We appreciate that you expect us to treat your data in accordance with professional standards. We always do our best to ensure that we do not act in any way that may endanger your personal data without very good cause.
In this document we aim to present you with a succinct overview of our policies, and to secure your consent to same. Whilst no one document can ever be completely comprehensive, we have striven to enclose many of the most salient matters requiring your attention in respect of how we manage any personal information we collect from you, or which you provide to us to enable us maintain the requisite consistency of experience in our applications for your convenience.
Information we collect from you
The following, among others, are some of the sources and channels through which your information may come into our possession.
- Information supplied by yourself to us. You may provide us with such information about yourself by completing forms or surveys via our web portals, through our native mobile applications, by calling our call center, or in various other direct ways. The information may also come to us in the form of electronic correspondence via multiple media, such as email, messaging and chat apps, social media, direct phone calls to our representatives, text messages, in-person questionnaires, fax or in a physical medium such as courier, post or packages. The contexts may vary widely, and may include, but not limited to, payments processing, quotes solicitation, invoice management, credit management, customer service, complaints investigations and management, and compliance formalities. Whilst the exact definitions of what qualifies as personal or customer data may vary from jurisdiction to jurisdiction, we can mention the following as a very tiny subset of the types of information that we may classify as personal or customer data in our servers: names, dates of birth, citizenship, residence information, sexual status, sexual identity, tax identification, medical status information, legal residence status information, credit history, shopping history, rating history, employment history, medical records, medical prescription data, banking data, income data etc.
- Third Party data about or related to you. To improve our effectiveness in providing you with relevant experiences and information, we usually have to rely on other sources in order to learn about your preferences and access rights and the like. For example, we may depend on companies whose custom you patronize to access information for your eligibility for a certain offer or to even obtain contact information for you before we can send you the notifications about your eligibility.
Storage & Handling
We observe all reasonable measures to ensure that our physical servers are maintained within reasonable bounds of security and integrity. We do have servers located within the European Union, where strict standards are in place regarding the safeguard limits considered appropriate. Our datacenter management contractors comply with local law on cybersecurity. Standard operational requirements usually require that information stored on servers in a particular jurisdiction must routinely be transferred and conveyed to other jurisdictions for reasons too many to enumerate here. When this happens, appropriate safeguard standards covering transport and transfer are observed.
The cloud computing, server configuration, and datacenter management fields are in constant flux. New measures are promulgated constantly. We ensure that we only engage contractors capable of understanding emerging risks and the evolving nature of cyber threats and attack vectors. There is however no framework, protocols, systems or processes completely immune to compromise. We can therefore not guarantee that our measures can defy every attempt to breach or circumvent them. Consequently, whilst our systems have been designed to a reasonable level of robustness, in order to be able to resist conventional threats and attacks, we cannot anticipate all scenarios and can therefore not prepare for all risks in advance. We are thus unable to provide assurance that our systems and your data may not be compromised whilst in our possession; we can only assure you that we shall take reasonable care and take steps to reduce the likelihood of such incidents occurring.
There is also no set period for preserving records of your information. In many instances our duty and obligation to law enforcement agencies require that we maintain information for as long as physically practicable, even after you or we have terminated the relationship and the services being offered by us to you. Rest assured however that even after termination, we shall continue to take reasonable steps to prevent the unauthorized disclosure of your data to third parties in the absence of the appropriate procedures.
Fair Use of Your Information
We consider the following to constitute reasonable grounds for holding, handling, managing and storing your information:
- To comply with law, regulations, equity, policy, ethics and professional standards.
- To equip us to be able to deliver on our commercial obligations to you or to a third party reasonably deemed to be acting in your commercial interest or providing you with products and services.
- To optimize the user interfaces of our platforms to ensure a consistent experience.
- To enhance the customer engagement and relationship process.
- To keep you abreast of information relevant to you based on your record of interactions with us, our products, services and affiliates.
Authorised Disclosure of Your Information
We shall not willfully and unethically seek to trade in your information in anyway that can pose foreseeable harm to your interests.
Whenever we share your information within units in our organization, with authorized affiliates, or with third partie we reasonably deem to be legitimate recipients, we would only be doing so cognizant of the fact that the parties with whom we are sharing the information have consented to abide by the professional standards in the industry or sector within which they operate. We require all service providers, affiliates, allies, and authorised third party recipients of information to comply with professional confidentiality standards and to observe marketing ethics. Our contractors are explicitly forbidden from exploiting customer information for unethical, illegal and underhand purposes, and their continuing access to information we hold is dependent and contingent on their commitment to compliance.
We are generally required by law, policy, regulations and ethics to release information held on individuals and customers to assist law enforcement agencies and regulatory bodies for the purposes of public safety, the prevention of crime, and the abatement of fraud. Depending on the precise jurisdiction in which data handling, storage, transfer or management is being done, periodic disclosures may be warranted as a matter of course.
Widgets and Cookies
Providing a consistent and stress-free user experience across platforms, applications and devices is one of our most important objectives. To do this, it is often crucial that our insights into customer preferences and interests are accurate, up to date, and comprehensive. Cookies and widgets embedded into websites, portals, native apps, and other applications improve our chances of attaining these objectives. These tiny files keep track of navigational referents and event sequences as well as a range of other ambient factors in order to help us render the most appropriate interfaces to you, whichever part of our service and product landscape you may be. In this document and related others, we shall refer to the terms, “cookies” and “widgets”, interchangeably and sometimes together as a quick means of describing the various tools and techniques required to align the state of our products and services with your interests, preferences and anticipated preferences, especially in the digital realm.
Third Party Content
There are occasions when we have to link you to third party resources on the internet and elsewhere in order to assist you obtain a complete picture of a particular issue, situation or event. We may do these through hyperlinks, references or even popups. Please note that any such referrals or redirections are not meant to serve as an endorsement, approval or promotion of the content, features or functionalities that you may encounter on these sites or in these resources. You are strongly advised to do your own assessment of the appropriateness of the content or resources before taking any actions or decisions. Under no circumstances can we accept liability for the outcomes or consequences of your use or reliance on such third-party content.
This policy is valid and active from October 2015 onwards until further notice. Any updates or changes shall reflect on the dedicated privacy statement/policy, compliance, and disclaimer pages on our websites and in the designated spots or pages in our applications. At all times, the definitive version of this policy is the version hosted on our websites or in our applications. No other version of this policy statement/document, even if emailed or sent directly to you or anyone by a member of our staff, can be relied upon unless it is an exact replica of the version hosted on our websites or inside our applications.