This Privacy and Cookies Policy is intended for those accessing or using Safecharge Sandbox and Safecharge Express products, services and websites including all displayed information and material (together “Safecharge Express”) owned and/or operated by SafeCharge Limited and its affiliates and subsidiaries (“we” or “us”) and describes and explains how we treat information that is received and/or collected, when received or collected, through the access or use of Safecharge Express or a related application. The protection of privacy and the safeguarding of our Client’s personal and financial information is our highest priority. Special attention is paid to privacy and regulations.
We encourage you to review this Privacy and Cookies Policy carefully and to periodically refer to it so that you familiarize yourself with our Privacy and Cookies Policy and understand it and the subsequent changes, if any.
Some of our products and services require registration, in which case you may need to provide additional information including certain personal information and this Privacy and Cookies Policy shall apply subject to the terms, conditions and privacy guidelines specific to such products and services, where available.
Why we collect and process Personal Data
You share information with us when you use our services. We use this information to comply with our legal obligations (such as laws to prevent money-laundering), where the processing being necessary for the performance of the contract (such as using your email address to send an email providing you access to the services), where the processing is in our legitimate interests (such as checks to prevent and detect fraud), to find out which products and services you might be interested in, and what solutions we should build in the future.
How we collect information
Our products and services require registration. Your organization must provide information, including certain personal information. We will always ensure that your data is obtained fairly. We will do this by providing you with the necessary information in a clear manner so that you can determine the purposes for which your information will be used at a given time. We will collect your data through a number of different channels including, but not limited to, when you and/or your organization:
(a) purchase products or services from us;
(b) register your details with us as part of registration, or to receive communications;
(c) submit enquiries to us or contact us generally;
(d) enter any promotions, competitions or prize draws;
(e) use any of our products or services;
(f) allow another company to share information with us and that company shares information with us;
(g) take part in market research;
(h) terminate your account with Us; and/or
(i) provide us with information and documents as part of our Know Your Customer processes
We will also collect Your Data indirectly from you when you:
(a) visit or browse our internet site, related micro-sites or other related sites;
(b) use our products or services.
Please note that our interfaces (including the application and website) gather certain data, (for example IP-address, date, time, internet browser details, cookies, geographical location and viewed pages) and that this is saved on our server. The right to conduct statistic evaluation of anonymous data sets is reserved by us.
We may also collect your data from other sources including, but not limited to: (a) fraud prevention agencies; (b) other telecommunications providers or financial institutions; (c) business directories, telephone directories, electoral registers and other commercially or publicly available sources. Should you opt to provide us with information about third parties (for example, if you provide us with contact details of another person), it is your responsibility to first secure the consent of such third party to the disclosure of information to us and our subsequent use of such information as per this policy.
How we use Your Data
Your data will be used primarily for the purposes of the administration of the Safecharge Express service, the processing of transactions carried out using the service and routine account maintenance. However, your data may be used for a number of other purposes including but not limited to:
(a) supplying products and services that you have ordered/requested, including services that may display customised content and advertising;
(b) informing you of any service related message that may be relevant to your services;
(c) verifying that you are an authorised user of the account for security purposes;
(d) assisting us in preventing and detect fraud and other crimes;
(e) assisting you with any product or service enquiries, complaints or issues that may arise;
(f) analysing markets and producing reports, performing research and statistical analysis, and to monitoring usage behavior to improve our technologies and services;
(g) marketing our products and services generally; and/or
(h) informing you of any products and services offered by other companies that we think may be of interest to you, provided that you have chosen to receive this information;
Disclosure of Your Data
Your data will only be disclosed in limited circumstances such as where we are obliged to do so by law, or where it is shared with our partners, agents, affiliates and subcontractors who are involved in the delivery of products or services used or ordered by you.
We may share information internally as well with third parties, such as trusted suppliers, service providers, business partners, advertisers and search engines. However, unless specifically indicated in this document, such information is collected and shared without any association to your personally identifying information so that you remain anonymous.
We may share and/or transfer information including personally identifying information internally as well as with government bodies and law enforcement agencies (where lawfully instructed or required), successors in title to the respective business (i.e. if we become involved in any form of merger or acquisition) and to affiliates, partners or suppliers we engage (e.g. to process data on our behalf).
Retention of Information
|Type of Record or Information||Retention Period|
|Cookies||Cookies are stored on a per session basis to aid your navigation of our web-sites. Persistent cookies may be set to store display related preferences. Depending on your browser you may also be able to control cookie use by altering your browser settings.|
|Transaction||End of relationship plus six years.|
|KYC Documents and Data||Five years from the date on which the transactions were completed or the business relationship terminated.|
Pseudonymized data (that is data that has been changed so that it does not identify an individual person) may be retained for longer periods for the purposes.
Accessing your Information
You have a right of access to copies of your personal data kept by us. Such requests should be made in writing and addressed to email@example.com and the subject should contain the words “Data Access Request”. You should include adequate information to identify yourself, including, name, address, account number and/or mobile phone number. We will take all reasonable steps to verify your identity before issuing your data. We will comply with your request as soon as is practicable.
You also have a right to have inaccurate information corrected. If you discover that we hold inaccurate information about you, you may instruct us to correct that information. Your instruction should be in writing to the address outlined above. Your request will be dealt with as soon as possible.
You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browsers.
Cookies are typically divided into four main types, we may use some or all:
- Strictly necessary cookies. These are cookies that are required for the operation of a website. They include, for example, cookies that enable users to log into secure areas of a website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. These types of cookies allow providers to recognise and count the number of visitors and to see how visitors move around their website when they are using it. This assists providers in improving the way their website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise users when they return to a website. They enable the personalisation of content, the recognition of users and remember user preferences (for example, their choice of language or region).
- Targeting cookies. These cookies record a user’s visit to a website, the individual pages visited and the links followed. If the cookie is set by a third party (for example, an advertising network) which also monitors traffic on other websites, this type of cookies may also be used to track a user’s movements across different website and to create profiles of their general online behavior. Information collected by tracking cookies is commonly used to serve users with targeted online advertising.
Below you will find the list of cookies used by us and a description of what each cookie is designed to accomplish, the list may be updated from time to time and you are invited to check back on a regular basis. Please note the difference between a ‘session cookie’ (i.e. expires at the end of the session) and a ‘ persistent cookie’ which does not expire at the end of the session.
|Name of cookie||Source||Purpose|
|_ga||Google Analytics||This cookie is used with Google’s Universal Analytics suite. It is used to uniquely identify you as a visitor to this site. This is achieved by generating two random numbers and setting them in a cookie, no personal information or data is tracked. It expires after 2 years.|
|_gat||Google Analytics||This cookie is used with Google’s Universal Analytics suite. This cookie is used to monitor and track visitor’s behavior on the site anonymously. This cookie throttle’s the request rate back to Google. It expires after 10 minutes.|
|incap_ses||Incapsula CDN/DDOS protection||Content Delivery Network Cookie. This is used to improve performance of the website by serving cached data from Incapsula’s network, as well as protect the sites against distributed Denial of Service attacks. Expires at session end.|
|visid_incap||Incapsula CDN/DDOS protection||Content Delivery Network Cookie. This is used to improve performance of the website by serving cached data from Incapsula’s network, as well as protect the sites against distributed Denial of Service attacks. Expires after 2 years.|
We use the following Google Analytics cookies to help us as an analytics tool to measure how users interact with the Site: _utma, _utmb, _utmc and _utmz (_utmc is a session cookies and the others are persistent with an expiry date). For more information on the Google Analytics cookies please visit www.google.com/analytics/
For the avoidance of doubt, our services are available to persons under 18 years of age. Persons under 18 years of age should not transfer personal data to us. We do not request personal data from children, do not collect it and do not forward it to third parties.
We have security measures in place to prevent unauthorised access to and protect the loss, misuse and alteration of the information under our control. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorised access, and we make no warranty, express, implied or otherwise, that we will prevent such access. We point out that data transmission over the Internet (e.g. when communicating by e-mail) may have security gaps.
Complete protection of data against unauthorised access by third parties is not possible.
Insofar as we commission third parties for hosting and/or other technical service, we make a careful selection of our hosting services and all other technical operations involved as part of our duty of care to ensure that such service providers are in compliance with this Privacy and Cookies Policy and the applicable laws and regulations.
Please note that this policy is continuously under review and we reserve the right to amend or modify this Privacy and Cookies Policy at any time with immediate effect. We will post any amended versions of this policy on this page so you will always know how we collect, use and disclose your
Safecharge regularly reviews its compliance with this policy. If you have any queries, questions or concerns regarding this policy or treatment of personal data please contact us via Customer Care at firstname.lastname@example.org
Date of last update: February 2018