Privacy Policy

1. EFT GROUP PRIVACY POLICY

EFT Corporation Limited, its affiliates, subsidiaries and associated companies, its agent(s), partner(s), or other authorized representative(s) (collectively or individually “EFT Group” or “us” or “we” or “our”), is committed to maintaining the accuracy, confidentiality, and security of your personal information (defined below). The details of the EFT Group are available on www.eftcorp.com (“Website”).

This policy regulates the processing of personal information or personal data which means the personal information or personal data listed below in this policy and/or as defined in applicable law (“Personal Information”) by EFT Group and sets forth the requirements with which EFT Group undertakes to comply when processing Personal Information pursuant to undertaking its operations and fulfilling its contractual obligations in respect of data subjects and third parties in general.

By using any of our products and services (“Services”) and Websites, you consent to the collection, processing, use and disclosure of your Personal Information in accordance with this Privacy Policy. We recommend that you review this Privacy Policy carefully and retain it for future reference. If you do not agree with these terms, you are requested not to provide any Personal Information to EFT Group. You may also withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Please contact EFT Group’s Compliance Officer to withdraw your consent.

Certain Services can only be offered if you provide Personal Information to EFT Group. Consequently, if you choose not to provide EFT Group with any required Personal Information, EFT Group may not be able to offer you Services.

1.1  What Information is Collected and Processed?

Whenever you engage with EFT Group, whether it be physically or electronically, or through the use of our Services, facilities or website EFT Group will in effect be processing your Personal Information.

It may be from time to time that EFT Group has collected your Personal Information from other sources and in such instances EFT Group will inform you by virtue of any privacy notices it deploys from time to time. In the event that you have shared your Personal Information with any third parties, EFT Group will not be responsible for any loss suffered by the you and/or your, dependents, beneficiaries, customers, representatives, agents or employees (as the case may be).

When you provide EFT Group with the Personal Information of any other third party, EFT Group will process the Personal Information of such third party in line with this policy, as well as any terms and conditions or privacy notices to which this policy relates.

EFT Group undertakes to process any Personal Information in a manner which promotes the right to privacy, retains accountability and your participation.

It is specifically recorded that any data subject has the right to object to the processing of their Personal Information and EFT shall retain and store the Data Subject’s Personal Information for the purposes of dealing with such an objection or enquiry as soon and as swiftly as possible

EFT Group hereby records the types of Personal Information/personal data of data subjects it may process from time to time:

  • Full names;
  • Identity numbers;
  • Passport numbers;
  • Registration numbers;
  • Financial information, including banking account information;
  • Statutory information;
  • Physical and postal address particulars;
  • Telephone numbers;
  • Email addresses;
  • Biometrics;
  • Unique Identifiers (a distinctive code, number, or character sequence that distinguishes one entity, individual, or object from others within a specific context).

 

When this policy refers to:

  • “anonymisation” this means the processing of Personal Information in such a manner that the Personal Information can no longer be attributed to data subjects without the use of additional information which is kept secure and stored separately;
  • “applicable laws” this means laws applicable to Personal Information and includes any statute, regulation, notice, policy, directive, ruling or subordinate legislation; the common law; any binding court order, judgement or ruling; any applicable industry code, policy or standard enforceable by law; or any applicable direction, policy or order that is given by any regulator, competent authority or organ of state or statutory industry body. In general, this policy aims to deal with Personal Information as required under POPIA and GDPR as applicable;
  • “data subject” or “you”, this means an individual [and in certain jurisdictions a juristic person or entity (for example a company or a trust)] whose personal data is collected, processed, stored, or transmitted by EFT Group;
  • “GDPR” this means the General Data Protection Regulation, which is a European law that governs all collection and processing of personal data from individuals inside the European Union;
  • “personal data” (as defined in Article 4 of the GDPR) it means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly;
  • “Personal Information” this means either personal information as such term is defined in POPIA and/or personal data as such term is defined in GDPR as applicable;
  • “POPIA” this means the Protection of Personal Information Act, No 4 of 2013;
  • “process” or “processing” or “use” of Personal Information this means any operation or activity or any set of operations, whether or not by automatic means, concerning Personal Information, including the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use, dissemination by means of transmission, distribution or making available in any other form by electronic communications or other means, merging, linking, blocking, degradation, erasure or destruction. For the purposes of this definition, “process” has a corresponding meaning;
  • “Services” this means EFT Group products and/or services that it offers from time to time via any of its group companies;
1.2  Websites

When you visit (www.eftcorp.com) or the website of any EFT Group company (meaning EFT Corporation Limited and/or any affiliates, subsidiaries and associated companies of EFT Corporation Limited, collectively or individually) for information concerning their product or service offering or any other information that you may be looking for (collectively, the “Websites”), we may collect navigational Information about your visit, and/or Personal Information if you have voluntarily provided it to EFT Group. You are welcome to browse all Websites at any time anonymously and privately without revealing any Personal Information about yourself. We do not allow third parties to collect Personal Information when you access the Websites.

Certain web browsers may provide an option by which you may have the browser inform website or internet services you visit that you do not wish to have Personal Information about your activities tracked by cookies or other persistent identifiers across time and across third-party Internet websites, online or cloud computing services, online applications, or mobile applications. These are commonly called “do not track” or “DNT” signals. The Websites and Services do not respond to DNTs. If you have enabled DNT in your web browser, some parts of our Websites may not display properly, and this may affect your browsing experience.

1.3  Phone Calls

Personal Information may be collected on any call to our offices for the purposes of verifying the security of your account or addressing any customer service inquiry you may have. For purposes of maintaining quality service, calls to any of our customer service lines may also be recorded.

1.4  Mobile and Web Applications (“Apps”)

To ensure our Apps function as intended, Personal Information is collected and stored within the Apps you have registered to use. Moreover, non-personally identifiable Navigational Information and other non-personally identifiable usage details, such as how often the App is used, the events that occur within the App, aggregated usage, and performance data is collected to ensure the proper functionality and ongoing performance of the Apps.

1.5  Personal Information

Most of the Personal Information we collect comes to us directly from you, and only with your consent to the extent this is necessary. We may collect Personal Information from you in person, over the telephone or by corresponding with you via mail, facsimile, our kiosks, the internet, or from referrals by third parties such as your financial institution. Personal Information may include name, address, e-mail address, occupation, date of birth, any information relating to an identified or identifiable natural person, business information, other information about yourself or your business, and transaction details.

1.6  Navigational Information

This is information about your computer and how you interact with our Websites which may include your IP address, geographical location, web browser, referral source, length of visit, and viewed pages.

1.7  Anonymous/Non-Personal Information

EFT Group also collects anonymous/non-personal information. Anonymous/non-personal information is information that we do not associate with or trace back to a specific individual or business entity. For example, our web servers collect some anonymous/non-personal information automatically when you visit one of our Websites. When this information is gathered electronically, it may include the pages you visited, the type of web browser you are using, the level of encryption your browser supports and your internet protocol address.

To help us better understand our markets, we may also gather information for analytical purposes by conducting customer surveys, and by extracting demographic information from existing files.

 

2. HOW YOUR INFORMATION IS USED

2.1  Personal Information

EFT Group use your Personal Information to communicate with you and to effectively provide you with the Services. This includes using your information to establish and ensure the proper functioning of online accounts for Services through our Websites and Apps, responding to your requests, communicating with you about our Services (including the Websites), including communications for promotional and marketing purpose. Additionally, we use your Personal Information to improve any of our Services and/or to create new products or services.  EFT Group may also process your Personal Information in order to manage and administer its business, foster a legally compliant workplace environment, as well as safeguard the Personal Information relating to any data subjects which it in fact holds and in general to comply with applicable laws. We may also send you information about other Services in which we believe you may be interested Additionally, if you are an EFT Group  merchant client, we will keep you informed about your merchant account activities, send you important notices, and respond to any special needs or enquiries you may have. Any person providing Personal Information to EFT Group may also be required to confirm that they are a competent person (a competent person means anyone who is legally competent to consent to any action or decision being taken by any matter concerning a child, for example a parent or legal guardian) and that they have authority to give the requisite consent to enable EFT Group  to process such Personal Information.

In addition to the above we process your Personal Information in order to:

  • to transfer Personal Information to third party service providers and well as other EFT Group companies so as to enable EFT Group and its group companies to deliver its Services to its customer(s);
  • help EFT Group identify you when you engage with us;
  • allocate to, you, customers and data subjects unique identifiers for the purpose of securely storing, retaining and recalling their Personal Information from time to time;
  • maintain records of data subjects and specifically customer records;
  • maintain third party records;
  • monitor access, secure and manage any facilities owned or operated by EFT Group;
  • carry out analysis and customer profiling;

We only use Personal Information for the purposes that we have disclosed to you. If for any reason your information is required to fulfil a different purpose, we will obtain your consent before we proceed, to the extent necessary.

From time-to-time EFT Group may process Personal Information by making use of automated means (without deploying any human intervention in the decision-making process) to make decisions about the data subject or their application or any use of or access to our products or services. In this instance it is specifically recorded that the data subject may object to or query the outcomes of such a decision.

2.2  Merchant Customers

In particular, if you are an EFT Group merchant customer, our merchant agreement with you, inter alia, authorizes us to use and disclose the Personal Information that you provide to us to:

  • respond to any application for our Services;
  • provide our Services to you, including to:
  • provide you transaction details, reporting, and receipts;
  • determine your financial situation by collecting credit and related financial information from our affiliates, strategic partners, credit agencies, other financial institutions and from references provided by you;
  • facilitate the provision of the Services by sharing your information including Personal Information with our third-party service providers, credit and debit card issuers, credit and debit card associations, credit agencies, banking institutions and similar parties connected to credit or debit card services;
  • investigate potentially fraudulent or questionable activities regarding your merchant account(s) or the use of our services;
  • use for reporting purposes under credit or debit card association rules or regulations and to credit and debit card issuers, financial institutions or other credit or debit card related entities;
  • offer you related products and services that might benefit you; and
  • provide billing and statement services.
  • in the course of an actual or potential sale, reorganization, consolidation, merger or amalgamation of our business.
2.3  Apps and Website Users

If you are an individual who is using our other Services, we may use and disclose Personal Information to provide the Services that have been requested, as well as in the following ways:

  • to facilitate the provision of our Services by sharing the Personal Information with our third-party service providers, EFT Group companies, merchants you have transacted with, and similar parties connected to the Services;
  • to offer related products and services that might benefit you;
  • improve and/or personalize your experience with our Apps and Websites;
  • provide you transaction details, reporting, and receipts;
  • to assist with any service inquiries you may have;
  • determining your financial situation by collecting credit and related financial information from our affiliates, strategic partners, credit agencies, other financial institutions and from references provided by you; and
  • in the course of an actual or potential sale, reorganization, consolidation, merger or amalgamation of our business.
2.4  Navigational Information

We may use navigational information to operate and improve the overall experience you have with our Apps and Websites. We may also use navigational information in combination with Personal Information to help cater our offerings to your specific needs.

2.5  Anonymous/Non-Personal Information

At times, we may anonymize your Personal Information for statistical and/or analytical purposes to better improve our offerings and develop additional services that may be of benefit to our customers. We also use such information to report to our investors and for investment related purposes subject to strict obligations of anonymity. The anonymous/non-personal information gathered from the Apps and our Websites is also used primarily for technical, research and analytical purposes like evaluating the various sections of the Websites. This information does not include any Personal Information and it is only retained until its intended purpose is fulfilled. It is our goal to continuously improve our service offerings to you. Therefore, we use anonymous/non-personal information collected from surveys, from public archives and by extracting information from existing files to better understand our customers’ interests, priorities, and satisfaction levels. Anonymous/Non-Personal Information may be used occasionally for security investigations.

2.6  When Information May be Disclosed to Outside Parties

We are obliged to keep your Personal Information confidential except when authorized by you, when required by law and/or when permitted by law.

2.7  Third-Party Service Providers

At EFT Group, we sometimes contract third parties to perform specialized services such as establishing an online gateway for information transfer to our merchants, terminal delivery and repair, and shipping and fulfilment services. Our trusted third-party service providers may at times be responsible for processing and handling some of the information we receive from you.

When we contract with these third parties, they are given only the information necessary to perform those services. Additionally, they are prohibited from storing, analysing or using that information for purposes other than to carry out the service they have been contracted to provide, unless otherwise authorized by you to the extent necessary. Furthermore, as part of our agreements, our suppliers and their employees and representatives are required to protect your information in a manner that is consistent with the privacy policies and practices that we have established.

2.8  Communications and Marketing

If you have not opted out of receiving promotional emails, newsletters and other materials from EFT Group, we may also use your Personal Information to promote and market our Services and to communicate special offers and promotions to you (including special offers and promotions sent on behalf of us through third-party providers). We may disclose your name and contact information (address and/or e-mail address) to these third parties so that they can send you special offers and promotions directly. You may unsubscribe from these emails at any time. EFT Group does not share or sell its customer lists to any third parties for marketing or promotional purposes.

To help EFT Group make e-mails of more interest to you, and for tracking purposes, EFT Group may receive a confirmation when an e-mail is delivered to you and/or you open an e-mail from us, if your computer supports such capabilities.

2.9  Cookies

EFT Group may, from time to time, use standard technology called “cookies” on its Apps and Websites. Cookies are small data files that are downloaded onto your computer or mobile device when you visit a particular web site. EFT Group uses Cookies to understand your browsing preferences based on previous or current site activity, which enables us to provide improved Services to our customers. We also use cookies to help us compile aggregate Navigational Data to improve the user experience of our Websites. You can disable cookies by turning them off in your browser; however, some areas of our Apps or Websites may not function properly if you do so.

2.10 Links to Third-Party Websites

EFT Group’s Websites may, from time to time, offer links to third-party websites. These websites may also collect your Personal Information, including information generated through the use of cookies. EFT Group is not responsible for how such third-party websites collect, use or disclose your Personal Information.

2.11  When Required by Law

The type of Personal Information we are legally required to disclose may relate to criminal investigations or government tax or other regulatory or authority reporting requirements. In some instances, such as a legal proceeding or court order, we may also be required to disclose certain Personal Information to authorities. Only the Personal Information specifically requested is disclosed and we take precautions to satisfy ourselves that the authorities that are making the request have legitimate grounds to do so.

2.12 When Permitted by Law

There are some situations where we are legally permitted to disclose Personal Information such as employing reasonable and legal methods to enforce our rights under our agreements, to collect a delinquent account or investigate suspicion of illegal activities.

 

3. SHARING YOUR INFORMATION

3.1  Our Employees and Contractors

In the course of daily operations, access to private, sensitive and confidential information is restricted to authorized employees and contractors who have a legitimate business purpose and reason for accessing it. For example, when you call us, our designated employees will access your information to verify who you are and to assist you in fulfilling your requests.

As a condition of their employment or contract agreement, all employees and contractors of EFT Group are informed about the importance of privacy and are required to abide by the privacy standards we have established. They are also required to work within the principles of ethical behaviour and must follow all applicable laws and regulations.

Unauthorized access to and/or disclosure of customer information by an employee of EFT Group  s strictly prohibited. All employees and contractors are expected to maintain the confidentiality of customer information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.

3.2  How EFT Group safeguards your Information

We use state-of-the-art technologies and maintain current security standards to ensure that your Personal Information is protected against unauthorized access, disclosure, inappropriate alteration or misuse. All safety and security measures are also appropriate to the sensitivity level of your information.

3.2.1 Customer Files

Electronic customer files are kept in a highly secured environment with restricted access. Paper-based files are stored in locked filing cabinets. Access is also restricted.

3.2.2 Online Security

We manage our server environment appropriately and our firewall infrastructure is strictly adhered to. Our security practices are reviewed on a regular basis and we routinely employ current technologies to ensure that the confidentiality and privacy of your information is not compromised.

Our Websites and Apps use Secure Socket Layer (SSL) implementation with a PCI compliant cipher. SSL is the industry standard tool for protecting and maintaining the security of message transmissions over the Internet. When you access your accounts or send information from secured sites, encryption will scramble your data into an unreadable format to inhibit unauthorized access by others.

To safeguard against unauthorized access to your accounts, you may be required to “sign-in” using a user id and a password to certain secured areas of Apps and Websites. Both user id and password are encrypted when sent over the Internet. If you are unable to provide the correct password, you will not be able to access these sections.

When you call our customer service centre you will be required to verify your identity by providing some personally identifying information.

Personal Information will only be retained by EFT Group for as long as necessary to fulfil the legitimate purposes for which that Personal Information was collected in the first place and/or as permitted or required in terms of applicable law.

3.2.3 General on Securing Your Personal Information

EFT Group will always implement appropriate, reasonable, physical, organisational, contractual and technological security measures to secure the integrity and confidentiality of Personal Information, including measures to protect against the loss or theft, unauthorised access, disclosure, copying, use or modification of Personal Information/Personal Data in compliance with Applicable Laws.

In further compliance with applicable laws, EFT Group will take steps to notify the relevant regulator(s) and/or any affected data subjects in the event of a security breach and will provide such notification as soon as reasonably possible after becoming aware of any such breach.

Notwithstanding any other provisions of this policy, it should be acknowledged that the transmission of Personal Information, whether it be physically in person, via the internet or any other digital data transferring technology, is not completely secure. Whilst EFT Group has taken appropriate, reasonable measures to secure the integrity and confidentiality of the Personal Information which it processes, in order to guard against the loss of, damage to or unauthorized destruction of Personal Information and unlawful access to or processing of Personal Information, EFT Group in no way guarantees that its security system(s) are 100% secure or error-free. Therefore, EFT Group does not guarantee the security or accuracy of such information (whether it be Personal Information which it collects from any data subject or otherwise).

Any transmission of Personal Information will be solely at the own risk of a data subject. Once EFT Group has received the Personal Information/Personal Data, it will deploy and use strict procedures and security features to try to prevent unauthorised access to it. EFT Group reiterates that it restricts access to Personal Information to third Parties who have a legitimate operational reason for having access to such Personal Information.

EFT Group shall not be held responsible and by accepting any terms and conditions to which this policy relates, you agree to indemnify and hold EFT Group harmless for any security breaches which may potentially expose the Personal Information in EFT Group possession to unauthorized access and or the unlawful processing of such Personal Information/Personal Data by any third-party.

3.3  Cross Border Transfer of Personal Information

EFT Group may, under certain circumstances, transfer Personal Information to a jurisdiction outside of the jurisdiction where you are located or where the Personal Information originated in order to achieve the purpose(s) for which the Personal Information was collected and processed, including for processing and storage by third-party service providers. If it is required, EFT Group will obtain your consent to transfer the Personal Information to such foreign jurisdiction/s.

You should also take note that, where the Personal Information is transferred to a foreign jurisdiction, the processing of Personal Information in the foreign jurisdiction may be subject to the laws of that foreign jurisdiction.

3.4  Accessing and Amending Your Information

At EFT Group, decisions are made based on the information we have. Therefore, it is important that your Personal Information is accurate, updated and complete. As a customer, you have the right to access, verify and amend the information held in your personal and financial files. For privacy-related matters, you may access and verify any of your information by contacting EFT Group Compliance Officer for the relevant EFT Group company, in writing:

By Email:

privacy@eftcorp.com

By Mail:

EFT Group – 6 St Denis Street, 1st Floor River Court, Port Louis, 1114-04, Mauritius

Before EFT Group can provide you with any information, correct any inaccuracies, or respond to any complaints we may ask you to verify your identity and to provide other details to help us to respond to your request. We will endeavour to respond within 30 days of receiving your request or complaint. If you have questions or concerns regarding this Privacy Policy and/or EFT Group’s privacy practices, please contact the EFT Group Compliance Officer. EFT Group will investigate all complaints received in writing and will attempt to resolve all complaints to customers’ satisfaction.

3.5  Amending Your Information

To help us keep your Personal Information up-to-date, we encourage you to amend inaccuracies and make corrections as often as necessary. Despite our efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file(s), please contact the EFT Group Compliance Officer, in writing, so we can make the proper changes. Where appropriate, we will communicate these changes to other parties who may have unintentionally received incorrect information from us. In each case, you will be required to verify your identity by providing some personally identifying information.

3.6  Updating this Privacy Policy

Any changes to our privacy policy and information handling practices will be acknowledged in this privacy policy in a timely manner. We may add, modify or remove portions of this policy when we feel it is appropriate to do so. EFT Group will not reduce customers’ rights under this Privacy Policy without their express written consent. You may determine when this policy was last updated by referring to the modification date found at the bottom of this privacy policy.

 

4. DATA SUBJECT ACCESS REQUEST

All enquiries and/or requests for access to information received from any source (i.e. customers, data subjects, persons, interest groups, interested parties, government, non-governmental organisations s and/ or regulators) for access to information must be directed within 48 hours to the EFT Group Compliance Officer. Further enquiries in terms of this policy as well as requests for information as defined above must be directed to privacy@eftcorp.com.

The EFT Group Compliance Officer will scrutinize the access request for completeness as well as register receipt thereof and direct the requester accordingly regarding the process and fees which may have application to the request…

The decision and discretion in granting the requester access to the information sought rests with the EFT Group Compliance Officer.

The outcome of the request must be confirmed to the requester by the EFT Group Compliance Officer in 30 calendar days from the time the request was received by EFT Group, provided that all information required from the requester is furnished to EFT Group Compliance Officer. Should further information be required from the requester this 30-day period will run from the date upon which all requested information has been provided. No request may be released to a requester of information without full and proper payment of the applicable fees.

 

5. COMPLAINTS TO THE INFORMATION REGULATOR

If you are of the view or belief that EFT Group has Processed your Personal Information in a manner or for a purpose which is contrary to the provisions of this policy, you must first attempt to resolve the matter directly with EFT Group, failing which  you or the third party shall have the right to lodge a complaint with the applicable information regulator in the jurisdiction where you are located or where the Personal Information originated.

 

6. CHANGES TO THIS POLICY

You are advised to review this policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

EFT Group Compliance Officer:

Glenda Shafee, Head of Compliance

gshafee@eftcorp.com

+27 83 320 8349