- WHO WE ARE
- HOW WE COLLECT INFORMATION
To the extent permissible under applicable laws, we collect information about you and any other party whose details you provide to us when you:
- register to use our websites and portals (including free trials); this may include your name (including business name), address, email address and telephone number. We may also ask you to provide additional information about your business and your preferences;
- complete online forms (including call back requests), take part in surveys, post on our message boards, post any blogs, download information such as publications or participate in any other interactive areas that appear on our website or portals;
- interact with us using social media;
- provide your contact details to us when registering to use or accessing any websites or portals we make available or when you update those details; and
- contact us offline, for example by telephone, SMS, email, post or any other means of communication.
We will also collect your information where you only partially complete and/or abandon any information inputted into our website and/or other online forms and may use this information to contact you to remind you to complete any outstanding information.
We also collect information from your devices (including mobile devices) and applications you or your users use to access and use any of our websites or portals (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history and your web log information) and we will ask for your permission before we do so. We may do this using cookies or similar technologies.
We may enhance personal information we collect from you with information we obtain from third parties that are entitled to share that information; for example, information from other agencies, search information providers or public sources (e.g. for due diligence purposes), but in each case as permitted by applicable laws.
Providing us with information about others
- HOW WE USE YOUR INFORMATION
To the extent permissible under applicable law, we use your information to:
- provide any information and services that you have requested;
- compare information for accuracy and to verify it with third parties;
- provide, maintain, protect and improve any information and services that you have requested from us;
- manage and administer your use of services you have asked us to provide;
- manage our relationship with you (for example, customer services and support activities);
- monitor, measure, improve and protect our content, websites/ portals and provide an enhanced, personal, user experience for you;
- undertake internal testing of our website, systems and portals to test and improve their security, provision and performance, in which case, we would pseudonymise any information used for such purposes, and ensure it’s only displayed at aggregated levels which will not be linked back to you or any living individual;
- provide you with any information that we are required to send to you to comply with our regulatory or legal obligations;
- detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
- contact you to see if you would like to take part in our activities (for example, feedback on your use of our website and portal);
- to monitor, carry out statistical analysis and benchmarking, provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual;
- deliver targeted advertising or information to you which may be useful to you, based on your use of our website or portal;
- deliver joint content and services with third parties with whom you have a separate relationship (for example, social media providers); and
- provide you with location- based services (for example, advertising and other personalised content), where we collect geo-location data.
Our websites, portals (including mobile applications) and services may contain technology that enables us to:
- check specific information from your device or systems directly relevant to your use of the websites or portals against our records to make sure the websites, applications or services are being used in accordance with our end-user agreements and to troubleshoot any problems;
- obtain information relating to any technical errors or other issues with our website or portal;
- collect information about how you and users use the functions of the features of our website and portal; and
- gather statistical information about the operating system and environment from which you access our applications or services.
You can manage your privacy settings within your browser or our applications and services (where applicable).
In addition to the purposes described in this section 3, we may also use information we gather to deliver targeted advertising or information to you which may be useful, based on your use of the website, applications or services or any other information we have about you (depending on the websites, applications or services, you may be able to configure these features to suit your preferences).
We may monitor and record our communications with you, including e-mails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about our websites and portals you request from us or ask us about, and in order to meet our legal and regulatory obligations generally.
Mobile applications may provide us with information related to a user’s use of that mobile application and use of our applications and services accessed using that mobile application. We may use such information to provide and improve the mobile application or our own application or services. For example, activity undertaken within a mobile application may be logged.
You can configure our mobile application’s privacy settings on your device but this may affect the performance of that mobile application and the way it interacts with our applications and services.
Data analytics and bench-marking
We may use information generated and stored during your use of our services for our legitimate activities to enable us to give you the best service and/or solutions and the best experience. These purposes include to:
- deliver advertising or information to you which may be useful to you, based on your use of services;
- carry out research and development to improve our services and applications;
- develop and provide new and existing functionality and services (including statistical analysis, benchmarking and forecasting services); and
- provide you with location based services (for example location relevant content) where we collect geo-location data to provide a relevant experience.
Whenever we use your information for our legitimate interests, we will ensure that your information is processed on a pseudonymised basis and displayed at aggregated levels, which will not be linked back to you or to any living individual.
You have the right to object to processing based on our legitimate activities but if you object, this may affect our ability to provide certain services and/or solutions for your benefit.
- SHARING YOUR INFORMATION
We may share your information with:
- our service providers and agents (including their sub-contractors) or third parties which process information on our behalf (e.g. internet service and platform providers, payment processing providers and those organisations we engage to help us send communications to you) so that they may help us to provide you with the applications, services and information you have requested or which we believe is of interest to you;
- partners, including system implementers, independent software vendors and developers that may help us to provide you with the applications, services and information you have requested or which we believe is of interest to you;
- third parties used to facilitate payment transactions, for example financial institutions and transaction beneficiaries;
- third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites or other third party application providers);
- fraud prevention agencies;
- regulators to meet NITDA’s regulatory obligations;
- law enforcement agencies so that they may detect or prevent crime or prosecute offenders;
- any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
- any third party in order to meet our legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;
- NITDA professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;
- another organisation to whom we may transfer our agreement with you; and
- MDAs where reporting is mandatory under applicable laws.
We may share non-personally identifiable information about the use of our website or portal publicly or with third parties but this will not include information that can be used to identify you.
- YOUR INFORMATION AND YOUR RIGHTS
If you are based within other jurisdiction having data protection laws, in certain circumstances you have the following rights:
- the right to be told how we use your information and obtain access to your information;
- the right to have your information rectified or erased or place restrictions on processing your information;
- the right to object to the processing of your information e.g. where the processing is based on our legitimate interests;
- the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another organisation, where technically feasible (“data portability”);
- where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
- the right to object to any decisions based on the automated processing of your personal data, including profiling; and
- the right to lodge a complaint with the supervisory authority responsible for data protection matters.
If you request a copy of your information you may be required to pay a statutory fee.
If we hold any information about you which is incorrect or if there are any changes to your details, please let us know so that we can keep our records accurate and up to date.
We will retain your personal information for the duration of our regulatory services to you and afterwards for as long as is necessary and relevant for our regulatory purposes, in accordance with our Act or as otherwise permitted by applicable laws and regulations. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).
- SECURITY, STORAGE OF INFORMATION AND DISCLAIMER
We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. We will do our best to protect your personal information but we cannot guarantee the security of your information which is transmitted to our website/portal or to other websites/portals via an internet or similar connection. If we have given you (or you have chosen) a password to access certain areas of our websites or portal please keep this password safe – we will not share this password with anyone.
- OTHER SITES AND SOCIAL MEDIA
Our websites/portal may enable you to share information with social media sites, or use social media sites to create your account or to connect your social media account. Those social media sites may automatically provide us with access to certain personal information retained by them about you (for example any content you have viewed). You should be able to manage your privacy settings from within your own third party social media account(s) to manage what personal information you enable us to access from that account