ASL (أصل) operates the ASL mobile application and aslbullion.com (together, the Service). This Privacy Policy explains how we collect, use, store, and protect personal information when you use the Service.
1. Who we are
The data controller for the Service is ASL (referred to as “we”, “us”, or “our”), available at aslbullion.com. For privacy-related requests, use our Support page.
2. Information we collect
Depending on how you use the Service, we may collect:
- Account and contact data: mobile phone number, one-time verification codes, display name, and language preferences.
- Identity and KYC data: information required to verify your identity and meet legal obligations, such as government ID details, date of birth, address, and photographs or selfies submitted for verification.
- Profile and app data: savings goals, membership status, notification settings, device type, operating system version, app version, and in-app preferences.
- Transaction and activity metadata: when funding, allocation, withdrawal, redemption, or membership features are available, records such as amounts, timestamps, references, status, and related operational logs. We do not use the Service to store full payment card numbers on your device.
- Support communications: messages you send to us by email or through in-app support channels.
- Technical and security data: IP address, session identifiers, authentication events, and diagnostic logs used to secure the Service and prevent abuse.
We collect information you provide directly, information generated through your use of the Service, and information from identity-verification and payment partners where needed to operate the Service lawfully.
3. How we use your information
We use personal information to:
- create and manage your account and authenticate you by phone;
- provide allocated precious-metals savings features, membership benefits, and customer support;
- verify identity, conduct anti-fraud checks, and meet applicable legal and regulatory obligations;
- process transactions and maintain accurate records when those features are live;
- secure the Service, detect misuse, and troubleshoot technical issues;
- communicate with you about the Service, including important notices and support responses;
- improve reliability, performance, and user experience through aggregated or de-identified analytics where appropriate.
4. Legal bases
Where applicable law requires a legal basis, we rely on: performance of our contract with you; compliance with legal obligations; our legitimate interests in operating a secure financial-services-style product; and, where required, your consent.
5. How we share information
We do not sell your personal information for advertising. We may share information only with:
- service providers that help us host infrastructure, verify identity, process payments, send messages, or provide customer support, under contractual confidentiality and security obligations;
- professional advisers, auditors, or insurers where reasonably necessary;
- law enforcement, regulators, courts, or other authorities when required by law or to protect rights, safety, and security;
- a successor entity in connection with a merger, acquisition, or asset transfer, subject to this Policy.
6. Advertising and tracking
We do not use your personal information for third-party advertising. The Service does not currently use the Apple App Tracking Transparency framework for cross-app tracking. If that changes, we will update this Policy and, where required, request your permission before tracking.
7. Retention
We retain personal information only as long as needed to provide the Service, meet legal and regulatory record-keeping requirements, resolve disputes, and enforce our agreements. Retention periods may vary by data type and legal obligation. When information is no longer required, we delete or de-identify it using reasonable technical measures.
8. Security
We implement administrative, technical, and organizational measures designed to protect personal information, including encryption in transit, access controls, and monitoring. No method of transmission or storage is completely secure; we cannot guarantee absolute security.
9. Your rights
Subject to applicable law, you may have rights to access, correct, delete, restrict, or object to certain processing of your personal information, and to withdraw consent where processing is consent-based.
You can request access or deletion by using Settings → Delete Account in the app (where available) or by using our Support page. We may need to verify your identity before fulfilling a request and may retain certain information where the law requires.
10. Account deletion
To delete your account:
- Open the ASL app and sign in.
- Go to Settings.
- Select Delete Account and follow the prompts.
If you cannot access the app, use our Support page and include the address associated with your account. Deletion is subject to legal retention requirements for financial and compliance records.
11. Children
The Service is not directed to children under 18. We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us and we will take appropriate steps.
12. International processing
Your information may be processed in Egypt and in other countries where our service providers operate. Where required, we use appropriate safeguards for cross-border transfers.
13. Changes to this Policy
We may update this Privacy Policy from time to time. We will post the updated version on this page and revise the “Last updated” date. Material changes may also be communicated in the app or by email where appropriate.
14. Governing law
This Privacy Policy is governed by the laws of the Arab Republic of Egypt. Disputes relating to this Policy shall be subject to the exclusive jurisdiction of the competent courts in Cairo, Egypt, unless mandatory law provides otherwise.
15. Important product notice
ASL is a precious-metals savings product focused on allocated silver and gold; it is not a bank account, deposit product, or securities offering. Nothing in this Policy or the Service constitutes investment, tax, or legal advice. Metal prices fluctuate and you may receive less than you paid. Our regulatory posture may evolve as the product launches and applicable rules are clarified; we do not represent that any specific licence or approval has been obtained unless we state that expressly in the app or on our website.
16. Contact
Website: aslbullion.com
Support page: aslbullion.com/support