1.     Privacy


1.1.  Collection of personal information. We collect information to provide better services to all of our users. We collect the following types of personal information in order to provide you with the use of the Service and to help us personalize and improve your experience.


1.2.  Information you provide to us. When you use the Service, we collect information sent to us by your Mobile Device. The information sent to us includes, but is not limited, to the following: data about the pages you access, device ID or unique identifier, device type, geo-location information, connection information, mobile network information, information related to the transactions you process, their amount, their frequency, the kind of goods or services involved in transactions, the time of the transaction and other related  information.


1.3.  Information you provide to us. We may collect and store any information you provide to us when you use the Service, including when you add or update your AzamPay Account, participate in community discussions or dispute resolutions or when you otherwise correspond with us regarding the Service. When you use the Service, we also collect information about your transactions and activities. In addition, when you open an AzamPay Account or use the Service, we may collect the following types of information:


(a)   Contact information, such as your name, address, phone, email and other similar information;

(b)  Financial information, such as your full bank account numbers or a tokenized representation of such number that you link to your AzamPay Account and give us when you use the Service [note:  We are collecting, but not storing, the bank account number.  It is only retained as long as needed to validate the number with the bank.  After which time, we store only the token];

(c)   Detailed personal information such as your date of birth or national ID number.


We may also collect from or about you from other sources, such as through your contact with us, including our customer care support team, your results when you respond to a survey, your interaction with other members of the Group.


1.4.  Information from other sources. We may also obtain information about you from third parties such as credit bureaus and identity verification services.


1.5.  What we do with your personal information. Our principal purpose for collecting your personal information is to provide you with a secure, smooth, efficient and customized experience. We may use your personal information to:


(a)   provide the Service and customer service support;

(b)  process Payment Transactions and send notices about your transactions;

(c)   verify your identity, including during account creation and password reset processes;

(d)  resolve disputes and troubleshoot problems;

(e)   manage risk, or to detect, prevent or remediate fraud or other prohibited or illegal activities;

(f)   detect, prevent or remediate violations of policies or applicable user agreements;

(g)   improve the Service by customizing your experience;

(h)  measure the performance of the Service and improve its content and layout;

(i)    manage and protect our information technology infrastructure;

(j)    for marketing purposes, provide service update notices or deliver promotional offers based on your preferences;

(k)  contact you as authorized by these Terms;

(l)    perform creditworthiness and solvency checks and compare information for accuracy and verify it with third parties.


1.6.  Direct marketing. We do not sell or rent your personal information to third parties for their marketing purposes without your express consent. We may use your personal information to provide you with information about products, promotions and such other information which we believe may be of interest to you if you select to receive such information when you complete the registration process. you can change your mind about your preferences in respect of marketing by unsubscribing to direct marketing through the directions provided within your AzamPay Account.


1.7.  Disclosure of your personal information. We will not disclose your personal information to any third party without your express consent, except:


(a)   to a member of the Group to provide the Service (including but not limited to help detect and prevent potentially illegal acts and violations of our policies);

(b)  to our professional advisers;

(c)   as required by applicable law or where it is necessary to protect out legitimate interests.


1.8.  Cookies. When you access the Service, we may place small data files on your Mobile Device. These data files may be cookies, pixel tags, "Flash cookies," or other local storage provided by your browser or associated applications (collectively "Cookies"). We use these technologies to recognize you as a customer; customize the Service, content, and advertising; measure promotional effectiveness; help ensure that your account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety across our sites and the Service.


1.9.  You are free to decline our Cookies if your browser or browser add-on permits, unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with your use of our website and AzamPay Services.


1.10.    How we keep your personal information secure. However, protecting your privacy is very important to us. In order to do so, we have put in place reasonable procedures to safeguard and secure the personal information which we collect. This has been done with a view to prevent unauthorized or unlawful processing of your personal information and accidental loss or destruction of, or damage to, your personal information.  We protect the security of your personal information by:

(a)   using encryption where appropriate;

(b)  using password protection were appropriate; and

(c)   limiting access to your information


1.11. Whilst we have done all of this, we cannot guarantee that your information is secure when submitted or otherwise communicated through insecure means. Use of the Service involves the electronic transmission of personal information through third party connections. Because we do not operate or control these connections, we cannot guarantee the privacy or security of these data transmissions. We are not responsible for your Mobile Device or the software or hardware it contains and make no representations, warranties, or guarantees regarding the same.


1.12.    You must also take appropriate steps to keep your information secure as advised below at clause 2.



2.     Security

2.1.  The Service stores information of your Payment Account in your Mobile Device and therefore should be protected in the same manner as you would be required to protect details of your Payment Account under the terms agreed with your Participating Bank. The Service does not store details of your actual Payment Account Number, but rather stores a tokenized version of that number.


2.2.  You must keep your username and Passcode secret and secure at all times and exercise reasonable care and diligence to prevent any unauthorized use including by avoiding obvious usernames and Passcodes, by changing your Passcode regularly and by ensuring that you do not disclose your Passcode or grant any other person access to your AzamPay Account. You agree to refrain from using any functionality that saves or store your username and Passcode on your Mobile Device.


2.3.  Once you have logged on to the Service, you must not leave the Mobile Device from which you have accessed the Service unattended at any time or let anyone else use it until you have logged off the Service. You must also ensure that you log off the Service at the end of every session.


2.4.  You are responsible for all Payment Transactions carried out using your Passcode including those made by persons that you give access to or that otherwise use your Passcode.


2.5.  If your Mobile Device is lost or stolen, you must immediately notify us. If you change your Mobile Device, you must delete all Payment Account information from your old Mobile Device.