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Privacy Policy

This is the privacy policy for the service provided by Trustlink Payment Network (Pty) Ltd, a South African company with registration number 2019/478958/07 (collectively, the “Service Provider” or ”we” or “us”). We are committed to ensuring the protection of the privacy of all visitors (“Visitors”) to our Trustlink-InstaPay.co.za the “Website”), and mobile application (“App”), as well as all persons and merchants (“Users”) who have subscribed to any of the services we offer (“Services”).
If you have questions or complaints regarding our privacy policy or practices, please contact us by telephone on 012 470 4900 or email us at support@chips.co.za. This privacy policy (this “Policy”) describes the ways in which we collect, store, use and protect the personal information of our Visitors and Users. Throughout this Policy, 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 made anonymous so that it does not identify a specific person (also known as de-identified information).
Each User and Visitor needs to accept all the provisions in this Policy when using our website, downloading our App and if signing up for any of our Services. If you do not agree with anything in this Policy, then you may not use our Website, use our App, register and/or use any of the Services.
You may not access the Website, App or use the Services if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts. We do not have any intention of collecting or processing any personal information from individuals under 18 years of age.
By accepting this Policy, you are deemed to have read and agreed with all the provisions thereof.

1 CHANGES TO PRIVACY POLICY
We may amend this Policy at any time by posting a revised version on our Website and App. The revised version will apply to Visitors with effect from the time we post it. However, we will provide Users with prior notice of any such revision by posting notice of the change in the “Policy Updates” page of the Website or requiring you to read and accept the new terms in the App, provided that if a User is not happy with the revisions made, he/she/it shall be entitled to terminate the Services subscribed for.

2 GENERAL INFORMATION ABOUT EVERYONE
2.1 Types of Information we collect
As a Visitor or User, you agree that we may electronically collect, store and use the following of your information for the purposes set out in clause 2.3 below:
2.1.1 internet usage information, including your Internet Protocol address (“IP Address”), browsing habits, click patterns, unique user ID, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the Website or App, and the dates and times that you visit the Website, or App, paths taken, and time spent on sites and pages within the Website, or App (“Usage Details”);
2.1.2 information required by us when you register for any service (“Required Details”); and
2.1.3 additional information you may provide on a voluntary basis, such as demographic information or information related to your favourite social networking site (e.g. the site name, address and description), or information relating to your participation in competitions, promotions, surveys, and/or additional services (“Optional Details”).
2.2 How we collect such information
2.2.1 Voluntarily provided by you: Required Details and Optional Details may be submitted by you to us if you decide to use the services we provide or upload or download certain content (or products) from the Website or App, enter competitions, take advantage of promotions, respond to surveys, register and subscribe for certain additional services, or otherwise use the optional features and functionality of the Website, or App. If you do not agree to provide the Required Details we may not be able to provide services to you.
2.2.2 Automatically gathered via various technologies:
2.2.2.1 “Cookies” Information: When you access the Website or App, we may send one or more cookies (small text files containing a string of alphanumeric characters) to your device to collect certain Usage Details. The Service Provider may use both session cookies (which disappears after you close your browser) and persistent cookies (which remain after you close your browser which can be removed manually) and may be used by your browser on subsequent visits to the Website or App. Please note that the use of cookies is standard on the internet and many major websites use them. Please review your web browser “Help” file to learn more about modifying your cookie settings.
2.2.2.2 Other tracking technology: When you access the Website or App or open one of our HTML emails or message links, certain Usage Details may be automatically collected and recorded by us from your system by using different types of tracking technology.
2.2.2.3 Web Beacons: Our Website may contain electronic image requests (called a “single-pixel gif” or “web beacon” request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Web beacons are typically 1-by-1 pixel files (so small that you would likely not realize that they are there), but their presence can usually be seen within a browser by clicking on “View” and then on “Source.” We may also include web beacons in HTML-formatted newsletters that we send to opt-in subscribers in order to count how many newsletters have been read. The Service Provider web beacons do not collect, gather, monitor or share any personally identifiable information about our Users, they are just the technique we use to compile anonymous information about the Website and Service usage.
2.3 The purpose for which we collect this information
2.3.1 We use Required Details provided by you for such purposes as indicated to you at the time you agree to provide such Required Details, which includes providing you with the services.
We do not verify the accuracy of the information you provide to us, and it remains your responsibility to ensure correctness of the information supplied.
2.3.2 We may use your Required Details to:
2.3.2.1 Verify your identity;
2.3.2.2 Provide the services to you;
2.3.2.3 comply with our legal obligations;
2.3.2.4 share your Required Details with our service providers and licensors in order to provide the services to you;
2.3.2.5 administrate your account and provide customer support and correspondence; and
2.3.2.6 enforce our legal rights.
2.3.3 We may use any Optional Details provided by you for such purposes as indicated to you at the time you agree to provide such Optional Details. We do not verify the accuracy of the information you provide to us, and it remains your responsibility to ensure correctness of the information supplied.
2.3.4 We may use your Usage Details to:
2.3.4.1 automatically provide you with the latest version of the Application on your system;
2.3.4.2 remember your information so that you will not have to re-enter it during your visit or the next time you access the Website or App;
2.3.4.3 monitor aggregate Website usage metrics such as total number of visitors and pages accessed; and
2.3.4.4 track your entries, submissions, and status in any promotions or other activities in connection with your usage of the Website or App.
NOTE: Some of our business partners (e.g. advertisers or platform providers) use their own cookies and/or widgets on our Website, and the Service Provider has no access to or control over such cookies or widgets. (Widgets are interactive mini-programs that run on our Website to provide specific services from another company (e.g. displaying the news, opinions, music, etc) and these widgets may collect certain of your personal information (e.g. your email address). Cookies may also be set by the widget to enable it to function properly.) Information collected by any such cookie or widget is governed by the privacy policy of the company that created it, and not by The Service Provider. This Policy covers the use of cookies by The Service Provider only and does not cover the use of cookies or widgets by any third party advertisers or partners on the Website.

3 INFORMATION ABOUT USERS
PRIVACY POLICY
3.1 Types of information we collect about Users
If you are a User, you agree that we may also electronically collect, store and use the following of your information:
3.1.1 name and surname, identity number, student number, language, and gender (“Personal Details”);
3.1.2 mobile number and email address (“Contact Details”).
3.2 How we collect information about Users
Your Personal Details, and Contact Details are provided by you directly to us during your registration as a User and/or thereafter by your actively updating or supplementing such details in your User Account.
3.3 The purposes for which The Service Provider collects the information
The Service Provider uses the information that Users provide (or that we collect) to operate, maintain, enhance, and provide all of the features of the Services. More specifically:
3.3.1 We use your Personal Details to identify you when you access your User Account, to manage and administer your use of the Services.
3.3.2 We use your Contact Details to verify your identity and to inform you of facts relating to your use of the Services (e.g. notifications regarding major updates or content you have posted or downloaded from the Website, User service notifications, and to address copyright infringement or defamation issues) as well as to inform you, subject to obtaining your prior consent, of competitions, promotions and special offers from us and/or our partners and/or affiliates.

4 HOW WE PROTECT & STORE PERSONAL INFORMATION
4.1 We store and process the personal information of our Users and Visitors on AWS (Amazon Web Services) and Azure cloud-based servers that are protected by firewalls and data encryption. The Service Provider applications stores no data on the mobile device and communicates with the cloud servers through Secure Socket Layers (SSL’s). We authorize access to personal information only for those employees who require it to fulfil their job responsibilities.
4.2 You should not divulge your account password to anyone. The Service Provider will never ask you for your password or PIN in an unsolicited telephone call or e-mail. YOU ARE RESPONSIBLE FOR MAINTAINING THE SECRECY OF YOUR UNIQUE PASSWORD, ACCOUNT INFORMATION AND LINKED BANK ACCOUNT INFORMATION AT ALL TIMES.
4.3 If you are a legal entity and not an individual, we will liaise only with your named contact or alternative contact provided by your named contact. It is your responsibility to let us know of any changes to your named contact.

5 HOW WE SHARE PERSONAL INFORMATION WITH OTHERS
5.1 We may share your personal information with:
5.1.1 Other divisions or companies within the group of companies to which we belong which may include companies registered in countries other than South Africa, so as to provide joint content and services like registration, transactions and User support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about their products, services and communications. Members of our corporate family will only use this information to send you marketing communications if you have requested their services;
5.1.2 Service providers under contract who help with parts of our business operations (fraud prevention, marketing, 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;
5.1.3 Universities, retailers, service providers and/or financial institutions that we partner with to jointly create and offer products and services. These organisations may only use this information to market The Service Provider-related products unless you have given consent for other uses;
5.1.4 Companies that we plan to merge with or be acquired by. (Should such a combination occur, we will require that the new combined entity follow this Policy with respect to your personal information. If your personal information could be used contrary to this Policy, you will receive prior notice);
5.1.5 Law enforcement, government officials, fraud detection agencies or other third parties when –
5.1.5.1 we are compelled to do so by a subpoena, court order or similar legal procedure;
5.1.5.2 we need to do so to comply with any law; and/or
5.1.5.3 we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our User Agreement;
5.1.6 Other third parties, with your consent or direction to do so.
5.2 The Service Provider will not sell or rent any of your personal information to third parties for their marketing purposes and only shares your personal information with third parties as described in this Policy.

6 YOUR RIGHTS
6.1 It is very important that any personal information we hold about you is up to date and correct. Please inform us of any changes to your personal information.
6.2 You can review and edit any of your personal information at any time by signing into your Account and clicking the My Profile menu in any of the Application pages.
6.3 You also have the right to request access to your personal information, provided you provide us with proof of identity in a form acceptable to us. You may request that we (i) confirm, free of charge, whether or not we hold personal information about you; and (ii) provide you with record or a description of the personal information we hold about you, including information about the identity of all third parties, or categories of third parties, who have, or have had, access to the information, and we will do this within a reasonable time; at a prescribed fee; in a reasonable manner and format; and in a form that is generally understandable.
6.4 You may request that we correct or rectify your personal information: You can ask us to have inaccurate personal information we process about you fixed or changed;
6.5 You may restrict the processing of your personal information: You can require certain personal information to be marked as restricted for processing in certain circumstances, such as an objection to our processing of your personal information based on our legitimate interests;
6.6 You may object to automated decision making, including profiling, if these decisions produce a legal effect on you;
6.7 Deleting your information: You can ask us to delete or erase personal information under certain circumstances if the personal information is no longer needed for the purposes for which we collected them (subject to local data retention legal obligations);
6.7.1 You can deactivate your account at anytime by selecting the option from the menu and deleting the App from your device. You will be prompted to supply your pin number and be warned that the action is irreversible should you opt to continue.
6.7.2 Please note: Even after you have deactivated your account and/or removed the App, copies of that information may remain viewable elsewhere, to the extent it has been shared with others, it was otherwise distributed pursuant to User’s privacy settings, or it was copied or stored by other users or our partners.
Certain information may be retained for legal purposes and will only be held for so long as required by applicable law
6.7.3 You may withdraw your consent: You may withdraw your consent on condition that:
6.7.3.1 The withdrawal of your consent does not affect the processing of your personal information before the withdrawal of your consent; or
6.7.3.2 The withdrawal of your consent does not affect the processing of your personal information if the processing is in compliance with an obligation imposed by law on us; or
6.7.3.3 The withdrawal of your consent does not affect the processing of your personal information where such processing is necessary for the proper performance of a public law duty by a public body; or
6.7.3.4 The withdrawal of your consent does not affect the processing of your personal information as required to finalise the performance of a contract in which you are a party; or
6.7.3.5 The withdrawal of your consent does not affect the processing of your personal information as required to protect your legitimate interests or our own legitimate interests or the legitimate interests of a third party to whom the information is supplied.
6.8 You may raise a complaint: You may raise a compliant at any time to the Information Officer for personal information protection issues at inforeg@justice.gov.za regarding an alleged interference with the protection of personal information in accordance with this Policy.
6.9 Please submit a request if you would like to exercise any of the above rights. These rights are limited in some situations, such as where we are legally required to process your personal information, and this may limit your ability to use some of our products and services.

7 NON-PERSONAL INFORMATION
Notwithstanding anything contained in this Policy regarding your information, the following information is not regarded as personal information for purposes of this Policy:
7.1 Permanently de-identified information that does not relate and/or cannot be traced back to you specifically. We may compile, use, share and otherwise process such information as we deem fit.
7.2 Non-personal statistical information collected and compiled by us. We own and retain all rights in such information.
7.3 Information which you have provided voluntarily in an open, public environment or forum including (without limitation) any blog, chat room, albums, community, classifieds or discussion board. Because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this Policy. Since such public environments are accessible by third parties, it is possible that third parties may collect and collate and use such information for their own purposes and you should accordingly be careful when deciding to share any of your personal information in such public environments.

8 YOUR CONSENT TO THE PROCESSING OF YOUR PERSONAL INFORMATION
By accepting this Policy, you consent to our collection, storage, processing and disclosure of your personal information as described in this Policy, for so long as you are a registered User of our Services. Should you terminate your registration with us and close your Account, you consent to our retention of the information we have already collected from you for record-keeping purposes only in accordance with applicable law.

9 CHANGES TO THE PRIVACY STATEMENT
This Policy may change over time. The recent version of this Policy is published on this Website.
This version was issued on 23 August 2021.
We will notify you of any changes to this Policy by publishing this on our Website. You can print or store this Policy by downloading a copy from your browser.

10 HOW YOU CAN CONTACT US ABOUT PRIVACY RELATED QUESTIONS
If you have questions or concerns regarding this Policy, want to exercise any of your rights, or you are aware that a minor under the age of 18 has provided us with personal information, you should contact us by emailing us at support@chips.co.za.