identified from this information, and it is used only to assist us in providing an effective service on our Services.

• We also obtain your Data from your authorized representatives, agents, lawyers or introducers, from entities or people with which you may have a relationship such as your employer, from entities affiliated or connected to OMT, from third parties who provide services or payments to you or to OMT or with whom you are engaged in business or relation, or from correspondents or reference agencies, directories, fraud prevention agencies or government agencies, and from publicly available resources, such as commercial and real estate registrars, central banks, databases of local and foreign regulatory and supervisory authorities (such as sanctions list), the press, the media, online search engines and other online resources.

Where processing is to be carried out on behalf of OMT, we as the controller shall use only Processors providing sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of applicable privacy and data protection laws and regulations and ensure the protection of the rights of the Data Subject.

3. Age Restriction. OMT enforces a strict policy prohibiting individuals under the age of 18 from using our Services. We do not knowingly collect any personally identifiable information from children under the age of 18. If we become aware of any such information provided by a child under 18, we will promptly remove it from our servers. We encourage parents or guardians to contact us if they believe their child has shared personal information with us, so we can take the appropriate action.

4. Type of Collected and Processed Data. The types of Data that OMT may collect and process, as determined and authorized by applicable privacy and data protection laws and regulations, include your Personal Data and/or the Personal Data of the Connected Persons (or when applicable as provided in the Section entitled Processing of Sensitive Data herein, yours and their Sensitive Data), such Data being collected and processed by OMT as mentioned in this policy:

• Data such as name, surname, passport, identity card, social security number, gender,

marital status, dependents, nationality, date and place of birth, residential status and addresses, phone numbers, educational status, employment and business information, personal and financial information, annual income, assets and liabilities, source of funds, personal net worth and origin of wealth, emails and mailing addresses, politically exposed persons information, purpose of the relation with OMT, relationship with banks, information relating to the beneficial owner of the economic rights, information relating to taxation status or other information relating to legal or regulatory or contractual requirements.

• Data relating to your payment transaction, collection transaction, wallet service or card transaction such as amounts of money transacted, IBAN, accounts, nature, purpose and type of payment, beneficiaries thereof, card number, card code number and PIN, type of merchandise or service you bought or transacted, merchants and counterparties with whom you transacted by utilizing our services and, any other information needed or which could arise in connection with such services or transactions.

• Data such as the IP address, your login Data, type of device you use and the relevant access time and location.

5. Cookies and Internet Technologies. By using our Services, you are giving your consent to the use of cookies and other Internet Technologies. We use internet technologies like cookies for a variety of purposes, including but not limited to, those identified below:

a. To assist us in providing services to you;

b. To allow you to change Web pages during your visit without having to re-enter your password;

c. To temporarily track activity on our website and mobile application;

d. To deliver information specific to your interests; or

e. To identify you when you visit our website, to personalize the content of the website for you and to assist you in carrying our the transactions and accessing account information.

You can choose to reject cookies at any time, either by changing your browser settings (if your browser permits) or by ceasing to our Services or by using the applicable opt-out functions. You should be aware that certain features are only available through the use of cookies and if you choose not to accept cookies, such features may not be available to you.

6. Purposes for Processing of Personal Data. Please note that we will process your Personal Data for one or more of the following reasons/purposes mostly connected with the exercise of our business and services activities and/or OMT’s relation with the Data Subject, or in the public interests, such as:

a. For the purposes of the contractual relationship with you or a third party or contractual relation between you and a third party or to be able to fulfil and apply the requirements and the rights and obligations under that contract.

b. For the purposes of compliance with a legal obligation.

c. For the purposes of safeguarding our legitimate/vital interests or those of a third party or the legitimate/vital interests of Data Subject.

d. For the purpose of sending you marketing information regarding promotions we occasionally run or services we believe may interest you.

e. For other purposes, when we have a Data Subject Consent.

7. Who Do We Share Your Personal Data With. We may share or disclose your Personal Data in connection with the purposes described in this policy. This may include sharing your Personal Data with the following:

a. Our sister companies for marketing, business, administrative and legal purposes (for example, payment, verification or membership awards and points);

b. Facebook, Twitter, Instagram or any other social media platforms that we may use from time to time (if you use your account with them to sign up/in with us), if applicable;

c. Service providers, business partners, suppliers, subcontractors or agents (for example IT service providers, customer relationship management, business development and marketing support services) who perform functions such as IT, marketing, payment, fulfilment and delivery of orders as well as administration and processing of payments We may share personal information with third-party providers to facilitate certain payment services through our mobile application. We will mandate these third-party providers to uphold security measures and adhere to this policy when handling your Personal Data;

d. Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;

e. Government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons;

f. Third parties, who acquire us or substantially all of our assets, in which case your Data (including any Sensitive Data) will be one of the transferred assets (however, we will let you know before this happens); and

g. Analytics and search engine providers that assist us in the improvement and optimization of our Services.

8. Processing of Sensitive Data. We will only process your Sensitive Data in the following circumstances:

a. We have secured a Data Subject Consent.

b. Processing is necessary for the purposes of the proper implementation of the service functionality of any of our Services.

c. Processing is necessary for carrying out our obligations and exercising our specific rights or those of the Data Subject in the field of employment and social security laws in so far as it is authorised by applicable laws or a collective agreement pursuant to applicable laws providing for appropriate safeguards for the fundamental rights and the interests of the Data Subject.

d. Processing is necessary to protect the vital interests of the Data Subject or of another natural person where the Data Subject is physically or legally incapable of giving consent.

e. Processing relates to Data which are manifestly made public by the Data Subject.

f. Processing is necessary for the establishment, exercise, or defence of legal claims or whenever courts are acting in their judicial capacity.

g. Processing is necessary for reasons of substantial public interest, based on applicable laws which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the Data Subject.

h. Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of applicable laws or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in applicable privacy and data protection laws and regulations.

i. Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of applicable laws which provide for suitable and specific measures to safeguard the rights and freedoms of the Data Subject, in particular professional secrecy; processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes based on applicable laws which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the Data Subject.

9. Your Choices Regarding Our Use and Disclosure of Your Personal Data. We give you choices regarding our use and disclosure of your Personal Data for marketing purposes. You may opt out from receiving marketing-related emails from us. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by sending an email to customercare@omt.com.lb or by using the unsubscribed link at the bottom of each marketing email. We will try to comply with your request(s) as soon as reasonably practicable.

10. Retention of Data. Your Data will not be kept longer than necessary to meet the purposes detailed above. The criteria that we use to determine how long we will keep your Data includes the period of time during which we have an ongoing relationship with you, and whether we have a legal obligation to store it (for example, for accounting purposes or for litigation, or regulatory investigations purposes). Should retention of your Data no longer be required we will remove it from our systems and records and/or take steps to properly anonymise it so that you can no longer be identified from it.

11. Where We Store/Transfer Your Data. We may transfer, process and store your Data outside of the country in which you are located depending on the circumstances. This includes any country where we operate but also countries where our external service providers are based or are hosting your Data on our behalf. We take steps to ensure that appropriate transfer safeguards, required by law, are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. You can obtain further details about the transfer safeguards we use by contacting us at the Contacting Us section below.

12. Third party websites. Through our website or applications, you may have access to other parties, websites, and platforms that offer you the benefit of their products or services. As such, you may be required to submit your Data to register or apply for products or services provided by such third parties. This policy does not apply to these third-party sites. Please note that we have no control over the information that you submit to them. You should read the relevant privacy policy of those third-party sites before responding to any offers, products or services advertised by them.

13. Security. Your privacy is important to us and we have implemented various technology and operational security measures, including encryption and security protocols, in order to protect your Data from loss, misuse, alteration, destruction or unauthorized access. We have established procedures to address any suspected data breaches. However, no internet transmission is 100% secure or error-free, nor is stored data free from vulnerabilities. We cannot guarantee the security of our websites, databases or services, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the internet. We are not responsible for actions of third parties.

14. Your Rights. You have certain rights relating to your Data. However, these rights can differ depending upon the country in which you are located. That country's law will determine which rights apply and in what instances.

Right to withdraw consent. Where you have provided your consent to us, you will always have the right to withdraw this at any time. You can do this by either following the information provided at the time you provided your consent, or by contacting us using the following email address customercare@omt.com.lb. The withdrawal of consent will not affect any processing that was based on consent before its withdrawal.

Right to request correction of your Data. You will always have the right to request that we correct any Data that we process about you that is inaccurate or incomplete. You can do this by contacting us at customercare@omt.com.lb.

Additional Rights. You are also provided with additional rights which allow you, subject to certain conditions, to:

• upon request, be provided access to, or copies of, your Data that we process;

• upon request, restrict the processing of your Data;

• upon request, delete your Data which we process;

• object to our processing of your Data; or

• upon request, obtain a copy of your Data which we process in a commonly used and machine-readable format.

It is important to understand that these rights are not absolute (e.g. their application may depend upon the lawful basis we rely upon to process your Data) and that we may require further information from you (e.g. to confirm your identity) in order to action your request.

Our account deletion policy allows users to easily delete their accounts through the mobile application's settings, permanently removing their profile and associated data. Users are advised to back up any important information prior to deletion. Once an account is deleted, it cannot be reactivated, and users must create a new account to access our services again. For assistance or questions, users can contact our support team.

15. Contacting Us. If you want to exercise any of the rights set out above or have any questions or concerns about how we treat your Data, please contact us at customercare@omt.com.lb or by phone on +961 1 391 491 or by writing to us at: OMT Building, 5th Floor, 266-Sami El Solh Avenue, Museum, Beirut 2490-116, Lebanon. Please include your reply address when you write to us.

16. Amendments. We reserve the right to update or change this policy at any time, particularly in case of amendments introduced to applicable privacy and data protection laws and regulations. You are encouraged to review this policy from time to time for updates.