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.
● “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.
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.
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.
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.
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;
● 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;
● to analyse your credit and repayment behaviour scoring as part of our compliance monitoring purposes;
● to assess financial risks;
● to transfer or assign our rights, interests and obligations under any of your agreements with us;
● to protect or enforce our rights to recover any debt owing to us;
● to conduct anti-money laundering checks;
● for crime detection, investigation, prevention and prosecution;
● to comply with any sanction or law enforcement requirements;
● to enforce and/or defend any of our rights; and/or
● 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.
Disclosure of Information
● 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;
● any other person under a duty of confidentiality to us which has undertaken to keep such information confidential;
● any trustees, beneficiaries, administrators or executors;
● 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
● 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.
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 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.
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.
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
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.
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.