Privacy Policy of the “Crédit Plus” Application

The use of the “Crédit Plus” mobile application (hereinafter the “Application”) implies the full and unconditional acceptance by the user (hereinafter the “User” or the “Users”) of this Application Privacy Policy (hereinafter the “Privacy Policy”). The term “Use” refers indiscriminately to any consultation, search or downloading of elements of the Application. The terms “FNAC” or “We” are used to designate the company Société de Financement Nouveau à Crédit, its subsidiaries and shareholdings.
Crédit + is the commercial brand under which FNAC, a financing company authorized and supervised by Bank Al-Maghrib, conducts its activities (“Crédit +”). For the purposes of this document, the terms “FNAC” and “Crédit +” are used interchangeably and designate FNAC, which operates under the Crédit + commercial brand.

FNAC reserves the right to modify and update the Application as well as this Privacy Policy, subject to notifying the User by any means. Each modification of the Privacy Policy will be subject to a dated and referenced version. The new version may be consulted on the Application. In this case, the date of the last update indicated on the Application will be modified. Any modification takes effect immediately at the time of its publication on the Application. If the User continues to use the Application after the publication of the modifications, this implies full and unconditional acceptance of such modifications. These modifications and updates are binding on the User who must therefore regularly refer to this section in order to verify the version in force.

The data, presentations, documents and information (hereinafter the “Information”) communicated on the Application are provided in good faith, for information purposes only and without any guarantee of any kind; errors and omissions may notably occur. Consequently, FNAC cannot be held liable for them. They may be modified or updated by FNAC without prior notice.
The User uses the Application under his/her sole and entire responsibility. The User is deemed to have accepted this Privacy Policy simply by using the Application. Under no circumstances shall FNAC and/or its subcontractors guarantee the completeness, precision or accuracy of this Information or even the absence of omissions relating to the Information, nor be held responsible for direct and/or indirect damages, whatever their causes, origins, nature or consequences, including incidental or special damages resulting from the content or the Use of the Application and/or any of the links and addresses related to it (including access or the impossibility for Users to access the Application or any of these links, as well as any use that may be made of this Information), including, without limitation, any loss of business, financial or commercial loss, loss of programs and/or data, particularly in the information system of the User of the Application.
The User fully assumes the risks related in particular to the importance and credibility given to the Information. This Information is provided on the condition that the User or any other person receiving the Information can determine its relevance for a specific purpose before using it. Under no circumstances shall FNAC be responsible for damages that may result in particular from the importance attributed to this Information or from its use, particularly for private or professional purposes. This Information should not be considered as recommendations for the use of information, products, procedures, equipment or formulations that would be in contradiction with a patent, copyright or trademark. FNAC declines all responsibility, express or implied, if the use of this Information infringes a patent, copyright or trademark. FNAC categorically rejects any interpretation that would assimilate the content of the Application with offers to purchase or incentives to acquire shares or other securities of its subsidiaries and direct or indirect shareholdings.
No express or implied guarantee is given regarding the merchantable nature of the Information provided, nor its suitability for a particular purpose, nor regarding the services referred to in this Information.
FNAC does not guarantee that the Application operates without interruption or that the servers providing access to it are free from viruses. Furthermore, FNAC shall in no case be held responsible for loss of data or deterioration of the User’s data.

Users are informed that during their visits to the Site, a navigation tracking mechanism may be implemented. They have the right to access, withdraw and modify personal data communicated through tracking techniques. Their visit to the FNAC Site results in the creation of a session cookie (hereinafter the “Cookie(s)”) which records information relating to the navigation of their phone/tablet on the Site (pages visited, date and time of consultation, etc.), which FNAC may read during subsequent visits of users.
During the entire duration of the visit to the Site, the pages viewed by the User generate a session Cookie that is downloaded by the User’s phone/tablet. Cookies are small files containing text that allow a server to recognize a phone/tablet and therefore determine whether the phone/tablet (and probably the User) has previously visited the Site. If the device reconnects to the Site, the Site will search for and use these Cookies, or “tokens”, left on the hard drive during the previous visit.
Cookies themselves do not allow identification of a User, but only the device used. Cookies merely record which parts of the Site the device visited and the time spent there. The User is free to refuse the recording of Cookies by configuring the browser as described below. However, by refusing Cookies it will be impossible to provide certain personalized services and this may slow down or prevent access to certain parts of the Site.
The User is informed that, during visits to the Site, a Cookie may automatically be installed on the browsing software and temporarily stored in memory on the hard disk. This information is used to provide an optimal service. Thus, Cookies are used in particular to:

Under no circumstances are Cookies intended to exploit personal information identifying individuals connected to the Site.
The User acknowledges having been informed of this practice and authorizes FNAC to use it. The User may disable the Cookie through the settings available in their browsing software and in particular by modifying the options of the browsing software on their phone/tablet.

FNAC holds all domain names relating to FNAC in cases where it has chosen to purchase domain names from the hosting provider. Otherwise, FNAC benefits from a right of use of the domain name owned by the hosting provider. The Application as a whole, as well as the elements composing it, constitute intellectual works protected by the laws in force, particularly in matters of intellectual property.
All data such as texts, structure, software, animations, photographs, illustrations, diagrams, graphic representations, logos, sounds, images, information and databases appearing in the sections of the Application are the exclusive property of FNAC. Any reproduction, representation or distribution, in whole or in part, of the content as well as any extraction, even partial, of the Application databases on any medium or by any process whatsoever is prohibited. Failure to comply with this prohibition constitutes infringement likely to engage the civil and criminal liability of the infringer or the User.
Unless otherwise stated, corporate names, logos, products and trademarks mentioned in the Application are registered trademarks of FNAC. Any total or partial reproduction of these trademarks and logos for any purpose whatsoever, particularly for advertising or commercial purposes, carried out from elements of the Application without prior written authorization of the trademark holder is prohibited in accordance with the provisions of the Industrial Property Code.
The general structure of the Application, the templates and frameworks used as well as the information, pictograms, photographs, images, texts, video sequences, animated or not, sound sequences or other documents composing the Application or accessible through the Application are subject to laws protecting intellectual property and are the property of FNAC or third parties who have authorized FNAC to use them, as well as its possible suppliers, subcontractors, partners and/or affiliated companies involved in the functioning of the Application.
Any reproduction, representation, adaptation, translation and/or transformation, partial or complete, of the Application or one or more of its components, by any process whatsoever (including transfer to another website), without prior written authorization of FNAC is prohibited and would constitute infringement punishable under the provisions of the Industrial Property Code and likely to engage the civil and/or criminal liability of its author. No license or right other than that of consulting the Application is granted with regard to intellectual property rights.

By personal data, FNAC means all information disclosed by Users as natural persons, whatever their nature, such as their names, surnames, emails, telephone numbers, region, province and municipality, CIN number, photos and images enabling them to be identified directly or indirectly and voluntarily provided through the Application, as well as banking data, behavioral data (navigation, use of the application), biometric data, technical logs (including electronic signature), information relating to credit refusals, as well as data received from partners or service providers as part of the provision of services.
The personal data collected by FNAC are intended exclusively for entities responsible for internal communication, external communication, subsidiaries and partners of FNAC and/or any organization or authority authorized to receive such data in the context of a legal or regulatory obligation in order to allow the User to benefit from the services offered by the Application.
Certain data may also be processed by specific service providers for defined purposes:
i) : KYC/AML verification, access to identity documents (CIN, etc.);
ii) : risk assessment, processing only the phone number and email.
All data processed in this context remain located in Morocco. Any possible transfer abroad will be subject to authorization in accordance with the provisions of Law No. 09-08 and applicable regulatory requirements.
Any personal data that the User transmits to FNAC is subject to the provisions relating to the protection of personal data.
No personal information concerning the User is transferred to third parties or used for purposes not provided for.
Users of the Application are required to comply with the provisions relating to the protection of personal data. To this end, they must in particular refrain from any collection, capture, distortion or use of the information to which they have access and, more generally, from any act likely to infringe upon the privacy of individuals.
In accordance with the provisions relating to the protection of personal data, the User has the right to access, modify, rectify and delete personal data concerning them that FNAC may collect by contacting us at any time online through the “Contact” section of the Application, or by sending a letter to FNAC at the addresses indicated in the “Contact” section of the Application.
FNAC retains personal data only for the period necessary for the purposes for which they were collected and in accordance with applicable legal and regulatory obligations, including in particular:
i) accounting and banking obligations;
ii) obligations relating to the fight against money laundering and terrorist financing (AML/CFT);
iii) retention of information related to credit refusals.
Consequently, it is not possible to delete certain data before the expiration of the corresponding legal retention periods, even at the User’s request.
All personal data are hosted and processed in Morocco, including when entrusted to service providers such as VoveID or RiskSeal. FNAC ensures that these providers comply with the same security and confidentiality standards applied internally.

FNAC formally declines all responsibility regarding the content of all sites to which it provides links. These links are offered to Users of the Site or the websites of its subsidiaries and affiliated entities as an additional service. The decision to activate these links lies exclusively with the Users of the Site.
Since FNAC is not the publisher of these sites and/or mobile applications, it cannot perfectly control their content. Consequently, FNAC cannot be held responsible for the content of the sites and/or mobile applications thus accessible and in particular for their accuracy, timeliness, quality, completeness, relevance, legality, advertising, information, products, services or any other material available on or from these sites or mobile applications or external sources.
FNAC cannot be held responsible for any collection and transmission of personal data, installation of cookies or any other process with the same purposes carried out on and by these sites or mobile applications.
The confidentiality and integrity of Information are not guaranteed on the internet network. Consequently, messages sent electronically by the User may be intercepted and/or modified. FNAC declines all responsibility in this regard.
Users of the Site may under no circumstances create a hyperlink or framing (example of programming in HTML code) directing to the Site without the prior written authorization of FNAC. Consequently, no element appearing on a page of the Site may be partially or totally distributed, transferred or inserted into another website, nor used to create derivative products without the prior express authorization of FNAC. For this purpose, Users may send their request to the Site Administrator at the address indicated in the “Contact” section of the Site.

The Application, its general terms of sale, legal notices as well as this Privacy Policy are governed by Moroccan law. In the event of a dispute relating to the interpretation or execution of the Application and/or the Privacy Policy, the competent jurisdiction is the Court of First Instance of Casablanca.