"Personal Information" is personally identifiable information, such as your name, phone number, address, e-mail address, social insurance number, government issued identification such as driver’s licenses or passports, credit card information, birth date and gender. At the time of collection, we will clearly identify the information being collected and the purposes for which it will be used. It is always your choice whether or not to provide Personal Information but if you choose not to provide certain requested Personal Information, in some instances you may not be able to register to use the Website or Services or be able to access and use the Website or Services at all. In other instances, your choice not to provide certain other Personal Information may mean that you will not be able to use certain features of the Website or Services. We may collect Personal Information in respect of the Website and Services through registration processes, identification and authentication processes, communications with you, information downloads, service purchases, user support and surveys.
"Non-Personal Information" is information of an anonymous nature, such as an Internet Protocol Address (IP Address) that has been stripped of personal information, the domain used to access the Website, and the type and version of browser or operating system being used by visitors to the website. Aggregate and anonymized information, such as demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors, number of users of the Service, the number of users who download the mobile application, de-identified statistics about transactions performed using the services including the number of peer-to-peer transactions, what pages of the Website users access or visit, and average time spent on the Website is not considered Personal Information. Similarly, business contact information such as the name, title, business address, or telephone number of a business or professional person or an employee of an organization is not considered Personal Information.
Use of Information: We collect information for the following purposes:
- Registration, Identification, Authentication: In order to use our Services you must provide certain Personal Information in order to register for the Services and to permit us to verify your identity before you can use the Services. The exact type of Personal Information that we require will depend on the KYC/AML and regulatory requirements of each user’s jurisdiction of residence but may include, without limitation, some or all of the following information: your phone number, name, bank account information, residential address, social insurance or social security number, driver’s license and/or password, and any other information that is required by law or regulation to comply with AML standards. In general, none of your account registration information will be shared with any other users of the Website or our Services, however, we will use your Personal Information to verify and authenticate your information in accordance with the AML laws, rules, and regulations in your jurisdiction of residence. These verification processes involve checking your Personal Information against a variety of national and international AML watch lists and sanctions lists.
- eTopUp Service. If you use our eTopUp account recharging service in addition to any other information required during the registration, identification and authentication processes (as described in the “Registration, Identification and Authentication” section above). If you are paying for eTopUp services by credit card, you will also be required to provide credit card information to the merchant whose products or services you are buying/topping up. For example, if you are topping up mobile phone minutes, you mobile phone service provider may require your credit card information so that your account can be charged automatically when you purchase new mobile minutes. Your credit card information is stored by the merchant whose services you are purchasing. Telepin does not collect, store or use your credit card information.
- Mobile Financial Services. If you use our mobile financial services, including the mWallet, you may be required to provide us with your bank account information. We will use your account information to set up your account with us and to provide the Services, including money transfer and bill payment services, however all your funds will be held by your financial institution, not by Telepin.
- Mobile Application. If you live in a country where we offer the Telepin mobile application, and you have downloaded the mobile application, you will be required to register for an account. In addition to any of the information we may collect in the registration and authentication processes, as described in the “Registration, Identification, Authentication” section above, we will also collect the number from your SIM card, the mobile device serial number, the IMEI number from the mobile device (which enables us to determine certain device information, including country of origin, manufacturer, and model number) and your location information.
- Marketing Communications: If you opt-in to receive marketing communications from us, we will keep you up to date on our products and services. You may withdraw your consent to receiving marketing communications from us at any time by following the opt-out instructions in each communication, or by contacting our marketing department at firstname.lastname@example.org.
- Statistics: We also use third party tools to collect statistics about use of the Services purchased through the Website, App and the use of our other Services. This information will be kept confidential, however, aggregate statistics that do not personally identify an individual will be kept by us and such aggregate statistics may be made available to other members or third parties.
From time to time we may employ third parties to help us improve the Website and/or the Services. These third parties may have limited access to databases of user information solely for the purpose of helping us to improve the Website and/or the Services and they will be subject to contractual restrictions prohibiting them from using the information about our members for any other purpose.
Important Exceptions: We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Website members, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.
Security: The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you. For example, we scramble the Personal Information that you provide to us when it is stored on our servers.
You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your account information or your password for the Services to third parties.
Access and Accuracy: You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant information available to you such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.
Contact Us: You can help by keeping us informed of any changes such as a change of address or telephone number. If you would like to access your information, if you have any questions, comments or suggestions of if you find any errors in our information about you, please contact us at: email@example.com.
Last Updated: November 21, 2016.