1. WEBSITE PRIVACY STATEMENT

1.1. Your privacy is important to us.

1.2. Please read this privacy policy carefully.

1.3. By using the Centbee’s website at www.centbee.com, Centbee’s Mobile Application and/or any other related blogs, applications, websites and/or platforms owned and operated by Centbee (collectively referred to as the “Website”), you (the “User/you”) are indicating your acceptance to be bound by this Privacy Policy.

2. INTRODUCTION

2.1. Centbee (Pty) Ltd, with registration number 2017/014560/07 (“Centbee/us/we”) and duly registered in South Africa in accordance with the Companies Act of 2008, is sensitive to the personal nature of the information you provide and treats it as private and confidential by placing great importance on data security and data protection.

2.2. The purpose of this Privacy Policy is to describes how Centbee collects, uses, and discloses your personal information.

2.3. It also informs you of your rights regarding the use of, your access to, erasure of, and correction of your Personal Information as provided.

3. OVERVIEW AND ROLE OF CENTBEE

3.1. It is important for you to review this Privacy Policy as it applies to all Centbee’s Website, including the Mobile Application and/or any other related blogs, applications, websites and/or platforms owned and operated by Centbee .

3.2. Centbee takes the protection of and privacy of your personal information very seriously and will collect, use and disclose your information only in accordance with the terms of this Privacy Policy or otherwise with your consent or in compliance with the law.

3.3. In order to operate and provide the Centbee Website, provide you with Centbee’s Services and reduce the risk of fraud, we must ask you to provide us with information about yourself.

3.4. This Privacy Policy describes the information we collect and how we use and disclose that information.

3.5. We will not sell or rent your personal information to third parties for their marketing purposes.

3.6. However, in order for Centbee to offer our Website and Services to our users, enhance the quality of our Website and Services from time to time, and protect the interests of our users, we will in limited circumstances share some of your personal information with third parties under strict restrictions, as described in more detail in this Policy.

3.7. By accepting the Privacy Policy on registration, you expressly consent to our collection, use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy.

3.8. Further, you also understand and agree that we may lawfully process your personal information due to the legitimate business needs of Centbee to operate, as well as on the basis that you have contracted with us for the use of our Services.

3.9. Centbee is the Data Controller, as defined by applicable law, and is responsible for your personal data in instances where we decide to undertake processing operations concerning your personal data.

3.10. Sometimes we also operate as a processor of personal data on behalf of a third-party data controller, where that data controller’s privacy terms will apply, but we will draw your attention to them, when applicable.

3.11. If you disagree with the terms of this Privacy Policy, please do not register on Centbee’s Mobile Application or use the Centbee Services and immediately discontinue your use of the Website.

4. SCOPE AND APPLICATION
4.1. This Privacy Policy applies to Centbee’s website at www.centbee.com, Centbee’s Mobile Application and/or any other related blogs, applications, websites and/or platforms owned and operated by Centbee (the “Website”).

4.2. This Privacy Policy version was last updated on 116 July 2022 and historic versions are archived and can be obtained by contacting Centbee.

4.3. Users under the age of 18 or without capacity:

4.3.1. You may use Centbee’s Website Services only if you have full capacity to act.

4.3.2. If you are under the age of 18 (eighteen) or if you are not legally permitted to enter into a binding agreement, then you may use this Website only with the involvement and supervision of your parent or legal guardian. If your parent or legal guardian supervises you and gives his/her consent, then such person agrees to be bound to this Privacy Policy as well as Centbee’s Terms and Conditions and to be liable and responsible for you and all your obligations under this Privacy Policy as well as Centbee’s Terms and Conditions

4.3.3. If you are a parent or guardian of a person who’s personal information, we process pursuant to this Privacy Policy, you warrant that you have read, understood and agree to this Privacy Policy, and hereby expressly consent to Centbee processing their personal information in accordance with this Privacy Policy.

4.3.4. You further warrant that any engagement by them with Centbee is under your direct supervision and consent.

4.3.5. If you become aware that Centbee has been provided with their personal information without your consent, you should immediately contact us, and we will delete such information from our files.

5. SPECIAL CATEGORIES OF INFORMATION

5.1. Centbee does not process Special Categories of Personal Information, including information about your race, sexual orientation, political affiliation, trade union membership, ethnic or cultural origin or religious affiliation, nor does Centbee process any of your biometric information or information concerning your health.

5.2. As such, do not provide us with such types of information for any reason.

6. CATEGORIES OF INFORMATION WE COLLECT AND PROCESS

6.1. This Privacy Policy complies with the principles contained in the following legislation:

6.1.1. the Electronic Communications and Transactions Act 25 of 2002 (“ECTA”) for the electronic collection of your personal information;

6.1.2. the Protection of Personal Information Act 4 of 2013 (“POPIA”) for how we handle your personal information as provided; and

6.1.3. where applicable, the General Data Protection Regulation (“GDPR”) on date protection and privacy in the European Union and the European Economic Area.

6.2. Types of personal information:

6.2.1. The personal information that we may collect includes information necessary for us to provide you with our services.

6.2.2. This may include all of the categories of personal information listed in POPIA, and amongst others, include at least all of the following information:

6.2.2.1. identification data and contact information (name, address, telephone number, email address, date of birth);

6.2.2.2. profile information (the information provided by you which is displayed in your Centbee Account on the Mobile Application);

6.2.2.3. electronic identification data (IP addresses, cookies);

6.2.2.4. banking and payment information for accounts linked to your Centbee account (credit card information, account number);

6.2.2.5. survey results;

6.2.2.6. information about your usage of and interaction with the Centbee software, our products, and websites including computer, platform, device and connection information, device capability, carrier network, bandwidth, statistics on page views, and traffic to and from our websites, operating system, or browser type;

6.2.2.7. copies of government-issued identification, (ID, driver’s license, passport, or other documents);

6.2.2.8. information from third parties;

6.2.2.9. products or services ordered and delivered;

6.2.2.10. correspondence between you and Centbee, including email, telephone logs or recordings, or instant message content, or messages between or to your contacts or other Centbee users when sent using the Centbee system;

6.2.2.11. BSV addresses used and transactions on those BSV addresses; and

6.2.2.12. Centbee prepaid card details and usage.

6.3. Ways to collect personal information:

6.3.1. We may collect or obtain your personal information:

6.3.1.1. when you provide it to us such as when you sign up for a Centbee account, use our products and services, or take part in customer surveys, competitions, and promotions;

6.3.1.2. when you communicate with us by email, chat, telephone, or any other means, we collect the communication and any personal data provided in it;

6.3.1.3. when you use the Centbee’s Website we collect information on your transactions and the usage of your Centbee account;

6.3.1.4. when we obtain information from third parties such as identity verification services, credit reference agencies, regulatory and enforcement agencies, and public sources.

7. TRANSACTION INFORMATION

7.1. When you register on Centbee’s Website and/or Mobile Application or otherwise intend to use any of Centbee’s Services, whether or not such Services are actually used, you agree to have entered into a business relationship with Centbee and shall therefore be classified as a User for all intents and purposes of this Privacy Policy.

7.2. When you use Centbee Services, we ask you to provide information related to that transaction, including such information as the amount of the transaction, the type of transaction and payment information.

7.3. Also, when you send money Crypto to another Centbee user, you may be asked to provide personal details of that user to complete the transaction and your details may also be passed on to us from that user.

7.4. We retain this information for each of your transactions through the Centbee Mobile Application or by the utilisation of Centbee’s Services and may add this information to your account profile to be used for future transactions that you may make with us.

7.5. We also collect the Internet address (IP address) and other identifying information about the computer or device you use to create or access your Centbee Account or use the Centbee Services, in order to help detect possible instances of unauthorized or fraudulent transactions.

8. WEBSTE TRAFFIC INFORMATION

8.1. Because of the way Internet communication standards work, when you arrive at or leave the Centbee Website, we automatically receive the web address of the site that you came from or are going to.

8.2. We also collect information on which pages of our Website you visit, IP addresses, the type of browser and operating system you use and the times you access our website.

8.3. We use this information to try to understand our customers’ preferences better and to manage the load on our servers, so as to improve the Centbee Services.
8.4. Customer Service Correspondence:

8.4.1. If you send us correspondence, we retain such information in the records of your account.

8.4.2. We will also retain customer service correspondence and other correspondence from Centbee to you.

8.4.3. We retain these records in order to keep records of our relationship, to measure and improve our customer service, and to investigate potential fraud and violations of our Terms and Conditions.

8.4.4. We retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

8.4.5. You may use our telephone number to contact us for support or assistance with our services.

8.4.6. From time to time, we may contact you by telephone for support purposes. If we correspond by telephone, we will typically request certain personal information from you, such as your name, date of birth, address, and email address, in order for us to confirm your identity.

9. NON-USER RECIPIENTS AND REQUESTS

9.1. When you either send a payment to or request payment from, an individual who is not a registered member of Centbee, we will retain the information that you submit to us for the benefit of the member who is attempting to contact the non-member, so that you can see a complete record of your transactions, including uncompleted transactions.

9.2. Although this information is retained, we will not market to the non-member in anyway at any time using this information.

10. AGGREGATE DATA

10.1. We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose.

10.2. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

11. HOW DO WE USE YOUR PERSONAL INFORMATION?

11.1. The primary purpose of collecting your personal information is to provide you with a safe, smooth, efficient, and customized experience when using our Website, Mobile Application, and/or Services and to properly perform on our contractual duties to you.

11.2. Internal use:

11.2.1. We will only process your personal information where it is necessary for us to carry out our lawful business activities.

11.2.2. In doing so, we may use your personal information:

11.2.2.1. to verify your identity in accordance with Know Your Customer (KYC), Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) requirements;

11.2.2.2. to manage and maintain your account with us;

11.2.2.3. to deliver our services, including to personalise features and content (such as services, products, and advertisements) and make suggestions for you (such as services and information you may be interested in or topics you may want to follow) on or about our services or on our Website;

11.2.2.4. to monitor how you use and interact with our Website;

11.2.2.5. to develop, test and improve our services and/or our Website, including by conducting surveys and research, and testing and troubleshooting new services and features;

11.2.2.6. to select and personalise advertisements, offers and other sponsored content that we show you;

11.2.2.7. to communicate with you. We use your personal information to communicate with you about our services and to let you know about our Policies and Terms and Conditions. We also use your information to respond to
you when you contact us;

11.2.2.8. to detect and prevent fraudulent or unauthorized use of our products and services;

11.2.2.9. to improve our search functionality and help you find contacts more easily;

11.2.2.10. to compare information for accuracy, and verify it with third parties;

11.2.2.11. for our internal purposes, to associate relationships amongst our users through such attributes as address, phone number or device information, for example where more than one Centbee account is set up under one household or last name;

11.2.2.12. to protect both your interests and Centbee’s interests, including the enforcement of our Terms and Conditions and to investigate, prevent and fight against fraud; and
11.2.2.13. for any other purpose as we are legally authorised to do and as is allowed by law.

11.2.3. Your payment card number, bank account and other financial information will never be revealed to or be visible to other Centbee users, including anyone who you have paid or who has paid you through the Centbee services or third parties that use Centbee services, except with your express permission or if we are required to do so pursuant to payment card rules, a court order or other legal
process.

Disclosure to third parties:

11.2.4. We may share your personal information with:

11.2.4.1. any person that works for us;

11.2.4.2. financial and other institutions we partner with to provide our services;

11.2.4.3. companies and organisations that provide services to us including in relation to technical infrastructure, marketing and analytics, and web and app development;

11.2.4.4. companies and organisations that assist us with identity verification, background screening and due diligence;

11.2.5. We will otherwise treat your personal data as private and confidential
and will not share it with other parties except:

11.2.5.1. where you consent to us doing so; and

11.2.5.2. where it is reasonably necessary to comply with any law, regulation, legal process, or governmental request.

11.3. International Transfers of your personal information:

11.3.1. We share your personal information within the Centbee group and third-party service providers. This may involve transferring and processing your personal information outside of South Africa.

11.3.2. Whenever we transfer your personal information out of the country, we ensure a similar degree of protection is afforded to it by ensuring that we will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information in terms of POPI .

12. USE OF COOKIES

12.1. Cookies are pieces of information our Website transfers to a user's hard drive for record-keeping purposes. Cookies make surfing the web easier for you by saving your preferences and, tracking your online habits, traffic patterns, and making sure that you do not see the same advertisement too often. The use of cookies is an industry standard.

12.2. We may place a cookie on your browser to store and sometimes track information about you.

12.3. While most browsers are initially set up to accept cookies, you can reset the data subject’s browser to refuse all cookies or indicate when a cookie is being sent. Please note that some parts of our Website will not function properly if you refuse cookies.

12.4. Centbee uses its own cookies for a variety of purposes, including to:
12.4.1. recognise you when you sign in and understand how you arrived at our Website, so we can make sure that we provide you with relevant customer content and information;

12.4.2. to recognise your time zone so that your transaction histories and other account information are accurately displayed;

12.4.3. present customised content, if, for example, your cookie was set a
long time ago, we know you are not a new user and we will not show
you content intended for new users, such as ‘how to use Centbee ’pages;

12.4.4. remember your chosen preferences, such as the language you choose to see our website in or default currencies;

12.4.5. fight against fraud;

12.4.6. inform Centbee about the version of the Centbee software client you are using so that we can provide you with new software updates and direct you to the relevant help sections;

12.4.7. enable you to access your account and account services through the Centbee software client;

12.4.8. provide internal and customer analytics and gain statistics and metrics about our Website, such as total number of visitors and page views;

12.4.9. monitor the effectiveness and performance of our advertising and marketing campaigns and carry out research in order to help us to improve our products and Website;

12.4.10. initiate security measures such as ‘time-out’ when you have not logged into your account service area for a period of time; and
12.4.11. populate your Centbee client with one of your Centbee contacts’ information, where this contact invited you to join Centbee.

13. HOW LONG IS YOUR INFORMATION RETAINED?

13.1. Centbee will retain your information for as long as is reasonably necessary to:

13.1.1. fulfill any of its intended purposes (as described in this Privacy Policy); or

13.1.2. comply with applicable legislation, regulatory requests, and relevant orders from competent courts or our regulators.

14. HOW DOES CENTBEE PROTECT YOUR INFORMATION?

14.1. Centbee is committed to handling your customer information with high standards of information security.

14.2. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

14.3. Centbee will take appropriate organizational and technical measures to protect the personal data and traffic data provided to it or collected by it with due observance of the applicable obligations and exceptions under the relevant legislation.

14.4. We encrypt all transmission of information using secure socket layer technology (SSL).

14.5. Your personal and traffic data can only be accessed by authorized employees of Centbee or its affiliates, subsidiaries, or service providers who need to have access to this data in order to be able to fulfill their given duties.

14.6. The security of your Centbee account also relies on your protection of the device security mechanism of your mobile phone (PIN pattern/biometric). Centbee representatives will never ask you for your mobile phone PIN, so any email or other communication requesting your PIN should be treated as unauthorised and suspicious and forwarded to us.

14.7. The Security of your Centbee Account, and the provision of the Services, relies on the use of a Centbee Pin PIN generated by Centbee and consists of randomly generated words or phrases. It is your responsibility to keep this Centbee Pin PIN safe and secure as you may not be able to access your Centbee account without this Centbee PinPIN. A representative will never ask you for your Centbee PIN and so any email or other communication requesting your Centbee PIN should be treated as unauthorised and suspicious and forwarded to us.

15. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

15.1. You have the right to:

15.1.1. request that we correct, destroy, or delete any of your personal information that we have processed on our Website;

15.1.2. withdraw your consent for us to process your personal information at any time. The withdrawal of your consent can only be made by you on the condition that the withdrawal of your consent:

15.1.2.1. does not affect the processing of your personal information before the withdrawal of your consent; or

15.1.2.2. that the withdrawal of your consent does not affect the processing of your personal information if the processing is in compliance with an obligation imposed on us by law; or

15.1.2.3. that 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

15.1.2.4. that the withdrawal of your consent does not affect the processing of your personal information as required by law; or

15.1.2.5. that 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

15.1.2.6. that 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;

15.1.3. object to the processing of your personal information at any time, on reasonable grounds relating to your particular situation, unless the processing is required by law.

15.1.4. You can make the objection:
15.1.4.1. if the processing of your personal information is not necessary for the proper performance of a public law duty by a public body; or

15.1.4.2. if the processing of your personal information is not necessary to pursue your legitimate interests, our legitimate interests, or the legitimate interests of a third party the information is supplied to; or

15.1.4.3. if the processing is for purposes of direct marketing other than direct marketing by means of unsolicited electronic communications and you have not given your consent for that processing.

15.1.5. not have your personal information processed for purposes of direct marketing by means of unsolicited electronic communications from third parties unknown to you;

15.1.6. submit a complaint to the Information Regulator regarding an alleged interference with the protection of personal information processed. The Information Regulator's contact details are published by the government from time to time in terms of POPIA; and

15.1.7. complain to the South African Information regulator about how we process personal data at inforeg@justice.gov.za

16. ACCESSING OR CHANGING YOUR INFORMATION

16.1. You can review the personal information as provided and make any desired changes or deletions to such information, or to the settings for your Centbee account, at any time by contacting us.

16.2. Upon request, Centbee will provide you with information about whether we hold any of your personal information.

16.3. You have a right to ask for a copy of your information and to ask us to correct any inaccuracies in your personal information or delete your personal information.

16.4. A fee may be charged depending on the work required to obtain and provide the requested access.

16.5. We will respond to your request within a reasonable time frame.

16.6. If you choose to close your Centbee account, you will need to contact Centbee to request this closure.

16.7. We will mark your account in our database as “closed,” but will keep your account information in our database for as long as reasonably necessary to comply with our legal and regulatory requirements.

16.8. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account.

16.9. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required by law.

16.10. If you wish to subscribe to our newsletter(s) or marketing communications, we will use your name and email address and/or telephone number to send communication to you.

16.11. You may choose to stop receiving our newsletter or marketing communications by following the unsubscribe instructions or you can contact us.

17. POLICY ACCOUNTABILITY

Centbee is responsible for ensuring that our day-to-day procedures comply with this Privacy Policy. If you want to exercise your right to access your information or have any questions about this policy, Centbee’s information practices, or your dealings with Centbee, you can contact us.

18. THIRD PARTY SITES
Our site includes links to other websites whose privacy practices may differ from those of Centbee . If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

19. POLICY UPDATES AND NOTIFICATIONS
All future changes to this Privacy Policy as already published on the Centbee Website at the time you register for the Services are incorporated by reference into this Privacy Policy. We may amend this Privacy Policy at any time by posting a revised version on our Website. The revised version will be effective at the time we post it. If you disagree with the terms of this Privacy Policy, you may close your account at any time.