This Policy outlines your rights to your personal information and contains general principles that apply to the handling of your personal information when you use any of Sadapay UK Limited's (“SadaPay”) services.

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We believe that all of our customers should be able to trust SadaPay with their personal and financial information which is why we apply the following key privacy principles in every country in which we operate:

The data we collect and the way we record and store your personal information vary depending on why we collect your information, which in turn depends on the services you are using.

Generally, we collect and use your personal information where:

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There is certain personal information that is necessary for us to perform services you use. These include:

• Your name, phone number, email address, home address, date of birth, and other information provided when you sign up for using any of the services provided by SadaPay.
• Your biometric data while signing up for any of the services provided by SadaPay
• Payment-related information, such as credit or debit card information or other banking and payment information;
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Typically, we collect this information:

• When you sign up, buy, or use our products or services;
• When you subscribe to our newsletters or promotions about our products or services;
• When you contact us for information, question, or feedback about our product, service, or website.
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We generally use this information to perform the relevant service or provide the relevant product;

• manage your account;
• carry out credit checks;
• request payments; and
• communicate with you.

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During your use of our products, services, or websites, we may also collect other information from you.

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Some examples of such information include:

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• Information about your SadaBiz account and our communications with you, such as any customer support requests that you make or any feedback that you provide, dates of payments, and dates of invoices;
• Product usage data, such as your last active use of an application, the duration you spent on an application, and how much you spent on a product;
• Network data, including mobile calls and sms data, such as the date and time of the calls and texts you send or receive, and the duration of calls received and made through our network;
• Your geolocation data, when:
• you use our telecommunications services, such as call, sms, or broadband services;
• you choose to use our location-based service. For example, when you enable direction applications on your mobile phone; and
• you signed up for certain location-based promotional activities.
• Your browsing data, when you visit one of our websites and/or use some of our services. Information that we collect may include:
• information relating to your device, such as IP address, unique device identifiers, device model, and settings;
• network information;
• details and logs of when, where, and how you used the service;
• browser information such as type and version and browser plug-in; and
• information about your visit, including the websites that directed you to us, the pages on our website that you visited, services and products that you viewed or searched for, length of visit, our interaction with you, and the next websites you visit after our website.
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Typically, we use the information above and any other information necessary to:
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• improve customer experiences, such as for troubleshooting, network management, and network optimization purposes;
• use the recorded communications information for training quality assurance, feedback, or for records purposes;
• find ways in which we can better improve our service, such as using personal and/or aggregated statistics or de-identified information about sales, services, customers, network traffic, and location patterns to conduct research to help improve our understanding of your behaviors;
• conduct research that creates value for the community
• create customer profiles about you to offer you personalized content, provide a more relevant user experience or products and services, and ensure that we will not be recommending products and services that you may not be interested in. We may also use this information to find out whether you enjoy receiving our personalized services;
• analyze the use of our network and services to identify general trends and partner with third parties to develop new services for you;
• send you marketing communications about products and services based on your preferences and interests; and/or
• share your information within our affiliate companies, for processing, advertising, service development, cross-product marketing and sales, product and service creation, measurement, analytics, and research purposes.

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We use the information we have to keep our services and communities safe and secure:

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• we may investigate or take action regarding suspicious and illegal activities that violate our Seller’s Terms of Service and the Payment Link Terms or the applicable law; and/or
• share your information, in accordance with applicable laws/regulations and/or court orders, with the relevant authorities, for example, to protect you or someone else from harm or damage.

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We may also collect and process information about you when you consent to us collecting and processing this information.

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We sometimes collect personal information about you from third parties. Examples of the type of information that we collect are:

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• Your credit information, to help us with customer authentication and credit-related decisions;
• If you consent, other information, such as demographic information, to better understand you and your interests and offer you personalized services. Examples of third parties that we collect the information from include payment and delivery services, advertising networks, analytics providers, search information providers; and
• Social media information, such as your interests, “Likes” and friends list, when you use your social media credentials to interact with the SadaPay mobile application, our webpage, or offer.
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You can object to any of the processing above by, unless the information was required for us to perform the services.

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We may share your personal information with an affiliate company or third parties for the purposes listed above. Sometimes, the third party with which we share your personal information with may determine the purposes for which and how your personal information is processed, and therefore we shall ensure that the said third party follows the same privacy practices towards your information in accordance with our key privacy principles, this privacy statement and applicable law.

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More detailed examples of the third parties we may share your information with include:

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• Any of SadaPay’s affiliate companies (including our parent Group);
• Data processors to process your information on our behalf;
• Third-party services that you have asked us to integrate with, such as social networks
• Third parties who conduct research, analytics, or marketing in conjunction with us or on our behalf;
• Relevant third parties whom you consented to or that you requested that we share the information with;
• Prospective business partners, following your consent, if we decide to sell, buy, merge, or otherwise re-organize our business;
• Following your consent, third parties that conduct advertising, measurement, and analytics;
• Law enforcement agencies, where we are required to provide our cooperation for law enforcement purposes; and
• Third-party service providers such as debt collection agencies and credit check agencies.

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We ensure that your personal information is safe and secure through the following measures:

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• When you log into your account to use our services with your phone number or username and password, all of the data is encrypted using cryptographic protocols such as Transport Layer Security (TLS) and Secure Socket Layer (SSL) encryption. We employ such cryptographic protocols on all pages of our websites where we collect personal information. To make purchases from these web pages, you must use a TLS or SSL-enabled browser such as Internet Explorer, Safari, Firefox, or Chrome. This ensures that your personal information remains confidential and is protected while it is transmitted over the Internet;
• If your account has been inactive for some time, we automatically log you out to keep your details secure;
• When we use service providers or other data processors to process your personal information on our behalf, we ensure that the relevant providers and processors will implement appropriate technical and organizational measures to protect the information. Such controls include access control to the information and the infrastructure that stores the information, and contractual arrangement that requires the third parties to comply with all relevant laws. We apply for privacy and data protection by design and by default and build privacy and data protection into the foundation of our products and services.

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We will only process your personal information for legitimate purposes, and only for as long as it is necessary to achieve those purposes. We will dispose of your personal information safely and securely once it is no longer required subject to applicable laws for retention of data.

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t is important to us that you understand your privacy rights. Therefore, we have listed out below a non-exclusive list of privacy rights that you could exercise whilst entrusting us with your information:

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• Right to withdraw consent: Where you have consented for us to use, process, or share your personal information, you can withdraw that consent at any time, unless the information is required for us to perform our services.
• Right to access your information: You can access and request a copy of the personal information that we hold about you at any time by contacting us or accessing the information directly through your e-wallet account.
• Right to erasure: You can request that we erase some of the personal information we hold about you, provided that certain circumstances apply:
• The information is no longer needed by us and there is no legal requirement on us to retain the information;
• Other legal grounds permit you to do so.
• We will do our best in accommodating the request, but please bear in mind that this may result in you being ineligible to receive certain services.

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We commit to reviewing this statement at least once annually and on an ongoing as-needed. If there are substantial changes to the statement, we will inform you through ways in which we think fit, which may include a prominent announcement on our homepage, emails, SMS, or message to your registered device.

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We will consider factors such as the materiality of the change, the services affected by the change, and the reach when we choose a method of notification.