Privacy & Policy

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1. Introduction
This privacy policy explains how we collect, use, disclose and safeguard your information when using our platforms. Instacash respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. This policy describes the types of information we may collect from you or that you may provide when you use our mobile application, our USSD channel and our practices for collecting, using, maintaining, protecting, and disclosing that information.

1.2 Regulation of data privacy and protection
As a client of Instacash, your primary data controller will be DIRECTORE TECHNOLOGIES trading as INSTACASH. We conform to the Data Protection Act, 2022.

1.3 The purpose and scope of this statement
The purpose of this statement is to inform you about how we collect, use, store, make available, disclose, update, safeguard, destroy or otherwise deal with (process) your personal information and to explain your rights relating to the privacy of your personal information and how the law protects you.
We will only transfer personal information to countries that we are satisfied will provide adequate data protection.
Protecting the privacy, confidentiality and security of your personal information is very important to us as it is critical for us to maintain your trust and act in the right way to meet your needs. We have therefore implemented internal policies and procedures to ensure that your personal information is protected.

1.4 The types of personal information we collect
Personal information is any information from which you can be identified. The personal information we may collect about you includes but is not restricted to:
• Name, age, gender, sex, and identifying numbers.
• Physical and email addresses and contact numbers.
• Online identifiers and your online behavior such as cookies and IP addresses.
• Engagements with us including use of products or services, transactions, requests,
• Queries and complaints.

1.5 Collection of personal information
We will collect personal information directly from you or by telephone or through online channels such as our website, mobile applications or electronic messaging platforms. We also collect personal information about you from other sources where lawful and reasonable, such as reputable third parties (where you have consented for your PI to be shared for either the express purpose or for any further processing) that you deal with or that the Instacash group interacts with for the purpose of conducting its business. These third parties include:
• Business partners (including partners and participating partners involved in reward programs, campaigns or other business activity, joint-venture partners, social media, and platform partners) or companies that we may acquire or that merge with us. If you are a third-party service provider, we may collect personal information about you as a data subject to ensure that the business relationship and matters relating to the agreement between you and us can be fulfilled. You warrant that, if you provide us with any personal information about other persons, such as employees, shareholders or your directors, you are authorized to share their personal information with us for purposes set out in this statement.
Providing your personal information to us is voluntary. However, it is mandatory under certain circumstances, for example when you apply for products and/or services or to comply with anti-money laundering legislation or to fulfil a legal/regulatory obligation. If you fail to provide us with your personal information when requested, we may not be able to provide the products or services to you or comply with our legal obligations.
Whenever you provide us with the personal information of third parties, you must inform them that you need to disclose their personal information to us. We will process the information in accordance with this statement.

1.6 Reasons for processing personal information
Our responsibilities to you are very important to us and we aim to provide you with personalized services to meet your needs. We may process your personal information for any of the reasons outlined in the rest of this section 1.5.

1.6.1 Contract requirements
We may need to process your personal information if we require it to conclude or perform under a contract or agreement with you for a product or service that you have applied for either with us or through our business partners with whom we have entered a partnership, collaboration, or alliance arrangement or for purposes of:
• Providing services to you that involve opening and maintaining your account, executing transactions as well as managing our risks and maintaining our overall relationship with you.
• Communicating with you regarding the services you have with us; or
• Providing you with further information that you request from us regarding the services you have with us.

1.6.2 Lawful obligations
We may need to process your personal information for the following purposes:
• To complete integrity and business conduct checks required for compliance purposes including due diligence and onboarding processes, monitoring and assurance reviews and conduct sanctions screening against any sanctions lists.
• To comply with other risk management, regulatory and legislative requirements.
• To comply with voluntary and mandatory codes of conduct.
• To detect, prevent and report theft, money laundering, terrorist financing, corruption or other potentially illegal activity, or activity that could lead to loss.
• To process and settle transactions and payments.

1.6.3 Legitimate Interest
Instacash may process your personal information in the regular management of its business and to protect the interests of the Group and its clients, shareholders, employees and other third parties, including our business partners and members of the public.
Instacash may process your personal information to:
• Maintain, monitor, improve and develop our business policies, systems and controls.
• Maintain and improve data quality.
• Design, develop and test services and solutions for clients, which may include combining sources and types of your personal information.
• Personalize and customize services and solutions, messaging and advertising;
• Respond to client enquiries and communications and to record these interactions for the purpose of analysis and improvement.
• Achieve other related purposes.

1.6.4 Consent
In addition to the reasons given above, we may process your personal information where we have your specific consent for a defined purpose. We will also seek your consent as promulgated by the Data Protection Act 2022.
We will store your personal information according to our defined retention schedules as provided by the law and thereafter delete it.

1.7 Processing personal information
Due to the integrated nature of business and to provide you with efficient access to our services, we may process your personal information in the kingdom of eSwatini and or where our third-party service providers operate. We will only transfer personal information to countries that we are satisfied will provide adequate data protection, and we ensure our third party service providers comply with the minimum data protection standards of Instacash.

1.8 The duration of retaining personal information
We retain your personal information in line with our legal and regulatory obligations and for our business and operational purposes as highlighted above. This will generally be for at least 7 years of legal retention periods for Eswatini post account deletion in terms of the AML Act.

1.9 Communicating
Besides in-person communication, we use a wide array of channels to engage with you regarding your existing products and services and to keep you updated. These include SMSes, email, phone calls, notifications sent to your mobile device and inapp notifications. We need to keep you up to date on an ongoing operational basis about your existing services and their new features especially where we are making them more secure and as we make our services more convenient for you. We may contact you through these means for research purposes or to communicate with you for marketing of new products or services as explained in greater detail below.