Privacy Policy
We,
ZiCharge, are an electronic mobile payment service provider registered at 24, Karez
Street, Opposite Holland Bazar, Ankawa, Erbil,
Kurdistan, Iraq, hereinafter referred to as ZiCharge. At ZiCharge, we value
your privacy and strive to protect your personal information in compliance with
the laws of Iraq.
This
Privacy Policy is designed to explain and elaborate upon some of our policies
and principles pertaining to the privacy of your personal information, all of
which we have adopted as a sign of our commitment to respecting, maintaining,
protecting and safeguarding the privacy of your personal information.
This
Privacy Policy provides you with details about the manner in which your data is
collected, stored & used by us. This statement applies to all customers,
suppliers, agents, merchants, dealers, other future business entities and all
visitors frequenting any of ZiCharge premises. You are advised to read this
Privacy Policy carefully. By downloading and using the ZiCharge application/Mobile
site you expressly give us consent to use & disclose your personal
information in accordance with this Privacy Policy. If you do not agree to the
terms of the policy, please do not use or access ZiCharge.
For the purposes of this Privacy Policy,
please note that:
●
“ZiCharge '' or “our platform”, “we” or “us”, “our' ' and “ours' '
refers to ZiCharge Wallet unless and to the extent otherwise stated.
●
“You”, “Your” or “Yours” refers to any person, user, visitor,
supplier, agent, dealer and/or merchant who gains access to any ZiCharge
premises and accesses any of the products and services.
●
“Personal information” refers to any information which relates
directly or indirectly to you and/or your transactions with us. This
information includes but is limited to your name, address, gender, date of
birth, email address, contact details, ID details the type of products and/or
services subscribed to and such other necessary information regarding yourself
and your transaction(s) with us. For the avoidance of doubt, please note that
this Privacy Policy is applicable only if you are an individual.
General
ZiCharge will maintain strict
confidentiality relating to information of User provided to ZiCharge and
his/her transactions. ZiCharge shall not sell, share or rent your personal data
or your transaction report to any third parties or use your email
address/mobile number for unsolicited emails and/or SMS. Any emails and/or SMS
sent by ZiCharge will only be in connection with the provision of agreed
services & products and this Privacy Policy.
However, ZiCharge may share your
transaction behaviour data and location to third parties for observing your
transaction behaviour in order to recommend you with improved services or
features and make your experience safer and easier. You acknowledge that Zicharge
shall have the right to monitor your account usage, and may disclose personal
information to any of the following:
●
Any regulatory, supervisory or government authority having
jurisdiction over ZiCharge;
●
Any person to whom ZiCharge is required or authorised by law or a
court of law to disclose such information; and/or
●
Any organisation, service provider or financial institution for the
purposes of carrying out permissible functions and activities of ZiCharge.
Personal Information
In order to enable us to perform our
services, offer our products to you, deal with your inquiries, open and operate
an account for you and/or to fulfil partly or all of the services requested by
you, we may need to and/or be required to process personal information and data
about you, including but not limited to:
●
Personal Information means all information that can be linked to a
specific individual or to identify any individual which include but not limited
to, your name, address details, date of birth, telephone number, mobile phone
number, email addresses, bank account information (including but not limited to
bank name, bank account number, and account holder name), debit and credit card
information including but not limited to card number, expiry date and name)
nationality, ID details, Passport details, address proofs and visa information
(where necessary and applicable only to non-Iraqi);
●
personal information such as your profile picture, photos or avatar,
gender, age, ethnicity, marital status, educational level, occupation, salary
range, interests, hobbies, precise location-based information, device ID or
serial numbers, and passwords when you create an account for our services, and
any other information you directly give us through ZiCharge portal or any other
platforms that may be introduced by ZiCharge;
●
personal information that pertains to you obtained indirectly
through other sources (if any), in respect of which you have given your consent
to them disclosing information relating to you and/or where they are not
otherwise restricted
●
personal information including your particulars, images and
biometrics to establish your identity and background;
●
specimen signatures as well as digital or electronic signatures as
defined under the applicable laws and regulations;
●
personal information that you provide when you apply for any of our
products and services, including your views or opinions made known to us via
feedback or surveys;
●
information about your risk profile, financial standing and/or
business interests and assets;
●
information which we may collect from written communication when
you provide us complaints or issue of inconveniences while using our service
and we may use it for the purposes of communicating with you and to efficiently
manage your requests and to resolve any other issues you may face;
●
information such as occupation, language, postcode, area code,
unique device identifier, location and the time zone where the ZiCharge
products or services are used;
●
information relating to your activities, habits, preferences and
interests arising from your use of products and services of ZiCharge, our
partners or vendors; and/or
●
other electronic data or information relating to you such as IP
addresses, cookies, activity logs, online identifiers and location data through
your usage of our products and services or as part of their supply or delivery
to you.
Note: If you are below the age of eighteen (18), you are responsible to
obtain consent from your parent, guardian or person who has parental
responsibility, prior to disclosing your personal details to Zicharge. Zicharge
shall not be liable for any loss or inconvenience to you for failing to obtain
consent.
Collection of Information
We may obtain this information from
yourself and from a variety of sources, including but not limited to:
●
through your relationship with us, for example information provided
by you in application forms (physical or online through ZiCharge Portal), when
you register and operate your account and use our products or services, when
taking part in customer surveys, competitions and promotions, when providing
feedback or making complaints;
●
through your verbal and written communications with us and/or our
authorised agents via SMS, phone or mobile device, email, fax, mail, websites
or browsers, social media and/or any other appropriate communication channels;
●
from an analysis of the way you use and manage your account(s) with
us, from the transactions you make and from the payments which are made to/from
your account(s) and use of our products or services;
●
from recordings of Closed-Circuit Television (CCTV) installed at
our premises or wherever our Radio Frequency Identification (RFID) or License
Plate Recognition (LPR) products or services are offered;
●
from any relevant governmental authorities and/or law enforcement
agencies to ascertain inter alia your current and past financial standing;
●
from other sources (for example from credit reporting/ referencing
agencies, including but not limited to Central Credit Reference Information
System (CCRIS), Financial Information Services (FIS) and/or any other bureaus
or agencies established or to be established by Central Bank of Iraq or any of
its subsidiaries, or by any other authorities and/or from any financial
institution);
●
information received from refund, settlement or reconciliation
claims or other documents; and/or
●
from any information that is supplied and/or collected when you
visit our websites and/or download our mobile device applications which may
include your device's IP address or from data that is collected via cookies.
We use cookies (or equivalent
technologies) for a number of purposes, including to store your preference for
certain types of information or products, further analysis for the purpose of
providing products and services to you, to improve our products and/or to
personalise our services to you. Cookies are small text files that collect
information about users and their visit to the web site or use of the app, such
as their Internet protocol (IP) address, how they arrived at the web site (for
example, through a search engine or a link from another web site) and how they
navigate within the web site or mobile application.
ZiCharge may use third parties to track
its advertising across the web. The information ZiCharge or these third parties
collect does not include any personal information but is merely for the purpose
of identifying the general effectiveness of such online advertising.
You may adjust settings on your browser
and/or mobile device so that you will be notified when you receive a cookie or
other similar tracking tools. Please refer to your browser documentation to
check if the tracking tools have been enabled on your computer and/or mobile
device or to request not to receive cookies or to disable cookies if you do not
wish to have information collected via the use of cookies. However, do note
that if you enable blocking or disabling of cookies, it may limit certain
features and functions in your use of our web or mobile sites and that some
personalised services on our websites may not be available if you choose to
disable cookies.
Third-Party Sites and Services
Our websites, products, applications and
services may contain links to third-party websites, products and services. Our
products and services may also use or offer products or services from third
parties. Information collected by third parties, which may include such things
as location data or contact details are governed by their privacy practices.
This means, third party internet sites that you can link through our websites
are not covered by our policy. Therefore, we encourage you to familiarise with
those third parties’ sites’ privacy policies before using the links or
applications and we urge you to be careful when you enter any personal
information online. ZiCharge accepts no responsibility or liability for those
sites.
Use of personal Information
Other than as stated above, we may use
your personal information for one or more of the following purposes:
●
to assess, address or fulfil your registration, orders usage,
request(s), application(s), feedback or complaints for our products and
services;
●
to provide you with a better personalised experience on our apps
and websites;
●
to process refunds;
●
to conduct credit checks (including but not limited to ensure our
business partners are of sound financial standing);
●
to manage and maintain your account(s) with us;
●
to better manage our business and your relationship with us;
●
to understand your current and future products, services and
advertising needs;
●
to market and to provide you with information on ZiCharge and
selected third parties products, services, offers and/or contests which may be
of interest to you (in respect of which we may or may not be remunerated)
including but not limited to e-money or cashless payment and related services
and products, and services and products offered by our co-branding partners
(the names of such partners will be provided during the application of the
relevant services and products, as the case may be) and in this respect, to
contact you via short message service (“SMS”), phone or mobile device, email,
fax, mail, websites or browsers, social media or messaging, in person and/or
any other appropriate communication channels;
●
to improve our products and services and to test, research, analyse
and develop new products/ new features of products and/or services;
●
to notify you about benefits and changes to the features of
products and services;
●
to administer offers, competitions and promotions;
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to provide customer service, assess your interest in ZiCharge
products and services, market research purposes and to conduct customer
research or satisfaction surveys;
●
to provide you with products and services provided or administered
by our agents, affiliates, service providers, contractors (including
sub-contractors), merchant and business partners as part of the services and
benefits granted by us;
●
to respond to your enquiries and complaints and to generally
resolve disputes;
●
to protect our rights or property of Zicharge, or the rights of
others including our business partners, suppliers, clients, or others when we
have reasonable grounds to believe that such rights or property have been or
could be affected, or to comply with a judicial proceeding, court order, or
legal process;
●
to update, consolidate and improve the accuracy of our records;
●
to produce data, reports and statistics which have been anonymised
or aggregated in a manner that does not identify you as an individual;
●
to conduct research for analytical purposes including but not
limited to information processing, management and enhancement of data, data
mining and analysis of your transactions with us;
●
to meet the disclosure requirements of any law binding on ZiCharge;
●
to create and maintain risk related models relating to audit,
compliance and risk management purposes or functions;
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to analyse your credit and repayment behaviour scoring as part of
our compliance monitoring purposes;
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to assess financial risks;
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to transfer or assign our rights, interests and obligations under
any of your agreements with us;
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to protect or enforce our rights to recover any debt owing to us;
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to conduct anti-money laundering checks;
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for crime detection, investigation, prevention and prosecution;
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to comply with any sanction or law enforcement requirements;
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to enforce and/or defend any of our rights; and/or
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for any other purpose that is required or permitted by any law,
regulations, guidelines and/or the order of any court and/or relevant regulatory
authorities.
Please be assured that we will ask for
your consent before using your personal information for a purpose other than
those that are set out in this Privacy Policy and in the privacy terms in your
agreement(s) with ZiCharge.
Disclosure of Information
In providing you with our products and
services and the management and/or operation of the same and/or for any of the
purposes as set out in this Privacy Policy in relation to our use of your
personal information, you consent and authorise us to disclose information
about you and/or your accounts with us to:
●
all the entities within the ZiCharge;
●
companies and/or persons that act as our agents, affiliates,
service providers, contractors, merchants, business partners, lawyers, and/or
professional advisers (including the employees, directors, sub-contractors,
service providers, agents and professional advisors of all the aforesaid
companies and/or persons);
●
companies, banks, financial institutions and/or organisations that
assist us in processing and/or otherwise fulfilling transactions that you have
requested;
●
companies and/or organisations that assist us in providing value
added services;
●
companies and/or organisations that provide services to us in
delivering or communicating information about our products and services to you;
●
any authority, central depository or depository agent in relation
to the securities industry;
●
any insolvency department and our appointed debt recovery agents;
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any other person under a duty of confidentiality to us which has
undertaken to keep such information confidential;
●
any trustees, beneficiaries, administrators or executors;
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your advisers (including but not limited to accountants, auditors,
lawyers, financial advisers or other professional advisers) where authorised by
you;
●
any other person notified by you as authorised to give instructions
or to use the account(s) or products or services on your behalf;
●
any party we may deem necessary to facilitate any investigation
related to fraud and/or illegal activities;
●
any law enforcement, government, courts, dispute resolution bodies
and regulatory bodies including Central Bank of Iraq and their appointed
personnel or party; and/or
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any person connected to the enforcement or preservation of any of
our rights under your agreement(s) with us, subject at all times to any laws
(including regulations, guidelines and/or obligations) applicable to the Zicharge
(whether in or outside Iraq). The afore-mentioned third parties may in some
instances be located outside of Iraq.
The information you provide to ZiCharge,
as well as information we collected about you indirectly, may be used by
ZiCharge for marketing purposes. ZiCharge may extract, disclose and release the
information in the possession of ZiCharge relating to you as mentioned in this
Privacy Policy.
Additionally, the individual entities
within ZiCharge, may contact you about products, services and offers, which we
believe may be of interest to you or benefit you financially.
Further, please also be informed that we
will only disclose your personal information (which will not include
information relating to your affairs or accounts) to third parties such as our
merchants and strategic partners for marketing and promotional purposes where
your express prior consent has been obtained and subject at all times to any
laws (including regulations, guidelines and/or obligations) applicable to the
ZiCharge.
We will treat your personal information
as private and confidential and will not disclose your information to anyone
outside the ZiCharge except:
●
where you have given your express consent as set out in our
application form (s) and/ or pursuant to your consent and authorisation as
contained in this Privacy Policy and/or in the terms and conditions governing
the products and services which you have with us and/or under any of your
agreements with us;
●
where we are required or permitted to do so by law;
●
where required or authorised by any order of court, tribunal or
authority, whether governmental or quasi-governmental with jurisdiction over
ZiCharge;
●
where we may transfer rights and obligations pursuant to our
agreement(s) with you; and/or
●
where we are required to meet our obligations to any relevant
regulatory authority (whether in or outside Iraq).
Security of Information
Information is our asset and therefore
ZiCharge places great importance on ensuring the security of your personal
information. ZiCharge takes precautions including administrative, technical and
physical measures to safeguard your personal information against loss, theft
and misuse, as well as against unauthorised access, disclosure, alteration and
destruction.
Furthermore, we intend to protect your
personal information and to maintain its accuracy. ZiCharge implements
reasonable physical, administrative and technical safeguards to help us protect
your personal information from unauthorised access, use and disclosure. We
regularly review and implement up-to-date technical and organisational security
measures when processing your personal information.
Employees of ZiCharge are trained to
handle the personal information securely and with utmost respect, failing which
they may be subject to disciplinary action.
Data Retention
We will only retain your personal data
for as long as reasonably necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, regulatory, tax, accounting
or reporting requirements. We may retain your personal data for a longer period
in the event of a complaint or if we reasonably believe there is a prospect of
litigation in respect to our relationship with you.
To determine the appropriate retention
period for personal data, we consider the amount, nature and sensitivity of the
personal data, the potential risk of harm from unauthorised use or disclosure
of your personal data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means, the need to comply
with our internal policy and the applicable legal, regulatory, tax, accounting
or other requirements.
Anonymised information that can no longer
be associated with you may be held indefinitely.
Your Rights
We can assist you to access and correct
your personal information held by us.
Where you wish to have access to your personal
information in ZiCharge possession, or where you are of the opinion that such
personal information held by us is inaccurate, incomplete, misleading or not
up-to-date, you may make a request to us via:
We will use reasonable efforts to comply
with your request to access or correct your personal information within 21 days
of receiving your request and the relevant processing fee (if any).
Please note that ZiCharge may have to
withhold access to your personal information in certain situations, for example
when we are unable to confirm your identity or where information requested for
is of a confidential commercial nature or in the event we receive repeated
requests for the same information. Nevertheless, we will notify you of the
reasons for not being able to accede to your request.
Please also note that ZiCharge may use
its discretion in allowing the corrections requested and/or may require further
documentary evidence of the new information to avoid fraud and inaccuracy.
Please ensure your personal information
(such as your mailing address(es), e-mail address(es) and telephone number(s)
recorded with us are current, complete and accurate. Please notify us of any
change in your personal particulars via the channels made available by us to
ensure that all correspondence and/or communication reach you in a timely
manner and to enable us to serve you better.
If you wish to request that we no longer
use your personal data or limit the usage of your personal data in anyway
whatsoever, you may contact ZiCharge by email to support@zicharge,com. However,
please note that ZiCharge may not be able to proceed with the provision of the
relevant product or services and you may not be able to use such product and
services thereafter.
The personal data requested by ZiCharge
are mandatory for the relevant product or services which you must provide and
agree to the processing of such personal data. Should you decide not to provide
any or all of the personal data, ZiCharge may not be able to proceed with the
provision of the relevant product or services and you may not be able to use
such product and services thereafter.
Exercising Choices Over the Disclosure, Retention and Use of Your
Personal Information
Subject always to our contractual rights
and obligations under relevant laws and regulations, you may exercise your
choice in respect of the disclosure, retention and use of your personal
information. Should you wish to do so, kindly contact us at the Careline given
at the end of this Privacy Policy.
Please take note that certain
communications such as emails, newsletters, statements of account and/or our
websites contain standard information regarding our other products and services
that cannot be removed without affecting the delivery/provision of our services
and/or products, the operation of your account(s) with us, and/or additional
costs to you.
Consent
By using ZiCharge and/or by providing
your information, you consent to the collection and use of the information you
disclose on ZiCharge in accordance with this Privacy Policy, including but not
limited to your consent for sharing your information as per this privacy
policy.
Amendments/Revisions
ZiCharge reserves the right to amend or
change this privacy policy at any time without prior notification. To make sure
that you are aware of any changes, kindly review the policy periodically. This
Privacy Policy shall apply uniformly to ZiCharge application and future
ZiCharge Applications, desktop website & mobile site.
Contact Us
Should you have any query in relation to
this Privacy Policy or how we handle your personal information, kindly contact
us at the following contact points:
Call Centre Email |
support@zicharge.com |
Live chat |
https://www.facebook.com/zichargewallet |
Right to Lodge Complaint
If your issue is not resolved even after
contacting various complaint resolution channels, you have the right to lodge a
complaint with the relevant supervisory authority that is tasked with personal
data protection within Iraq.