1
INTRODUCTION & PURPOSE
This Privacy Policy spells out how Titan
Payment System Limited (Titan PS, MyCashBox, Us, We, Our) will protect your
information as you use MyCashBox, our digital financial services.
In order to operate an account on MyCashBox and to
reduce the risk of fraud We will ask you to provide Us with information about
yourself. By consenting to, and agreeing to the terms of this Privacy Policy,
you expressly consent and agree to us processing your data in the manner set
out in this document. This Privacy Policy describes the information we collect,
how we use that information and how We secure it. We take the privacy of your
personal information very seriously and will use your information only in
accordance with the terms of this Policy.
We will not sell your personal information to third parties for any purpose.
However, in order to offer better services to you, we may share some or all of
your personal information with third parties under Strict Privacy Restrictions.
It is important for you to review this Privacy Policy as it applies you.
By accepting this Privacy Policy at registration, you expressly give your
consent to our use and disclosure of the information you provide Us according
to this Privacy Policy.
2
NOTIFICATION OF CHANGES
This Privacy Policy may be revised from
time to time and the revised version posted on our website on the legal pages
and will be effective at the time of posting. Where the change to this Privacy
Policy is substantial in nature, we will provide users with at a 30 day prior
notice. We will send the notice by e-mail, SMS and social media to inform you
of the changes. After expiration of notice period, you will be considered as
having expressly given your consented to all revisions to the Privacy Policy.
If you disagree with the terms of this Privacy Policy, you may close your
account on MyCashBox at any time.
3
THIRD PARTY WEBSITES OR
PLATFORMS
In our operation, we may integrate with
third party platforms and websites. These sites are governed by their own
privacy statements and We shall not be responsible for their operations,
including their information practices. Users should review the privacy policy
of these third parties before submitting their personal information to or
through them.
4
USERS UNDER SIXTEEN YEARS OF AGE
Users under sixteen years of age are not
eligible to register and use our services on their own. Parents who wish that
their children use MyCashBox can easily sign them up and send them MCB credits.
Parents have full view and control over the activities of their children.
5
INFORMATION WE COLLECT
5.1
PERSONAL INFORMATION
To open an account on MyCashBox or use Our Services,
you must provide us with the following basic personal information;
·
Your name
·
Your preferred username/login
name
·
Mobile phone number
·
Email address (optional)
·
Date of birth
·
Biological gender
·
National ID card type – voter
card, Ghana card, driver’s license, passport
·
National ID number
·
Issuance Date
·
Expiry Date
Depending on the nature of the services you request,
you may have to furnish Us with additional information as may be required in
order for Us to be compliant with the requirements of the laws. Additional
personal information requested may include, but not limited to the following;
·
Residential address – House
number, street name, area name
·
Ghana post digital address
·
Image of national ID – side
with your photo and personal information
·
Marital status
·
Place of work
·
Occupation
We may also collect and store information relating to
your mobile devices including but not limited to device ID and geolocation
data.
5.2
TRANSACTION INFORMATION
When you transact using MyCashBox, we may
collect information about that transaction. This information may include;
·
Recipient name
·
Recipient mobile phone number
·
Recipient email
·
Transaction amount
·
Transaction description
·
Time of transaction
We may also collect information relating to
your IP address and geolocation. We retain such information so that we can
enhance Our services and also protect you against instances of unauthorised
transactions.
5.3
CUSTOMER SERVICE CORRESPONDENCE
Whenever you interact with Us through
emails, SMS, voice or by other means, we retain such information on our systems
so that we can keep records of our relationship, to measure and improve our
services to you.
5.4
YOUR INFORMATION WITH THIRD
PARTIES
By your consent, we may collect your
information with Third Party platform such as Google, Facebook, Microsoft and
Yahoo to improve our service delivery to you. We implemented the OpenID Connect / OAuth protocols to
allow you to sign-up and login to MyCashBox using your information from these
platforms.
5.5
SURVEYS AND PROFILE DATA
From time to time, We may conduct surveys
and collect information that we can use to serve your better. Information
collected may include demographics or relating to interests and needs. You will
be informed prior to participating in such surveys and how we intend to use the
information collected.
5.6
NON-USERS
When a registered user sends cash to a
non-user, We will keep the information that the registered user submits to Us
such as;
·
Recipient name
·
Recipient mobile phone number
·
Recipient email
·
Transaction amount
·
Transaction description
·
Time of transaction
6
HOW WE USE AND DISCLOSE INFORMATION
6.1
INTERNAL USES
Our primary objective for collecting your personal
information is to improve Our services to you and enhance your experience. You
agree that We may use your personal information to;
·
Improve Our services to you,
·
Provide you with support
services,
·
Resolve your complaints and
disputes,
·
Prevent fraud or other
illegalities,
·
Reach you directly with new
services and promotions,
·
Deliver direct marketing and
advertising base on your preferences and
·
Verify and authenticate
information you provided from third party sources.
6.2
CONTENT POSTED BY YOU FOR PUBLICATION
When you provide Us with content or you
post the content yourself for publication using MyCashBox, you grant Us
(MyCashBox and Titan PS) a non-exclusive, worldwide, perpetual, irrevocable,
royalty-free, sub-licensable right to exercise any and all copyright,
publicity, trademarks, database rights and intellectual property rights you
have in the content, in any media known now or in the future. Further, to the
fullest extent permitted under applicable law, you waive your moral rights and
promise not to assert such rights against the Titan PS or MyCashBox, its
sub-licensees or assignees.
6.3
DISCLOSURE OF YOUR
INFORMATION TO OTHER USERS
If you are a registered user, only your
full name and username or login name are made available to users you transact
with. Private users cannot search for other private users but can search for
businesses. If you are a registered Business using MyCashBox, your website
address and contact information will be made available to both private and
business users.
We may however disclose your information to
third parties when you use these third parties to access Our services. We will
disclose your information to no one unless we are required to do so by the
order of a court or other legal processes.
6.4
DISCLOSURE OF YOUR
INFORMATION TO THIRD PARTIES
We will not sell or let any of your
personal information to third parties for marketing activities and will only
disclose this information in limited circumstances and for the purposes
described in this policy.
You consent to and direct us to do any and all of the
following; disclose information including, without limitation to transaction
information, personal information and the contents of your communications to;
a.
The police; security forces;
government agencies, regulatory authorities, and agencies we in good
faith believe it is appropriate for us to cooperate with in investigations of
fraud or other illegal activities or potential illegal activities.
b.
A civil or criminal legal
process.
c.
Your agent or legal
representative, the holder of a power of attorney that you grant, or a guardian
appointed for you.
d.
Aggregated statistical data
with our business partners or for public relations.
6.5
CONTACTING USERS
We communicate with our users via their
account on MyCashBox, email, SMS, social media and by phone calls to:
·
Resolve complaints or claims
related to their transactions
·
Provide support for requests
·
Inform users if we have reason
to believe they are performing illegal transactions
·
Confirm a user's identity,
business or MyCashBox activity
·
Conduct customer surveys
· Investigate doubtful transactions
We use your account on MyCashBox, email and mobile number to alert you of payments that you have made and received and cash you have sent and received and to send you information about important changes to our services.
7
HOW WE SECURE YOUR
INFORMATION
We are committed to handling your
information with high standards of information security. We use computer
safeguards such as;
·
Firewalls and data encryption
·
Enforce physical access
controls to our premises and files
·
Authorise access to information
on a need to know or use basis
·
Share privacy policy with
customers on website, mobile app and social media
·
Report privacy issues through
customer complaint channels
The security of your account also relies on
how safe you keep your passwords or PINs;
·
You shall not share your
password or PIN with anyone.
·
Our staff or representatives
from partners and agents will never ask you for your password or PIN.
·
Any email or SMS or other
communication requesting your password or PIN should be treated as fraudulent
and forwarded to support@titanps.mycashbox.org.
· If you believe someone else has obtained access to your password, please change it immediately by logging in to your account.
8
UPDATING YOUR
INFORMATION ON MYCASHBOX
You can update your personal information on
your account on MyCashBox anytime by accessing your account on MyCashBox, go to
personal and make the changes you wish to make.
If you wish to close your account on
MyCashBox, you will have to notify us by sending a message to support from
within your account or an email to support@titanps.mycashbox.org. Note that
even if We close your account on MyCashBox, it will be marked as “disabled” for
a while then finally marked as “removed”. Your account information will, however,
be kept on our database. 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 one. However, if you close your account,
your personally identifiable information will not be used by us for any further
purposes except as necessary to prevent fraud and assist law enforcement, or as
required by law.
9
EFFECTIVE DATE
The Privacy Policy will come into effect immediately upon approval by
Managing Director and the Board of Directors.
10
REVIEW OF THIS POLICY
In the interests of dealing with the ever increasing risks, the contents
of this Policy will be reviewed annually by the Business Risk department and
tabled for approval from the MD.
11
QUESTIONS OR CLARIFICATIONS
RELATED TO THIS POLICY
All questions or other clarifications of this policy and its related
responsibilities should be addressed to the Business Risk Unit at compliance@titanps.mycashbox.org, who shall be responsible for the
administration, revision, interpretation, and application of this policy.
12
APPROVAL
