V1.2 | 10th May 2019
This Privacy Statement describes how Centbee (Pty) Limited. (“Centbee”, “our”, “us” or “we”) collects, uses and discloses the personal information you provide to us or which is collected from you, when you engage with Centbee in any way, such as when you use the Website, our Services or contract with us. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information.
- Name or title of data representative: The Chief Executive Officer
- Email address: email@example.com
- Postal address: 3rd floor, 2 Merchant Place, Fredman Drive, Sandton 2146
- Telephone number: +27 87 094 0995
A Special Note About Children’s Information and Special Categories of Information
Users under the age of 18 (eighteen) may use the Services and provide their personal information to us, subject to their parent’s/guardian’s express supervision and consent, which they hereby provide.
If a parent or guardian becomes aware that his or her child/ward has provided us with their personal information without his or her consent, he or she should immediately contact us at firstname.lastname@example.org and we will delete such information from our files.
Further, we do 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 do we process any of your biometric information or information concerning your health. As such, do not provide us with such types of information for any reason.
OVERVIEW AND ROLE OF CENTBEE
Centbee is the Data Controller, as defined by applicable law, and is responsible for your personal data in instances where we decide the processing operations concerning your personal data. 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.
1. WHAT INFORMATION DO WE COLLECT?
Categories of Information
Centbee may gather and use information about you, including (but not limited to) information in the following categories, which is either provided by you when registering for/using the Services, or is automatically collected from you when using the Website:
- Identification data and contact information (e.g. name, address, telephone number, email address, date of birth);
- Profile information (the information provided by you which is displayed in your Centbee profile in the Centbee application);
- Electronic identification data (e.g. IP addresses, cookies);
- Banking and payment information (credit card information, account number) for accounts linked to your Centbee account;
- Survey results;
- 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;
- Bitcoin SV addresses used and transactions on those Bitcoin SV addresses;
- Copies of government-issued identification, such as driver’s license, passport or other documents such as a recent utility bill;
- Information from third parties (as discussed below);
- Products or services ordered and delivered;
- 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; and
- Centbee prepaid card details and usage.
2. REQUIRED INFORMATION FOR REGISTRATION
To open a Centbee account or use the Centbee Services, you must provide your mobile phone number. Using certain profile information, we utilize third parties to extract additional information to help verify the authenticity, and any background checks required on your account. In order to purchase Bitcoin SV into your Centbee account, you must provide additional personal information (which may include a copy of government-issued photo identification, and supporting address documentation) necessary to validate your identity for legally-required “Know Your Client” purposes, and to comply with our legal obligations such as anti-money laundering and anti-terrorist financing laws and regulations. We may also require other commercial and/or identification information if you send or receive certain high-value transactions or high overall payment volumes through the Centbee Services in order for us to comply with our anti-money laundering or other legal obligations.
3. TRANSACTION INFORMATION
4. INFORMATION ABOUT YOU FROM THIRD PARTIES
In order to protect our customers against potential fraud, we verify the information you provide with identity verification services, payment processors and/or credit reference and fraud agencies. In the course of such verification, we may receive personally identifiable information about you from such services. In particular, if you use a credit card or debit card with Centbee, we will use card authorization and fraud screening services to verify that your card information and address match the information you supplied to Centbee, and that the card has not been reported as lost or stolen. If you send or receive high overall payment volumes through the Centbee Services, in some circumstances we are required to conduct a background check on you by obtaining information about you from a credit reference or fraud agency. If you owe us money, we may conduct a credit check on you by obtaining additional information about you from a credit reference or fraud agency, to the extent permitted by law. Centbee, at its sole discretion, reserves the right to periodically retrieve and review a consumer credit report supplied by such credit reference or fraud agency for any account, and reserves the right to close an account based on information obtained during this credit review process.
5. ADDITIONAL VERIFICATION
If we cannot verify the information that you provide, we may ask you to send us additional information (such as your driving license, credit card statement and/or a recent utility bill, or other information linking you to the applicable address), or to answer additional questions online to help verify your information. If you want to change your details or you have recently moved, we will need additional documentation from you.
6. WEBSITE TRAFFIC INFORMATION
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. 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. 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.
Customer Service Correspondence: If you send us correspondence, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from Centbee to you. 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 of Service. We retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. You may use our telephone number to contact us for support or assistance with our services. 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 date of birth, address and email address, in order for us to confirm your identity.
7. NON-USER RECIPIENTS AND REQUEST
When a Centbee user either sends a payment to, or requests a payment from, an individual who is not a registered member of Centbee, we will retain the information that the member submits to us for the benefit of the member who is attempting to contact the non-member, so that the member can see a complete record of his or her transactions, including uncompleted transactions. Although this information is retained, we will not market to the non-member in any way at any time using this information.
8. PERSONAL DATA OF FRIENDS
You may be interested in inviting your friends or contacts to join Centbee. In the event you wish to use Centbee’s referral service, you will provide contact information about these friends or contacts. This information will only be used for the purposes of automatically generating a message to these potential Centbee users. By entering your friend’s contact details you are confirming that your friend has consented to the supply of their details and that you consent to Centbee identifying you as the person who has made the referral in the invitation sent to your friend and including your name and details in such invitation. Further, you hereby indemnify Centbee against any liability it may accrue by virtue of your provision of a third-party’s information to us. You may request to remove this third-party information by emailing us at email@example.com.
9. AGGREGATE DATA
9. HOW DO WE USE AND DISCLOSE YOUR INFORMATION AND FOR WHAT PURPOSES?
Our primary purpose in collecting information is to provide you with a safe, smooth, efficient, and customized experience when using our Services and to properly perform on our contractual duties with you.
Internal Uses: We collect, store and process your personal information on servers located in various jurisdictions where Centbee facilities are located. Centbee collects and uses, or has third party service providers acting on Cent bee’s behalf collecting and using, personal data relating to you, as permitted or necessary for the following purposes, which are all done on the lawful grounds of your express consent, our legitimate business interests, and our contractual engagement with you:
- Provide the Centbee Services and members services you request including without limitation processing transactions and communicating with you about your transactions;
- Verify your identity and the information provided to us;
- Resolve disputes, collect fees, and troubleshoot problems;
- Inform you about service updates and faults;
- Investigate and prevent potentially prohibited or illegal activities, and enforce our Terms of Service;
- Customise, measure, and improve our services and the content and layout of our website;
- Deliver targeted marketing and advertising, service updates, and promotional offers based on the communications preferences you have defined for your Centbee account;
- To improve our search functionality and help you find contacts more easily;
- Compare information for accuracy, and verify it with third parties;
- 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;
- Protect your and Centbee’s interests, including in particular to enforce our Terms of Service and investigate, prevent and fight against fraud; and
- Comply with legal and regulatory requirements,
Disclosure to Other Centbee Customers. If you are a registered Centbee user, your name will be visible to other Centbee users who search for you.
When registering with Centbee, we create a Bitcoin SV address for you, and store that address on our servers. Such addresses and all transactions on them are intrinsically public-domain, and by processing Bitcoin SV transactions on these addresses you consent to that information becoming public. Centbee will never disclose your cryptographic keys or PIN associated with those addresses.
Disclosure to Third Parties: Other Than Centbee Users Centbee will not sell or rent any of your personal information to third parties for their marketing purposes, and will only disclose this information in the limited circumstances and for the purposes described in this Policy. In certain situations, Centbee may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements. Specifically, you consent to and direct Centbee (and third party service providers acting strictly on Centbee’s behalf) to do any and all of the following:
Disclose information including, without limitation, transaction information, account information, personal information and the contents of communications to: the police; security forces; competent governmental, intergovernmental or supranational bodies; competent agencies (other than tax related authorities), departments, regulatory authorities, self-regulatory authorities or organizations; and other third parties that we in good faith believe it is appropriate for us to cooperate with in investigations of fraud or other illegal activity or potential illegal activity, or to conduct investigations of violations of our Terms of Service (including without limitation, your funding source or credit or debit card provider). If you provide false or inaccurate information and fraud is identified, we may pass details to fraud prevention agencies and law enforcement agencies may access and use that information. We and other organizations may also access and use this information (including information from other countries) to prevent fraud and money laundering. ;
- Disclose information in response to the requirements of the payment card associations or a civil or criminal legal process.
- Disclose necessary information to the payment processors, banks, payment card associations, or other service providers necessary to provide the Centbee Services you request (these third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information was shared).
- Disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian legally appointed for you).
- Disclose aggregated statistical data with our business partners. For example, we may disclose that a specific percentage of our users live in particular geographies. However, this aggregated information is not tied to personal information.
Change of Purpose: We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by applicable national law.
International Transfers: We share your personal data within the Centbee group of organisations and affiliates, and this may involve transferring and processing your data outside of South Africa. Whenever we transfer your personal data out of the country, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of South Africa.
10. WHAT ARE COOKIES AND HOW DO WE USE THEM?
Centbee uses its own cookies for a variety of purposes, including to:
- Recognize 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;
- Recognize your time zone so that your transaction histories and other account information are accurately displayed;
- Present customized 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;
- Remember your chosen preferences, such as the language you choose to see our website in or default currencies;
- Fight against fraud;
- 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;
- Enable you to access your account and account services through the Centbee software client;
- Provide internal and customer analytics and gain statistics and metrics about our websites, such as total number of visitors and page views;
- 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 websites;
- Initiate security measures such as ‘time-out’ when you have not logged into your account service area for a period of time; and
- Populate your Centbee client with one of your Centbee contacts’ information, where this contact invited you to join Centbee.
11. HOW LONG IS YOUR INFORMATION RETAINED?
12. HOW DOES CENTBEE PROTECT YOUR INFORMATION?
Centbee is committed to handling your customer information with high standards of information security. 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 fulfil their job responsibilities. 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. We encrypt all transmission of information using secure socket layer technology (SSL). 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 fulfil their given duties. The security of your Centbee account also relies on your protection of your Centbee PIN. Do not share your Centbee PIN with anyone. Centbee representatives will never ask you for your PIN, so any email or other communication requesting your PIN should be treated as unauthorised and suspicious and forwarded to firstname.lastname@example.org. If you do share your Centbee PIN with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your PIN. If you believe someone else has obtained access to your PIN, please change it immediately by logging in to your account and changing your PIN and also contact us right away as described below.
13. ACCESSING OR CHANGING YOUR INFORMATION
You can review the personal information you provided us and make any desired changes or deletions to such information, or to the settings for your Centbee account, at any time by logging in to your account on the Centbee website and changing your preferences or by contacting our support support@Centbee.com. Upon request, Centbee will provide you with information about whether we hold any of your personal information. 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. A fee may be charged depending on the work required to obtain and provide the requested access. We will respond to your request within a reasonable time frame. If you choose to close your Centbee account, you will need to contact Centbee to request this closure. 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. 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. 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. If you wish to subscribe to our newsletter(s) or marketing communications we will use your name and email address to send communication to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at support@Centbee.com.
14. YOUR RIGHTS RELATING TO YOUR PERSONAL INFORMATION.
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no valid reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be communicated to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform on a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Website access or Services to you. We will advise you if this is the case at the time you withdraw your consent. Please take note that regardless of your right to withdraw consent under data privacy laws, other South African legislation applies and may require that we continue to process your data in order to comply with anti-corruption, crime-fighting or other legislation, which you expressly understand and agree to.
No fee usually required: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
14. POLICY ACCOUNTABILITY
15. THIRD PARTY SITES
16. POLICY UPDATES AND NOTIFICATIONS
You can contact us by email: email@example.com.