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INTRODUCTION

Vuuka Holdings Limited (registration number 154067 C1/GBL) (“Vuuka” or “we” or “us”) operates in various territories across the African continent and, in order to carry out our business activities, we are required to process data and/or information (hereafter interchangeably referred to as “data” or “information”) of various third parties for a variety of purposes.

We process the data of our clients, clients’ employees and contractors, vendors, vendors’ employees and contractors, our employees, agents and various other stakeholders who make it possible for us to operate (“Business Contacts”) in order to enable us to do business with them or provide our services.

The aim of this privacy notice is to make sure that you are fully aware of exactly who we are, the types of data we process, how we process it, who we may need to share it with, how long we retain data, as well as what your rights are in relation to our processing of your data. In this privacy notice, “you” means you as an individual, who we are dealing with and whose data we may need to collect and process in the course and scope of our business activities, or the entity you represent.

If you are a person who interacts with, accesses or in any way uses Vuuka ’s website, online services, mobile applications, Point of Sale device/application (“POS Application”), emails, social media sites and any other applications (“Vuuka Application(s)”), customer service centers or our services in general (“services”), this privacy notice applies to you.

This privacy notice describes how Vuuka and its agents collect, use, disclose, transfer, store, retain or otherwise process your data when you access the Vuuka Applications or services. Accordingly, please read this privacy notice carefully. By continuing to interact, access or otherwise use the Vuuka Applications or services, you are consenting to the practices, terms and conditions described herein.

This privacy notice explains:

  • Data we collect about you
  • Sources of data we collect about you
  • How we use your data
  • When and with whom we may share your data
  • Cookies and other similar automated technologies
  • Third-party analytics services
  • How long we keep your data
  • Your choices
  • Security
  • Storage and processing
  • Changes to this privacy notice
  • Ancillary policies and procedures
  • How to contact us

DATA WE COLLECT ABOUT YOU

We need to collect data about you to enable your access and continued use of the Vuuka Applications and to provide you with our services or the support you request. Specifically, we collect the categories of personal data described below.

Data you provide to access or use the Vuuka Applications or services

We collect data you provide when you (i) enquire about our services, (ii) apply or sign up or register for a Vuuka Application account, where applicable, (iii) go through our identity or account verification process, (iv) authenticate your account or identity on the Vuuka Applications (v) communicate or interact with us through the Vuuka Applications, (vi) answer our surveys, or (vii) otherwise use the Vuuka Applications in any way or access our services.

We collect the following categories of data about you when you access or use the Vuuka Applications or our services:

  • Identification data including but not no limited to: names, mailing address, email address, cell phone/telephone number, fax number, gender, age, date of birth (if applicable), company name and registration number (if any), country of residence or incorporation.
  • Additional identification data including but not limited to: authentication credentials (for example, information you use to log-in to Vuuka Applications, including biometric information where the Vuuka Application concerned is the POS Application), government-issued identification documents such as a birth certificate, passport or driver’s license and photographs in respect of natural persons, incorporation and constitutional documents in respect of juristic persons.
  • Financial information such as bank accounts and payment details you add to your Vuuka Application account or otherwise provide to Vuuka.
  • Contact information and, in order to provide customers with our services, we require and collect data from customers about the intended recipient of the payment or such other products or services customers request us to make or provide.
  • Procurement event information: when customers use the Vuuka Applications to make, accept or request procurement of certain products or services, we collect data such as when and where the events occur, the names of the parties involved, a description of the events, the settlement or transfer of event data, the means (such as devices) and payment methods used to complete the events.

Data we collect from you when you access or use Vuuka Applications or our services

We collect data about you and the devices you use to access the Vuuka Applications or our services, such as your computer, mobile phone, tablet etc. The data we collect includes, but is not limited to:

  • Geolocation Information such as: the location of your device, including your Internet Protocol (“IP”) address, device language and location of your network provider. For more information and to learn how to disable collection of location information from your devices, please see “Location information” further below.
  • Device Information, including: information about your device’s hardware model, operating system and version, device name, unique device identifier, mobile network information and information about the device’s interaction with the Vuuka Applications. If you use an iOS device, we also automatically detect if you have downloaded Chrome. Therefore, we may ask you which browser you prefer to use to open links from the Vuuka Applications where applicable.
  • Internet or other electronic network activity information, including: information about how you use and interact with the Vuuka Applications or our services, including your access time, “log-in” and “log-out” information, browser type and language, country and language setting on your device, IP address, the domain name of your internet service provider, other attributes about your browser, mobile device and operating system, any specific page you visit on our platforms, content you view, features you use, the date and time of your use, your search terms and the website you visited before accessing or using a Vuuka Application.
  • Inferences drawn from any of the information we collect to create a profile about you that may reflect, for example, your preferences, characteristics and behaviour, including for account security purposes or to enhance our services.
  • Biometric information which is procured from you in order to grant you access to certain Vuuka Applications, specifically the POS Application.

SOURCES OF DATA WE COLLECT ABOUT YOU

We collect data about you from the following categories of sources:

  • You directly when you submit information to us or allow us to access data.
  • Your devices when you access or use the Vuuka Applications or our services.
  • Our agents with whom you interact.
  • Other sources that might include:
    • Publicly available sources.
    • Credit, compliance and fraud: information about you from third parties for any credit investigation, credit eligibility, identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law. This includes, without limitation, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present and future places of employment, financial institutions and personal reporting agencies.
    • Identity verification: information from third-party verification services (e.g., identity verification agencies and companies which provide third party analytics (see “Third[1]Party Analytics” further below)).

HOW WE USE YOUR DATA

We may collect, process and share information about you for the following reasons:

Providing, improving and developing our services or the Vuuka Applications

  • Determining whether our services and/or Vuuka Applications are available in your country or any other territory where you intend to consume our services.
  • Measuring, tracking and analysing trends and usage in connection with your use of or the performance of our services or the Vuuka Applications.
  • Improving and personalising your use of our services or the Vuuka Applications.
  • Providing, maintaining and improving our services or the Vuuka Applications.
  • Providing you with the products and services and features you choose to use.
  • Delivering information and supporting your requests while using our services.
  • Maintaining your historical product and service procurement information.
  • Processing or recording procurement activities.
  • Developing new products and services.

Communicating with you about our services

  • Providing you with updates or any other information we deem you may find useful or necessary relating to or in connection with our services (for e.g., updated rates, updates or amendments to applicable laws, service outages etc.)
  • Providing you with information you request from us about our services.
  • Sending you surveys and/or getting your feedback about our services.

Protecting the Vuuka Applications, our services and maintaining a trusted environment

  • Protecting your, our, our clients’, our vendors’ and other users’ rights or property, or enhancing the security or integrity of our services or the Vuuka Applications.
  • Conducting investigations, complying with and/or enforcing any applicable laws, regulations, legal requirements, industry standards and responding to lawful requests for information from the relevant governments or competent regulatory authorities.
  • Investigating, detecting, preventing, recovering from, or reporting fraud, misrepresentations, security breaches or incidents, other potentially prohibited, malicious, or illegal activities, or to otherwise help protect your data or accounts.
  • Debugging to identify and fix errors that impair how our services or the Vuuka Applications function.
  • Ensuring compliance with the Vuuka terms of service or other applicable agreements or policies.
  • Contacting you to resolve concerns and help you with our services.
  • Verifying or maintaining the quality and safety of our services.
  • Complying with valid legal processes.
  • Verifying your identity.

Other Uses

For any other purpose we may inform you about from time to time. We will timeously inform you of any other purpose we may intend to (and where necessary seek your consent to) use your information provided for the purposes set out in this privacy notice, which further use is not covered by this notice

WHEN AND WITH WHOM WE SHARE YOUR INFORMATION

We may share your information with the following categories of third parties:

With Other Users of our Services

We may share your information with our Business Contacts with whom you engage during a procurement event or otherwise when accessing or using our services. We may also make certain information available to other Vuuka Applications’ users to help them know they are engaging with the correct counterparty, such as details of when you started using Vuuka Applications or services and whether you appear in their contacts and the number of people in their contacts who have also been party to procurement events or in any way engaged with you.

Vuuka and its Agents

We may share your information internally to provide you with enhanced services from Vuuka and other agent products or services you use, to understand how you engage with Vuuka to help make our services better for you and for all stakeholders involved and to help us build services tailored to your preferences

With our Service Providers

With service providers who help us provide, maintain and improve our services (e.g., service providers who help us with fraud prevention, identity verification and fee collection services), as well as financial institutions, payment networks, payment card associations, credit bureaus, carrying brokers and other entities in connection with our engagements with you or otherwise to help us provide our services.

Business Transfers and Corporate Changes

  • To a potential new owner, co-owner, or operator of one or more of the services or entities affiliated with Vuuka.
  • If we are engaged in a corporate merger, consolidation, or restructuring (including during due diligence and negotiation of these transaction), the sale of all or part of our stock and/or assets, the financing, acquisition, divestiture, or dissolution of all or a portion of our business. or other corporate change process, we may share your data with third parties involved in such transactions.

Safety and Compliance with Law

We may share your information with third parties if we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from creditors, tax authorities, law enforcement agencies, in response to a garnishment, levy, or lien notice, etc.), (ii) to establish, exercise or defend our legal rights, (iii) to enforce or comply with our terms of use or other applicable agreements or policies, (iv) to protect our or our stakeholders’ rights or property, or the security or integrity of our services, (v) for an investigation of suspected or actual illegal activity, or (vi) to protect us, users of our services or the public from harm, fraud, or potentially prohibited or illegal activities.

With Your Consent

With your consent, should it be applicable.

With Others

With other companies who deliver services on our behalf, including via the use of cookies and similar automated technologies and third-party analytics.

Aggregated and Anonymized Information

We may also share (within our group of companies or affiliates, or with service providers or other third parties) aggregated and/or anonymised information that does not specifically identify you or any individual user of our services.

COOKIES AND OTHER SIMILAR AUTOMATED TECHNOLOGIES

When you interact with certain Vuuka Applications, we may obtain certain information using automated technologies, such as cookies, web server logs, web beacons and other technologies. A “cookie” is a text file that websites send to a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag, or clear GIF, is a tiny graphic image that may be used in websites or e-mails to check that a user has accessed certain content.

We may use these automated technologies to collect your device information, internet activity information and inferences as described above. These technologies help us to:

  • Remember your information so you do not have to re-enter it where possible.
  • Track and understand how you use and interact with Vuuka Applications.
  • Measure how useful and effective our services and communications are to you.
  • Tailor our services to your preferences.
  • Otherwise manage and enhance our products and services.

We set some of these automated technologies ourselves, but others are set by third parties who deliver services on our behalf. For example, we may use other companies’ web analytics services (described in the “Third-Party Analytics Services” section below), which use automated technologies to help us evaluate how Business Contacts use Vuuka Applications.

Your browser can alert you when cookies are placed on your device and how you can stop or disable them via your browser settings. You can manage how your device and browser share certain device data by changing the privacy and security settings on your device. Please note, however, that without cookies some features of certain Vuuka Applications may not work properly. For more information regarding cookies in use on certain Vuuka Applications, specifically our website, please refer to our cookie policy on the Vuuka website https://Vuuka.com/.

THIRD-PARTY ANALYTICS SERVICES

We may use third-party analytics service providers to help us with our online services, such as Google Analytics. The analytics providers that administer these services use technologies such as cookies, web beacons and web server logs to help us analyse how you use certain Vuuka Applications. We may disclose your site-use information (including IP address) to these analytics providers and other service providers who use the information to help us figure out how you and others use the Vuuka Applications.

To manage how cookies are used, you can refuse the use of certain cookies through your Google personalisation settings anytime by visiting g.co/privacytools. You can prevent Google’s collection and use of data by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout/.

Further information concerning Google’s terms and conditions of use and data privacy can be found at https://policies.google.com/privacy?hl=en-US and for further information in respect of the types of cookies used by Google and how you can manage the use of cookies, please visit https://policies.google.com/technologies?hl=en-US.

HOW LONG WE KEEP YOUR INFORMATION

We generally keep your information as long as reasonably necessary to do business with you or to comply with the applicable laws. However, even after you deactivate your account, we can retain copies of information about you and any products and service procurement events or services in which you may have participated for a period of time that is consistent with applicable law, or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our services, to assist with investigations, to enforce our general terms or other applicable agreements or policies, or to take any other actions consistent with the applicable laws.

YOUR CHOICES

Personal Information

You can access, correct and update information that you have provided by logging into the relevant Vuuka Application account at any time or by making a request to us at [email protected]. We will need to verify your identity before granting access or otherwise correcting or updating your information.

Deactivating Your Account

If you wish to deactivate or permanently close your Vuuka Application account or stop using our service, you can do so at any time by contacting us at [email protected].

Location Information

In order to provide certain services, we may require access to location information, including precise geolocation information collected from your device. If you do not consent to collection of this information, some services or features in certain Vuuka Applications might not function properly and you might not be able to use those services or features. You can stop our collection of location information at any time by changing the preferences on your mobile device. If you do so, some of the Vuuka Applications will no longer function. You also may stop our collection of location information via the mobile Vuuka Application by following the standard uninstall process to remove the mobile Vuuka Application from your device.

Do Not Track

Certain web browsers allow you to instruct the browser to respond to do-not-track (“DNT”) signals to websites you visit, informing those sites that you do not want your online activities to be tracked. At this time, Vuuka Applications are not designed to respond to DNT signals or similar mechanisms from browsers.

CHILDREN’S PERSONAL INFORMATION

Our services are general audience services not directed at children under the age of 18. If we learn that any information we collect has been provided by a person under the age of 18, we will promptly delete that information.

HOW WE SECURE INFORMATION

We take reasonable measures, including administrative, technical and physical safeguards, to protect your information from loss, theft, misuse, unauthorised access, disclosure, alteration and destruction. Nevertheless, the internet is not a hundred percent secure environment and we cannot guarantee absolute security of the transmission or storage of your information. We hold information about you both at our own premises and with the assistance of third-party service providers.

STORAGE AND PROCESSING

Vuuka may itself or may use third-party service providers to, process and store your information in Mauritius or other countries.

CHANGES TO THIS PRIVACY NOTICE

We may amend this privacy notice from time to time by posting a revised version on our website and updating the “Effective Date” above. The revised version will be effective on the updated “Effective Date”. We will provide you with reasonable prior notice of material changes in how we use your information, which notifications may also be communicated through Vuuka Applications. If you disagree with any changes, you must stop accessing or using the Vuuka Applications or services and notify us of your concern in writing through [email protected]. If you keep using the Vuuka Applications our services, you consent to this privacy notice any other updates as may be applicable from time to time.

ANCILLARY POLICIES AND PROCEDURES

This policy should be read with other Vuuka policies and procedures which provide additional information on Vuuka’s data protection and privacy practices. The said policies and procedures will be published on Vuuka’s website at https://Vuuka.com/ from time to time and/or may be made available to any interested party on request.

HOW TO CONTACT US

If you have any questions regarding this privacy notice, or if you believe our privacy notice or applicable laws relating to the protection of your information have not been complied with, you may file a complaint or notify us in writing through [email protected]. We will respond to your complaint or notification to let you know when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution. If you become aware of a data breach or otherwise suspect there being a data breach in respect of data that we process (or that you or any other third party processes on our behalf, where applicable) you must immediately notify us in writing through [email protected].

You may further reach us through the following contact details for any other reason: