QR Pay Africa - Privacy Policy

Privacy Policy

Privacy

Statement

LAST UPDATED September 12, 2023

OUR COMMITMENT TO PRIVACY

QR Pay Africa, knows that you care about how your personal information is used and disclosed, and we take your privacy seriously. Our primary goal is to provide you with exceptional service, and we understand that you may have questions or concerns regarding your personal information and how it will be used. To make this Privacy Statement easy to find, we make it available from the home page of the QR Pay Africa website at qrpayafrica.com (the "website") and through our mobile applications. You may also email us at privacy@qrpayafrica.com with any privacy-related questions you have.

APPLICABILITY OF PRIVACY STATEMENT

This Privacy Statement applies to all information we collect through our Services from current and former QR Pay Africa users. “Services” means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by in connection with a QR Pay Africa account. When you are no longer our customer, we continue to disclose your information as described in this Statement. This Statement only applies to the Services and does not apply to the practices of any other service. QR Pay Africa is always improving. As the Services evolve we may occasionally update this Privacy Statement to reflect changes to our business, Services, or applicable laws. If the revised version requires notice in accordance with applicable law, we will provide you with 30 days prior notice by posting notice of the change on the "Privacy Policy" page of our website and mobile apps, otherwise the revised Privacy Statement will be effective as of the published effective date. Throughout this Privacy Statement, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific person. This Privacy Statement also applies to all information we collect from non-QR Pay Africa users who receive a payment from other QR Pay Africa users through QR Code (the “Recipient”). The QR code enables customers, with an eligible QR Pay Africa account, to send and receive money to and from QR Pay Africa.

THE INFORMATION WE COLLECT

When you visit the website or use one of our mobile applications or other Services, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed on our website. We also may collect Geolocation Information (defined below). If you do not agree to our collection of this information, you may not be able to use our Service. If you open a QR Pay Africa account, we collect the following information from you:

Account Information - text-enabled cellular/wireless telephone number, and other similar information.
Identification Information - your name, street address, email address, date of birth, ID number, and ID photo (or other governmental issued verification numbers).
Device Information - information about you: (a) from your mobile device or computer such as your device type, machine or mobile device identification number, Geolocation Information, time zone, language setting, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes. For fraud prevention purposes, we also may link your machine ID with the machines of others who use your same payment cards.
Geolocation Information - information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. We will collect this data for fraud and risk purposes. In addition, some of our Services may ask you for permission to disclose your current location within your device settings to enhance our Services. If you do not agree to our collection of Geolocation Information, our Services may not function properly when you try to use them. For information about your ability to restrict the collection and use of Geolocation Information to enhance our Services, please refer to the settings available in your device.
Financial Information – Mpesa number, bank account and routing numbers and credit cards linked to your QR Pay Africa account. QR Pay Africa does not disclose financial information with third party social networking services such as those listed in the prior bullet.
Biometric Information - when you consent in the user experience, we collect face scans to authenticate your account and manage fraud and risk.
Audio, electronic, visual or similar information - Call recordings when you talk to customer service or sales.
Professional or employment information – including business information, contact emails, phone numbers and taxpayer ID numbers/KRA pin.
Information you provide when you contact us – your response to surveys, recorded conversations, chat conversations with us, email correspondence with us, account status, repayment history, information about others if you choose to share it with us.

We may also collect the above data from other third parties, including service providers, internet service providers, partners and merchants, credit reporting agencies, government entities, data brokers, data analytics providers, advertising networks, card networks and financial institutions. In particular, for virtual cards we will receive the Recipient’s name and payment information from Visa and third-party Visa participating digital wallets for the purpose of processing and matching virtual card payment transactions between participating digital wallets and QR Pay Africa. We are committed to providing a safe, secure and all-around great service. Therefore, before permitting you to use the Services, we may require additional information from you we can use to verify your identity, address or other information in order to comply with law or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention and similar services. When you are using the Services, we collect information about your account transactions and we may collect Geolocation Information and/or information about your computer or your operating systems or other access device for fraud prevention and other similar purposes. Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team, store results when you respond to a survey.

INFORMATION FROM CHILDREN

The Services are not directed to children under the age of 18. If we obtain actual knowledge that we have collected personal information 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.

Device Information: Information about your mobile device or computer such as your device type and IP address.

Internet or network activity: Interactions with our Services, Information about response time for web pages, download errors, date and time when you used your account, statistics regarding how pages are loaded or viewed, and other usage information.

Why do we collect your data? To provide our Services: We only collect data from all users that is necessary to enable you to send or receive money.

To manage and improve our Services: We collect data to conduct customer analysis, provide our Services, and to support internal operations, for example troubleshooting, data analysis, testing, research, and statistical purposes.

Do we disclose your data? We may need to disclose data to other parties. Disclose means that other people may see your information. For example, we may disclose the name you have chosen to display to other users when you make a payment to them. Your data is disclosed with the Account Holder: the Account Holder will be able to monitor and access your activities and manage your user and privacy settings. We disclose your data with Cooperative Bank, and Flutterwave in order to provide you with the Virtual Card services. We may also disclose data with service providers that help us with our internal operations and analysis at our direction, such as processing payments, ensuring compliance, audits, corporate governance, communications, IT development, and maintenance. We may disclose your information or data with other parties. Depending on the settings an Account Holder chooses, your information or data might be seen by your friends, friends of the other party to the transaction or the public. We may also disclose your data with third parties if there is a legal obligation to do so.

HOW WE USE COOKIES

When you visit or use our Services, or visit a third-party website for which we provide online services, we and certain business partners and vendors may use cookies and other tracking technologies (collectively, "Cookies"). We use Cookies to recognize you as a customer; customize Services, other content and advertising, measure the effectiveness of promotions, perform a wide range of analytics, mitigate risk and prevent potential fraud, and to promote trust and safety across our Services. Certain Services are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of certain Services may be limited or not possible. Do Not Track: 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. Please review our Statement on Cookies and Tracking Technologies to learn more about how we use Cookies.

HOW WE PROTECT & STORE PERSONAL INFORMATION

We store and process your personal information using third party servers located in data centers in the United States. This information is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state laws and regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities. We strive to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal information as well, including never sharing your QR Pay Africa password with anyone. If QR Pay Africa learns of a systems security breach, we may attempt to notify you electronically so you can take appropriate protective steps. By using the Services, you agree that QR Pay Africa may communicate with you electronically. QR Pay Africa may post a notice on the website or mobile applications if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please email us at privacy@qrpayafrica.com

HOW LONG WE STORE YOUR PERSONAL INFORMATION

We retain your Personal Information for as long as needed or permitted in context of the purpose for which it was collected and consistent with applicable law. The criteria used to determine our retention period is as follows:

Personal Information used for the ongoing relationship between you and QR Pay Africa is stored for the duration of the relationship plus a period of 10 years, unless we need to keep it longer, such as:
- a legal obligation or compliance with laws to which we are subject is retained consistent with the applicable law, such as under Anti-Money Laundering obligations
- litigation, investigations, audit, and compliance practices, or to protect against legal claims.

HOW WE USE THE PERSONAL INFORMATION WE COLLECT

Our primary business purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun and customized experience. We may use your personal information to:

provide the Services and customer support you request;
process transactions and match payments, including payments performed by you through virtual cards when paying and matching of such payments to participating digital wallets, and to send notices about your transactions or your network activity;
resolve disputes, collect fees, and troubleshoot problems;
prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement through the use of our risk and fraud tools which may include use of Account Information, Identification Information, Financial Information, Device Information, Social Web Information and Geolocation Information;
create an account connection between your QR Pay Africa account and a third-party account or platform;
customize, personalize, measure, and improve our services and the content and layout of our website;
send you updates about new products and services that we are offering to customers;
compare information for accuracy and verify it with third parties;
perform other duties as required by law; and
if you elect to disclose your Geolocation Information, we will use this information to enhance the security of the Services and we may use this information to provide you with location-specific options, functionality, offers, advertising, search results, or other location-specific content.

HOW WE DISCLOSE PERSONAL INFORMATION WITHIN THE QR PAY AFRICA NETWORK

To process payments on QR Pay Africa, we need to disclose some of your personal information with the person or company that you are paying or is paying you. Your contact information, date of sign-up, the number of payments you have received and other verification metrics like social graph activity may be provided to users or companies when you transact with, on, or through QR Pay Africa. We work with vendors to enable them to accept payments from you using QR Pay Africa. In doing so, a vendor may disclose information about you with us, such as your mobile phone number or QR Pay Africa username, or email address when you attempt to pay that vendor. We use this information to confirm to that vendor that you are a QR Pay Africa customer, and that the vendor should enable QR Pay Africa as a form of payment for your purchase. Regardless, we will not disclose your phone number or email or ID number to anyone you have paid or who has paid you through QR Pay Africa, except with your express permission or if we are required to do so in order to comply with a subpoena or other legal process.

HOW WE DISCLOSE PERSONAL INFORMATION WITH OTHER PARTIES

QR Pay Africa does not disclose your personal information with third parties for their promotional or marketing purposes. Some personal information is public information and may be seen by anyone on the internet, whether or not they have a QR Pay Africa account. Public information may also be seen, accessed, reshared or downloaded through QR Pay Africa's APIs or third-party services that integrate with our products.

Public information for personal profiles includes your QR Pay Africa username, profile photo, first and last name, month and year of QR Pay Africa account creation, and public transactions in which you've been involved.
Public information for business or charity profiles includes QR Pay Africa username, profile and background photos, business or charity name, business or charity description, and QR code.
Public information for business or charity profiles may be indexed by and searchable on search engines.

We may disclose your personal information with:

Our parent company, and affiliates and subsidiaries it controls, but only for purposes allowed by this document.
Companies that plans to merge with or be acquired by or, in the event of any bankruptcy, a bankruptcy estate. Should such a combination occur, we will require that the new combined entity follow this Privacy Statement with respect to your personal information. If your personal information could be used contrary to this Statement, you will receive prior notice and the opportunity to communicate preferences you may have, if applicable.
Law enforcement, government officials, or other third parties if is compelled to do so by a subpoena, court order or similar legal procedure; when it is necessary to do so to comply with law; or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the QR Pay Africa User Agreement, or as otherwise required by law.
Third party service providers who assist us in providing Services to you or who provide fraud detection or similar services on our or any vendor’s behalf.
The other QR Pay Africa user participating in the transaction and, depending on the privacy setting of each QR Pay Africa account transaction, your QR Pay Africa friends and the QR Pay Africa friends of the other user participating in the transaction, or the public, through the QR Pay Africa feed on our website and mobile application and elsewhere on the internet.
Service providers under contract who help with parts of our business operations (for example, fraud prevention, payment processing, or technology services). Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
Partners and merchants, their service providers and others involved in a transaction, for example when you use the Services to initiate online purchases, pay non-QR Pay Africa users through virtual cards or return goods, we may disclose information about you and your QR Pay Africa account with the other parties (or their service providers) involved in processing your transactions. Please note that personal information shared with partners and merchants (or their service providers) involved in a transaction is subject to the partners’ and merchants’ own privacy policy and procedures.
For our businesses and their beneficial owners, we report personal information to databases maintained by the card networks pursuant to the card scheme rules to fulfill listing and reporting obligations.
Other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform.
- For the purposes of this Privacy Statement, an "account connection" with such a third party is a connection you authorize or enable between your QR Pay Africa account and a non-QR Pay Africa account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, QR Pay Africa and the third-party will exchange your personal information and other information directly. Examples of account connections include, without limitation: linking your QR Pay Africa account to your business using our API; connecting your QR Pay Africa account to a third-party data aggregation or financial services company, if you provide such company with your QR Pay Africa account log-in credentials; or using your QR Pay Africa account to make payments to a merchant or allowing a merchant to charge your QR Pay Africa account.
- If you connect your QR Pay Africa account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. 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 QR Pay Africa account to a social media account, we will receive personal information from the social media provider via the account connection. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Privacy Statement.
- Information that we disclose 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 information as part of the account connection. For example, personal information that QR Pay Africa discloses with a third-party account or platform such as a social media account may in turn be disclosed with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.

QR Pay Africa does not send your personal information to third-party social networks unless you have specifically requested or authorized us to do so. When you broadcast information to such third-party social networks, such information is no longer under the control of QR Pay Africa and is subject to the terms of use and privacy policies of such third parties.

HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION

You can review and update your personal information in your account settings at any time by logging in to your account.

LINKS TO OTHER SERVICES OR SITES

The Services may contain links to (or allow you to link to) other third-party services or websites. QR Pay Africa does not control the information collection of third-party services or websites that can be reached through such links. We encourage our users to be aware when they are linking to a third-party service or website and to read the privacy statements of any third-party service or website that collects personally identifiable information.

HOW TO CONTACT US

If you have questions or concerns regarding this Privacy Statement, or any feedback pertaining to your privacy and the Services that you would like us to consider, please email us at privacy@qrpayafrica.com