1. Scope and Application of Policy
1.1 CYBERGEM – FZCO. (“CYBERGEM”), including its affiliates and subsidiaries (collectively referred to as “CYBERGEM,” “we,” “us,” or “our”), collects and processes your personal data only where it is necessary or relevant to our relationship with you. This Privacy Policy (“Policy”) outlines our practices regarding the collection, use, processing, disclosure, transfer, storage, retention, and disposal of your personal data in connection with the services we provide as a data controller (“CYBERGEM Services”).
1.2 By accepting this Policy, you consent to the collection, use, processing, disclosure, transfer, storage, retention, and disposal of your personal data in accordance with the terms outlined herein.
1.3 “Personal Data” refers to information that identifies you as an individual, whether directly or in combination with other data to which we have or are likely to have access. The types of personal data we may collect and process include, but are not limited to:
• (a) Full name
• (b) Email address
• (c) Mobile number (MSISDN)
• (d) IP address and merchant affiliation
• (e) Cookies and analytical data (e.g., browsing behavior) that may identify you
• (f) Verification documents (e.g., identification proof)
• (g) Social media links or public profiles and any personal information made visible therein
• (i) Account credentials such as passwords you create
• (j) Any additional personal information you provide while using CYBERGEM Services
1.4 This Policy applies solely to personal data that is in our possession or under our control.
1.5 Please refer to the Additional Provisions section below for translated versions of this Policy and jurisdiction-specific terms that may apply based on your place of residence.
1.6 We collect and process your personal data to facilitate transactions on our platform, including purchases made from us, your mobile network operator, relevant third-party payment processors (“Payment Channels”), or digital merchants and publishers (“Publishers”). These services are accessed through CYBERGEM’s platforms, including our mobile applications, databases, servers, and websites at cybergemtech.com (collectively, the “Platform”).
1.7 CYBERGEM reserves the right to amend this Policy at any time without prior notice.
Updates will be published on our Platform and will take effect as of the stated effective date. You can determine whether changes have been made by checking the “last updated” date provided below. We recommend reviewing this Policy periodically. Continued use of the CYBERGEM Services following any updates constitutes your acceptance of the revised Policy.
2. Collection of Personal Data
2.1 We collect your Personal Data when you access or use the CYBERGEM Services or when you communicate with us. This data may be provided directly by you or shared with us by our affiliates, subsidiaries, Payment Channels, or Publishers, based on the consent you have granted to those third parties.
2.2 You may also provide Personal Data to us through other means, including but not limited to:
• (a) Responding to our communications;
• (b) Engaging with us via social media platforms or online forums;
• (c) Participating in offers, programs, or promotions initiated by CYBERGEM;
• (f) Completing the Partnerships or Marketing inquiry form available on our website;
• (g) Logging into CYBERGEM Services using social login credentials or third-party accounts (e.g., Facebook, Google). In such cases, we collect the information you have agreed to share from the respective social media or third-party platform.
2.3 We also collect transactional data—including details such as purchase amount, transaction date, and information about the digital content, goods, or services purchased (“Transaction Data”). This data is collected to fulfill our contractual obligations and to pursue our legitimate business interests. In most cases, Transaction Data does not constitute Personal Data unless it can be linked to your identity. When such linkage is possible, Transaction Data will be treated as Personal Data under this Policy. By using CYBERGEM Services or accessing our Platform, you consent to the collection of this information.
2.4 You are responsible for ensuring that any information you provide to us is accurate, complete, and not misleading. We reserve the right to request supporting documentation to verify the accuracy of the information submitted.
3.Use and Disclosure of Personal Data
3.1 Your personal data is collected and processed for the following purposes:
• (a) Facilitating transactions and delivering content;
• (b) Conducting marketing and promotional campaigns; and
• (c) Other legally permitted uses and disclosures.
3.2 Transaction Processing and Content Delivery
3.2.1 As an aggregator of payment channels and a distributor of digital content, CYBERGEM utilizes your Personal Data—and may share it with trusted third parties, including affiliates, Payment Channels, and Publishers—for the purpose of delivering CYBERGEM Services or fulfilling our business obligations to you.
3.2.2 Specifically, your Personal Data may be used to:
• (a) Enable your access and use of CYBERGEM Services;
• (b) Process and authenticate transactions and payments on our Platform;
• (c) Address disputes or issues related to transactions;
• (d) Prevent and mitigate fraud;
• (e) Safeguard our legitimate business interests;
• (f) Enforce our contractual rights; and
• (g) Provide you with information or support upon request.
3.2.3 To facilitate these purposes, we may share your Personal Data with:
• (a) The Publisher of the digital content you are purchasing; and
• (b) The Payment Channel you have selected for completing your transaction.
3.3 Marketing and Promotional Campaigns
3.3.1 From time to time, CYBERGEM may run promotional campaigns to reward users, such as recognizing top spenders by country, Publisher, or other categories. To administer these campaigns, we may analyze your Transaction Data and contact you using your Personal Data to distribute prizes (e.g., free credits or gifts from Publishers or Payment Channels). These campaigns are conducted solely by CYBERGEM, and your Personal Data will not be shared with third parties for this purpose. You may opt out of these campaigns by contacting us.
3.3.2 If you have consented to receive marketing and promotional communications, we may use your Personal Data to inform you about relevant campaigns related to CYBERGEM Services, including those conducted in partnership with Publishers, Payment Channels, or other third parties. For this purpose, we may share your name, email address, and/or mobile number with such partners. To opt out of receiving these communications or prevent your Personal Data from being shared for this purpose, you may contact us directly or use the unsubscribe option in any marketing email.
3.4 Other Permitted Uses and Disclosures
3.4.1 In addition, we may use your Personal Data for the following internal and customer-related purposes:
• (a) Managing and securing your CYBERGEM user accounts;
• (b) Communicating important account-related updates;
• (c) Responding to service requests, queries, or feedback;
• (d) Implementing internal security or risk management protocols;
• (e) Conducting market research and customer satisfaction surveys (which may involve third-party service providers);
• (f) Enhancing customer support and service delivery; and
• (g) Notifying you of significant updates to this Privacy Policy or our Terms and Conditions.
3.4.2 We may also disclose your Personal Data to our affiliates, subsidiaries, Publishers, Payment Channels, or relevant authorities when permitted or required by law. Such disclosures may occur in the following scenarios:
• (a) In connection with corporate transactions such as mergers, acquisitions, sales of assets, financing, or restructurings;
• (b) When we believe disclosure is necessary to:
(i) Comply with applicable laws, regulations, legal processes, or requests by authorities;
(ii) Assist with legal investigations or proceedings; or
(iii) Protect the rights, safety, and integrity of CYBERGEM, its services, users, or the public from fraud, harm, or illegal activity.
4. Your Rights, Choices, and Exceptions
4.1 You have the right to request the deletion of your Personal Data or to withdraw your consent to its processing, where such processing is based solely on your consent. If you choose to exercise this right or prefer that we do not use your Personal Data for any of the purposes outlined in this Policy, please contact us directly.
Please note, however, that depending on the nature and scope of your request, we may no longer be able to provide you with access to the CYBERGEM Services or facilitate the completion of transactions on our Platform.
4.2 You also have the right to access, update, or request corrections to your Personal Data at any time. If you wish to review the data we have on file or request updates or corrections, please contact us. We may charge a reasonable administrative fee to process such requests, and you will be informed of any applicable charges as soon as reasonably practicable.
5. Retention and Disposal of Personal Data
Your Personal Data will be retained only for as long as necessary to fulfill the purposes for which it was collected, or for as long as required to comply with applicable legal, regulatory, or legitimate business obligations. Once the data is no longer needed for these purposes, we will securely dispose of it using appropriate methods to prevent unauthorized access, disclosure, or further processing. Disposal methods may include permanent deletion or irreversible anonymization.
6. Security of Personal Data
At CYBERGEM, we are committed to protecting your Personal Data and have implemented reasonable measures to safeguard it from loss, misuse, unauthorized access, modification, disclosure, alteration, or destruction—whether accidental or intentional.
While no method of data transmission or storage over the internet can be guaranteed to be completely secure, we adopt and maintain a range of administrative, organizational, technical, and physical safeguards to protect your Personal Data to the fullest extent reasonably possible. These measures include, but are not limited to:
• (a) Restricting access to Personal Data strictly to authorized personnel on a need-toknow basis;
• (b) Employing robust technical safeguards to ensure data confidentiality and integrity;
• (c) Continuously monitoring, reviewing, and enhancing our data protection and security protocols; and
• (d) Implementing additional security controls as may be required under applicable local laws and regulations in your jurisdiction.
7. International Transfer of Personal Data
7.1.1 CYBERGEM operates across multiple jurisdictions. As such, you acknowledge and agree that your Personal Data may be transferred to, stored in, or processed in countries other than where it was originally collected. This may occur due to legal data localization requirements or in connection with our provision of CYBERGEM Services, the completion of your transactions, or other purposes outlined in this Policy. Such transfers may involve third parties such as Publishers, Payment Channels, or CYBERGEM affiliates and subsidiaries located in different countries.
8. Collection of Statistical Data
8.1 We, along with certain third-party partners (including but not limited to Amazon Web Services, Facebook, and Google), collect statistical information about your use of our Platform through cookies and similar technologies. This data—such as pages visited, access times and dates, and browser types—is aggregated and anonymized, meaning it does not identify you personally. It is used solely for the purpose of analyzing user behavior, enhancing functionality, and improving the overall performance and user experience of the CYBERGEM Services.
8.2 “Cookies” are small text files stored by your browser on your device when you visit a website. They enable us to recognize your device or browser to tailor content and improve your interaction with our Platform. Cookies do not reveal your identity unless you voluntarily provide personal information. You can manage or disable cookies through your browser settings at any time.
9. Use by Minors
9.1 The CYBERGEM Services are not intended for individuals who have not reached the age of majority in their respective jurisdiction (“Minors”). If you are a Minor, you may only access and use the CYBERGEM Services under the supervision and consent of a parent or legal guardian, and subject to applicable laws and age restrictions for digital content in your country.
9.2 By accepting this Policy on behalf of a Minor under your care, you, as the parent or legal guardian, consent to the collection, processing, and use of the Minor’s Personal Data in accordance with this Policy.
10. Links to Other Websites
Our Platform may contain links to third-party websites that are not operated or maintained by CYBERGEM. These websites have their own privacy policies and practices. We encourage you to review their privacy policies before providing any personal information. CYBERGEM is not responsible for the content, privacy policies, or practices of these third-party websites.
11. Contact Us
11.1 If you have any questions or concerns regarding this Privacy Policy or your Personal Data— including but not limited to withdrawing consent, opting out of receiving promotional communications or gifts, requesting access or corrections to your Personal Data, or exercising your rights under applicable data protection laws—you may contact us at our designated support email address.
12. Additional Provisions
This Policy may include jurisdiction-specific provisions that apply to users based on their country of residence. You may access localized versions of this Privacy Policy, including the relevant Additional Provisions, in both English and your local language, where applicable.