SMARTPESA RESPONSIBILITY

Where Licentia Group Ltd and its subsidiaries (trading as MYPINPAD and Transaction Technologies (MPP)) is acting as a service provider and where MPP possesses or otherwise stores, processes, or transmits cardholder data on behalf of the customer, or to the extent that MPP could impact the security of the customer’s cardholder data environment, MPP acknowledges that it is responsible for the security of cardholder data.

SMARTPESA PRIVACY POLICY

We are committed to protecting the privacy of our users.

This SmartPesa Privacy Policy (“Privacy Policy“) has been prepared by Transaction Technologies Pte. Ltd., a company incorporated in Singapore with the registration number of ​201414504W to help you understand what information we gather, how we use it, what we do to protect it, and to assist you in making informed decisions when using our Services.
In this Privacy Policy:

  1. “Services” refer to apps, products, services, technologies and websites offered by us and “Service” refers to any of the Services;
  2. “we“, “us“, and “our” refers to Transaction Technologies Pte. Ltd.; and
  3. “you” refers to you, as a user of Services.

Unless otherwise indicated below, this Privacy Policy will apply to all the Services (excluding services that may have separate privacy policies and which do not incorporate this Privacy Policy) and any information about you which we may collect from you, any person authorised by you, third parties and publicly available sources.

  1. CONSENT

By using any our Service or voluntarily providing us with information, you accept our Privacy Policy and the applicable terms of use in respect of that Service (“Terms of Use”), and you consent to our collection, storage, use and disclosure of your information as described in this Privacy Policy. This Privacy Policy applies to all users of the Services, regardless of whether such users have registered for or created any account with us.

  1. INFORMATION WE COLLECT

We may collect both “Personal Information” and “Non-Personal Information” about you.

“Personal Information” means data, whether true or not, about a person who can be identified from that data, or from that data and other information to which we have or are likely to have access.

“Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks.

We may collect the following types of Personal Information when you provide such information to us, or when you use our website or our Services:

  1. We may collect your personal particulars, including but not limited to your name, address and email address, as well as any other information which we may require as part of the anti-money laundering and countering the financing of terrorism checks.
  2. We may also collect other forms of Personal Information that you provide to us upon our request, or when you correspond with us, including when you correspond with us to provide feedback or report problems with our website or Services.
  3. In addition, we may also track information provided to us by your browser or by our mobile application when you view or use the Services, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Services, the time and date of access, and other information that does not personally identify you. We use this information for, among other things, the operation of the Services, to maintain the quality of the Services, to provide general statistics regarding use of the Services and for other business purposes. We track this information using cookies, or small text files which include an anonymous unique identifier.

Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive. Sending a cookie to a user’s browser enables us to collect Non-Personal Information about that user and keep a record of the user’s preferences when utilizing our services, both on an individual and aggregate basis. We may use both persistent and session cookies; persistent cookies remain on your computer after you close your session and until you delete them, while session cookies expire when you close your browser. Persistent cookies can be removed by following your Internet browser help file directions. If you choose to disable cookies, some areas of the Services may not work properly.

You represent and warrant that the Personal Information which you provide or otherwise disclose to us is accurate and complete. If you provide us with any Personal Information relating to a third party, you represent and warrant that (i) such Personal Information is accurate and complete; (ii) you have obtained the consent of the said third party to the collection, use, processing and disclosure of their Personal Information on the terms set forth in this Privacy Policy, and are duly authorised by the third party to do so.

  1. HOW WE USE AND SHARE INFORMATION
  1. Personal Information:

We will only collect, use, disclose or process your Personal Information to the extent necessary for the purposes described under this Privacy Policy, and to the extent allowed under the relevant data protection legislation, including but not limited to the Singapore Personal Data Protection Act (Act No. 26 of 2012), (“Data Protection Legislation“).

We may use your Personal Information for any or all of the following purposes:

  1. to provide you with the Services and to develop, improve and maintain the Services;
  2. to manage your subscription for the Services, including the creation and management of your accounts;
  3. to facilitate certain events that we hold and organise;
  4. to respond to and deal with enquiries or complaints, providing maintenance and support and preparing for data backup;
  5. to conduct investigations, internal audits or take action, including in relation to any violation of terms and conditions for the Services;
  6. to provide to third parties who provide Services on our behalf, but only to the extent necessary for the Services to be provided;
  7. to send you marketing and/or promotional materials on our latest Services or those of carefully selected third parties, so long as you consent to it;
  8. to meet legal and regulatory requirements imposed by the applicable public authorities, laws or regulations; and
  9. for any other purposes which are necessary, ancillary or consequential to the above.

In general, we do not sell, trade, rent or otherwise share your Personal Information with third parties without your consent. We may disclose your Personal Information with vendors and other third-party providers who are performing services for us. In general, the vendors and third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide for us. For example, when you provide us with Personal Information to complete a transaction, verify your credit card, place an order, arrange for a delivery, or return a purchase, you consent to our collecting and using such Personal Information for that specific purpose, including by disclosing such information to our vendors (and their service providers) performing these services for the Company.

However, certain third-party service providers, such as payment processors, have their own privacy policies in respect of the information that we are required to provide to them in order to use their services. For these third-party service providers, we recommend that you read their privacy policies so that you can understand the manner in which your Personal Information will be handled by such providers.

In addition, we may disclose your Personal Information if required to do so by law or if you violate our Terms of Use.

  1. Non-Personal Information:

In general, we use Non-Personal Information to help us improve the Services and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns of the Services. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our sole discretion.

  1. RETENTION OF PERSONAL INFORMATION

We shall collect and retain Personal Information in accordance with this Privacy Policy for as long as it is necessary, required, or relevant for business or legal purposes.

Without prejudice to any other provision in this Privacy Policy, we retain the right to collect and store identifying information for the purpose of providing and improving the quality, features and user experience of our website and/or Services. All identifying information will be stored and handled with proper security measures as required under the applicable data protection legislation.

  1. TRANSFER OF PERSONAL INFORMATION

We shall only transfer Personal Information outside Singapore in accordance with the Personal Data Protection Act (Act No. 26 of 2012).

Due to the nature of the Services provided by us, you agree, acknowledge and consent that your Personal Information (and such other Personal Information which you provide to us) may be stored or processed in any country where we have operations or where we engage service providers.

We may transfer Personal Information outside Singapore to countries which may have data protection rules that are different from those of Singapore. However, we shall take measures to ensure that any such transfers comply with the Personal Data Protection Act (Act No. 26 of 2012), and such Personal Information remains protected to the standards described in this Privacy Policy.

In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access the personal data.

  1. HOW WE PROTECT INFORMATION

We will make reasonable security arrangements to protect Personal Information in our possession or under our control, to prevent unauthorised access, collection, use, disclosure, copying, modification, deletion or similar risks, including implementing reasonable precautions and following industry best practices. However, while we will comply with our obligations under the Data Protection Legislation, we do not guarantee that your information will not be accessed, collected, used, disclosed, copied, modified or destroyed by breach of such precautions. By using any of Services, you acknowledge that you understand and agree to assume these risks.

  1. YOUR RIGHTS REGARDING THE USE OF YOUR PERSONAL INFORMATION

You may withdraw your consent to our continued use and/or disclosure of your Personal Information for any of the purposes and in the manner as stated in this Privacy Policy at any time by contacting us, using the contact details in this Privacy Policy. However, the withdrawal of your consent may result in us not being able to continue to provide our Services to you or perform our contractual obligations to you, and you release and hold harmless us from any complaint, claim, damage, loss, penalty or fines which you may have against us or which you may incur as a result. Our legal rights and remedies are expressly reserved.

You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to a user, and the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out in the Settings section of the Site, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Policy.

  1. LINKS TO OTHER WEBSITES

As part of the Services, we may provide links to or compatibility with other websites or applications which are not maintained by us. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain.

This Privacy Policy applies solely to information collected by us through or in relation to the Services and does not apply to your use of any third-party website or application. To the extent that you access or use the Services through or on a third-party website or application, then the privacy policy of that website or application will apply to your access or use of that website or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

  1. AGE OF CONSENT

You represent that you are at least 18 years of age or such minimum age of majority in your jurisdiction.

  1. CHANGES TO OUR PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy, we will post these changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it.

Any such modifications become effective upon your continued access to and/or use of the Services five (5) days after we first post the changes on the website or otherwise provide you with notice of such modifications. It is your sole responsibility to check this page from time to time to view any such changes to the terms of this Privacy Policy. You can see when this Privacy Policy was last revised by referring to the “Last Updated” legend at the bottom of this page. If you do not agree to any changes, if and when such changes may be made to this Privacy Policy, you must cease access to this website. If you have provided your email address to us, you give us permission to email you for the purpose of notification as described in this Privacy Policy.

  1. MERGER OR ACQUISITION

In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy. If our information practices change at any time in the future, we will post the policy changes here so that you may opt out of the new information practices. We suggest that you check this Privacy Policy periodically if you are concerned about how your information is used.

  1. EMAIL COMMUNICATIONS & OPTING OUT

We will send you announcements relating to the Services on occasions when it is necessary to do so. For instance, if the Services are temporarily suspended for maintenance, or a new enhancement is released, which will affect the way you use the Services, we might send you an email. As these communications are necessary for us to provide the Services to you, you may not opt-out of these communications, which are not promotional in nature. Based upon the Personal Information that you provide us, we may communicate with you in response to your inquiries to provide the services you request and to manage your account. We will communicate with you by email or telephone, in accordance with your wishes.

We may also use your Personal Information to send you updates and other promotional communications. If you no longer wish to receive those email updates, you may opt-out of receiving them by following the instructions included in each update or communication.

  1. ACCESS, CORRECTION AND UPDATE OF PERSONAL INFORMATION

You shall ensure that all Personal Information provided to us is accurate, complete and up-to-date. If there are any changes to your Personal Information, or if you believe that the Personal Information we have about you is inaccurate, incomplete, misleading or not up-to-date, please contact us so that we may take steps to update your Personal Information.

You may request access to your Personal Information held by us, subject to any fees which we may charge for processing your request for access. Such fees will depend on the nature and complexity of your access request. Information on the processing fee will be made available to you.

  1. CONTACT US & WITHDRAWING CONSENT

If you have any questions regarding this Privacy Policy or our privacy practices, or wish to withdraw your consent for the continued collection, use or disclosure of your information, please contact us by sending an email to info@smartpesa.com.

Last Updated: This Privacy Policy was last updated on January 25, 2021.