Pango Africa Limited
October
2020
Contents
1 – OVERVIEW 2
2 – DEFINITIONS 2
3 – WHAT PERSONAL DATA WE COLLECT 3
4 – WHY WE RETAIN PERSONAL DATA 4
5 – HOW WE PROCESS PERSONAL DATA 4
6 – DO WE SHARE PERSONAL DATA 5
7 – HOW WE WORK WITH OTHER SERVICES AND PLATFORMS 6
8 – HOW WE USE COOKIES AND TRACKING TECHNOLOGIES 7
9 – PRIVACY CHOICES AVAILABLE TO USERS 7
10 – HOW WE PROTECT YOUR PERSONAL DATA 8
11 – USE OF OUR SERVICES BY CHILDREN 8
12 – ADDITIONAL INFORMATION 8
13 – CONTACT US 9
Pango Africa Limited (Pango) has developed this Privacy Policy to explain how we may collect, retain, process, share and transfer your Personal Data when you visit our Sites or use our Services. This Privacy Policy applies to your Personal Data when you visit our Sites or use our Services, and does not apply to online websites or services that we do not own or control, including websites or services of other Pango users.
This Privacy Policy is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our Sites and Services.
Please contact us if you have questions about our privacy practices that are not addressed in this Privacy Policy.
Device Information means data that can be automatically collected from any device used to access the Sites or Services. Such information may include, but is not limited to, your device type, your device’s network connections, your device’s name, your device’s IP address, information about your device’s web browser and the internet connection being used to access the Site or Services, Geolocation Information, information about apps downloaded to your device, and biometric data (e.g. Touch ID/Fingerprint to verify your identity).
Geolocation Information means information that identifies your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. Some of our Services may ask you for permission to share your current location. Some of the Sites and Services require this information to provide a specific product or online service. If you do not agree to our collection of the geolocation information, our Sites or Services may not function properly when you try to use them.
Pango means Pango Africa Limited and its subsidiaries or affiliates. In this Privacy Policy, Pango is sometimes referred to as “we”, “us”, or “our” depending on the context.
Personal Data means personal information that can be associated with an identified or identifiable person. Personal Data can include name, physical or postal address (including billing and shipping addresses), telephone number, email address, payment card number, other financial account information, account number, date of birth, and government-issued credentials (e.g., driver’s license number, national ID, passport, and Taxpayer PIN). Personal Data does not include information that does not identify a specific user.
Process means any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, disseminating or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.
Services means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by Pango.
Sites means the websites, mobile apps, official social media platforms, or other online properties through which Pango offers the Services and which has posted or linked to this Privacy Policy.
Technical Usage Data means information we collect from your phone, computer or other device that you use to access the Sites or Services. Technical Usage Data tells us how you use the Sites and Services, such as what you have searched for and viewed on the Sites and the way you use our Services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through Cookies.
User means an individual who uses the services or accesses the Sites.
We may collect information about you when you visit our Sites or use our services, including the following:
Registration and use information - When you register to use our Services by establishing an Account, we will collect Personal Data as necessary to offer and fulfill the Services you request. Depending on the Services you choose, we may require you to provide us with your name, postal address, telephone number, email address and identification information to establish an Account. We may require you to provide us with additional Personal Data as you use our Services.
Transaction and experience information - When you use our Services or access our Sites to make purchases from merchants, receive money, process payments or to send money to friends and family, we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, merchant information, device information, technical usage data, and geolocation information.
Participant information - When you use our Services or access our Sites, we collect personal data you provide us about the other participants associated with the transaction.
Send or request money: When you send or request money through our Sites or Services, we collect personal data such as name, address, telephone number, and financial account information about the participant who is receiving money from you or sending money to you. The extent of personal data required about a participant may vary depending on the Services you are using to send or request money
Pay or request someone else to pay a bill: If you use our Services to pay your bill or a bill for the benefit of someone else, or if you request a user to pay a bill for you, we collect personal data from you about the account holder such as name, address, telephone number, email address, and account number of the bill that you intend to pay or request to be paid.
Add value to your accounts: If you use our Services to add value to your account or any other account you may have, or if you ask a user to add value to any of these accounts, we may collect personal data from you about the other party, or from the other party about you to facilitate the request.
Information about your friends and contacts - It may be easier for us to help you transact with your friends and contacts if you choose to connect your contact list information with your account. If you establish a connection between your device or a social media platform and establish an account connection between your device or a social media platform and your account, we will collect and use your contact list information (such as name, address, email address) to improve your experience when you use the Services.
Information that you choose to provide us to obtain additional Services or specific online Services - If you request or participate in an optional Site feature, or request enhanced Services or other elective functionality, we may collect additional information from you. We will provide you with a separate notice at the time of collection, if the use of that information differs from the uses disclosed in this Privacy Policy.
Personal data about you if you use unbranded Services - Certain services are available without being required to log in to or establish an account. We will collect Personal Data when you are interacting with and making payments to merchants using our card payment services that do not carry the Pango brand and when you checkout with Pango without logging into an account. For our unbranded payment services, your interaction is with the merchant, on their platform. If you are an Account holder, or create an Account at a later date, we may collect information about unbranded transactions and associate them with your Account to improve your customer experience as an Account holder and for compliance and analytics purposes. If you are not an Account holder, we will collect and store all information you provide and use such information in accordance with this Privacy Policy.
Information about you from third-party sources - We obtain information from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law.
Location - PangoDelivery collects location data to enable the delivery feature even when the app is closed or not in use.
Other information we collect related to your use of our Sites or Services - We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.
We retain Personal Data to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interest, and not prohibited by law. If your Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Policy.
We may process your information for the following reasons;
To operate the Sites and provide the Services, including to;
Initiate a payment, send or request money, add value to an account, or pay a bill;
Authenticate your access to an Account;
Communicate with you about your Account, the Sites, the Services, or Pango;
Create an account connection between your Account and a third-party account or platform;
Perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes;
Keep your Account and financial information up to date.
To manage our business needs such as monitoring, analyzing, and improving the Services and the Sites’ performance and functionality. For example, we analyze User behavior and perform research about the way you use our Services.
To manage risk and protect the Sites, the Services and you from fraud by verifying your identity. Pango’s risk and fraud tools use Personal Data, device information, technical usage data and geolocation information from our Sites and websites that offer Pango Services to help detect and prevent fraud and abuse of the Services.
To market to you about Pango Products and Services and the products and services of affiliated and unaffiliated businesses. We may also process your Personal Data to uniquely tailor the marketing content and certain services or site experiences to better match your interests on Pango and other third-party websites.
To provide personalized Services offered by Pango on third-party websites and online services. We may use your Personal Data and other information collected in accordance with this Privacy Policy to provide a targeted display, feature, Services or offer to you on third-party websites. We may use cookies and other tracking technologies to provide these online services and/or work with other third-parties such as merchant’s, advertising or analytics companies to provide these online services.
To provide you with location-specific options, functionality or offers if you elect to share your geolocation information through the Services. We will use this information to enhance the security of the Sites and Services and provide you with location-based Services, such as advertising, search results, and other personalized content.
To comply with our obligations and to enforce the terms of our Sites and Services, including to comply with all applicable laws and regulations.
To make it easier for you to find and connect with others, we may use the information you have shared with the Service to suggest connections between you and people you may know. For example, we may associate information that we learn about you through you and your contacts’ use of the Services, and information you and others provide to suggest people you may know or may want to transact with through our Services. Social functionality and features designed to simplify your use of the Services with others vary by Service.
To respond to your requests, for example to contact you about a question you submitted to our customer service team.
We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Policy. We may share your Personal Data or other information for the following reasons;
With other members of the Pango corporate family: We may share your Personal Data with members of the Pango family of entities to, among other things, provide the Services you have requested or authorized, to manage risk, to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements and to help us manage the availability and connectivity of Pango products, Services, and communications.
With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with Services, verify your identity, assist in processing transactions, send you advertisements for our products and Services, or provide customer support.
With financial institutions: We may share your Personal Data with other financial institutions that we have partnered with to jointly create and offer a product. These financial institutions may only use this information to market and offer Pango-related products, unless you have given consent for other uses. We may also share your Personal Data to process transactions and to keep your financial information up to date.
With the other parties: We may share information about you and your account with the other parties involved in processing your transactions. This includes other Users you are sending or receiving funds from, merchants and their service providers when you use the Services to pay for goods or services. The information includes;
Personal Data and Account information necessary to facilitate the transaction;
Information to help other participants resolve disputes and detect and prevent fraud; and
Aggregated data and performance analytics to help merchants better understand Users and to help merchants enhance Users’ experiences.
With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for Pango’s business purposes or as permitted or required by law, including;
If we need to do so to comply with a law, legal process or regulations;
To comply with law enforcement, regulators, government officials, or other third parties in relation to a court order, or other legal process or requirement under the laws and regulations of jurisdictions that are applicable to Pango or one of its affiliates or when we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or to report suspected illegal activity or to investigate violations of a user agreement;
To protect the vital interests of a person;
To protect our property, Services and legal rights;
To help assess and manage risk and prevent fraud against us, our Users and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals and merchants;
To banking partners;
To support our audit, compliance, and corporate governance functions.
With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorize an account connection with a third-party account or platform.
In addition, Pango may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services. This data will not personally identify you or provide information about your use of the Sites or services. We do not share your Personal Data with third parties for their marketing purposes without your consent.
A significant benefit and innovation of Pango’s Services is that you can connect your Account with a third-party account or platform. For the purposes of this Privacy Policy, an “account connection” with such a third-party is a connection you authorize or enable between your Account and a non-Pango account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, Pango and the third-party will exchange your Personal Data and other information directly. Examples of account connections include;
Linking your Account to a social media account or social messaging service;
Connecting your Account to a third-party data aggregation or financial services company, if you provide such company with your Account log-in credentials; or
Using your Account to make payments to a merchant or allowing a merchant to charge your Account.
If you choose to create an account connection, we may receive information from the third-party about you and your use of the third-party’s service. For example, if you connect your Account to a social media account, we will receive Personal Data from the social media provider via the account connection. If you connect your Account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and transactional information, such as purchases and funds transfers. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Privacy Policy.
Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your Personal Data as part of the account connection. For example, Personal Data that Pango shares with a third-party account or platform such as a social media account may in turn be shared with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.
When you visit our Sites, use our Services, or visit a third-party website for which we provide online Services, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”) to recognize you as a User and to customize your online experiences, the Services you use, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Sites and Services. Certain aspects and features of our Services and Sites are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Sites and Services may be limited or not possible.
Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not respond to DNT signals.
You have choices when it comes to the privacy practices and communications described in this Privacy Policy. Many of your choices may be explained at the time you sign up for or use a Service or in the context of your use of a Site. You may be provided with instructions and prompts within the experiences as you navigate the Services.
Choices relating to the Personal Data we collect
Personal Data: You may decline to provide Personal Data when it is requested by Pango, but certain Services or all of the Services may be unavailable to you.
Location and other device-level information: The device you use to access the Sites or services may collect information about you, including Geolocation Information and User usage data that Pango may then collect and use. For information about your ability to restrict the collection and use of such information, please use the settings available in the device.
Choices relating to our use of your Personal Data
Personalized Services offered by Pango on third-party websites and services: You may manage your preferences for Pango Services that are personalized and offered to you on third-party websites from your Account. We may also provide you with instructions and prompts on how to manage your preferences within the Service experience.
Finding and connecting with others: If available, you may manage your preferences for finding and connecting with others from your account of the Service you use.
Choices relating to account connections
If you authorize an account connection to a third-party account or platform, such as a social media account, you may be able to manage your connection preferences from your Account or the third-party account or platform. Please refer to the privacy notice that governs the third-party platform for more information on the choices you may have.
Choices relating to Cookies
You may have options available to manage your cookies preferences. For example, your browser or internet device may allow you delete, disable, or block certain cookies and other tracking technologies. You may choose to enable these options, but doing so may prevent you from using many of the core features and functions available on a Service or Site.
You may have an option regarding the use of cookies and other tracking technologies when you use a Service or visit parts of a Site. For example, you may be asked if you want the Service or Site to “remember” certain things about you, and we will use cookies and other tracking technologies to the extent that you permit them.
Choices relating to your registration and Account information
If you have an Account, you generally may review and edit Personal Data by logging in and updating the information directly or by contacting us. Contact us if you have questions about your Account information or other Personal Data.
Choices relating to communication, notices, alerts and updates from Pango:
Marketing: We may send you marketing content about our Sites, Services, products and services we jointly offer with other institutions, as well as the products and services of unaffiliated third parties and members of the Pango corporate family through various communication channels, for example, email, text, pop-ups, push notifications, and messaging applications. You may opt out of these marketing communications by following the instructions in the communications you receive. If you have an Account with us, you may also adjust your communication preferences in your Account settings. For messages sent via push notifications, you may manage your preferences in your device.
Informational and other: We will send communications to you that is required or necessary to send to Users of our Services, notifications that contain important information and other communications that you request from us. You may not opt out of receiving these communications. However, you may be able to adjust the media and format through which you receive these notices.
We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/Profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorized.
The Sites and Services are not directed to children under the age of 18. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 18.
Changes to This Privacy Policy.
We may revise this Privacy Policy from time to time to reflect changes to our business, the Sites or services, or applicable laws. The revised Privacy Policy will be effective as of the published effective date. If the revised version includes a substantial change, we will provide you with 30 days prior notice by posting notice of the change on the “Policy Update” page of our website. We also may notify Users of the change using email or other means.
Transfers of your Personal Data to other countries
Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers store and process your Personal Data in Kenya and elsewhere in the world. We will protect your information as described in this Privacy Policy if your Personal Data is transferred to other countries. By using our Sites and Services, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules than your country. We do not represent that our Sites and Services are appropriate or available in any particular jurisdiction.
You may contact us if you have general questions about our Privacy Policy and practices or questions about your Account information or Personal Data.