Wakandi Privacy Policy

1. Introduction

1.1 For the purpose of this Privacy Policy, “Wakandi” shall mean Wakandi Group AS Limited (Proprietary) with the Registration Number 2020/899210/07.
1.2 Wakandi is committed to safeguarding the privacy of visitors to our website and the users of our application (“our services”).
1.3 Please read the following Privacy Policy (policy) to understand how we collect your data and how it is treated. This policy may be updated from time to time, so please check it from time to time.
1.4 We recognis​e the importance of protecting your privacy in respect of your personal information as defined in the relevant legislation collected by us when you use our services.
1.5 “Personal information” means any information which uniquely identifies you, and includes information such as your name, email address, telephone number, MSISDN, biometric information and password, banking as well as any other personal data collected.
1.6 By using our services and communicating electronically with us, you consent to the processing and transfer of your personal information as set out in this Privacy Policy below.

2. Personal information we may collect

The information we collect about you and how we collect it can vary depending on the specific services that you use and subscribe to, how you have used the services, and how you have interacted with us even if you aren’t a customer, or what we have obtained from a third party with permission to share it with us.

2.1 We may get your personal information when you-

2.1.1 Transact with mobile money or acquire any other services from us.
2.1.2 Register for a specific service by providing your name, email id, address and other details for Mobile Money.
2.1.3 Subscribe to newsletters, alerts or other services from us.
2.1.4 Ask us for more information about our services, or contact us with a question or complaint.
2.1.5 Take part in a competition, lucky draw or survey conducted by Wakandi.
2.1.6 Download/access our application, or visit our website.
2.1.7 With your permission or consent and/or as permitted by law, we may also collect information about you from other organisations or third parties, if this is appropriate and allowed by law. These include fraud-prevention agencies, business directories, and credit reference agencies.

2.2 The information about you that we may collect and process includes (but is not limited to) the following:

2.2.1 Your name, date of birth, home language, address, account information and email address.
2.2.2 Your preferences for particular services or lifestyle activities when you tell us what they are – or when we assume what they are, depending on how you use our services.
2.2.3 Your contact number.
2.2.4 Your account information.
2.2.5 How you use our services.
2.2.6 The device or phone numbers that you use to access our services.
2.2.7 The level of service you receive.
2.2.8 Your website browsing information (which includes information about the websites you visit), and about how you use our Website on your device.
2.2.9 The date, time and length of your internet browsing, and your approximate location at the time of browsing.

In adopting this Privacy Policy, we wish to balance our legitimate business interests and your reasonable expectation of privacy. Accordingly, we will take appropriate and reasonable technical and organisational steps to prevent unauthorised access to, or disclosure of your personal information.

2.3 By continuing to use this website:

2.3.1 You agree that we may “collect, collate, process and/or store” your personal information (“process”) for, the purposes set out in this Privacy Policy including providing you with access to the website and the website content.
2.3.2 Where there are reasonable grounds to believe that your personal information has been accessed or acquired by any unauthorised person, we will notify the relevant regulator and you, unless a public body responsible for detection, prevention or investigation of offences or the relevant regulator informs us that notifying you will impede a criminal investigation.

3. How and when we process your personal information?

3.1 We may use and analyse your information to:

3.1.1 Process services, and keep you updated on the services including any updates thereto.
3.1.2 Keep you informed generally about new products and services (unless you choose not to receive our marketing messages).
3.1.3 Provide the relevant service or product to you. This includes services that use information about where you are when using your mobile equipment (location information) and to contact you with messages about changes to the service or product.
3.1.4 Contact you with offers or promotions based on how you use our products and services. These include your calling and messaging activities, location information and browsing information (unless you choose not to receive these messages).
3.1.5 Bill you for using our products or services, or to take the appropriate amount of credit from you.
3.1.6 To administer our website and our application and help us improve our services.
3.1.7 Respond to any questions or concerns you may have about using our services.
3.1.8 At your option, we will let you know about our partner companies’ products and services we think may interest you (including offers and discounts we’ve specially negotiated for our customers).
3.1.9 Protect our application and its network and manage the volume of transaction. For example, we identify peak periods of use so we can try and ensure the application can handle the volume at those times.
3.1.10 Understand how you use our application, products and services. That way, we can develop more interesting and relevant products and services, as well as personalising the products and services we offer you.
3.1.11 Carry out research and statistical analysis including to monitor how customers use our application and services on an anonymous or personal basis.
3.1.12 Prevent and detect fraud or other crimes, recover debts or trace those who owe us money.
3.1.13 Provide aggregated reports to third parties (such reports do not contain any information which may identify you as an individual).

3.1.14 Marketing purposes including organic reach and ads on social media platforms and browsers. 
3.1.15 Training purposes.

3.2 The relevant device information we use may include:

3.2.1 Your approximate location which will change as you move around with your mobile device.
3.2.2 We may make use of technologies that enable us to identify your telephone number if you are accessing some of our websites or apps.

We’ll store your information for as long as we have to in accordance with the law. If there’s no legal requirement, we may or may not store your personal information for as long as we think is required.

4. Sharing of your personal information

4.1. You consent that we may disclose your personal information to approved third party providers where necessary.

4.2. You agree that once your information has been de-identified, i.e.: delete any information that identifies you, personal information may be shared under the following circumstances:

4.2.1 To our agents, advisers, service providers and suppliers (our SEO agency, creative, brand, digital and media agencies, Microsoft, Google and other research agents).
4.2.2 Partner companies of Wakandi, including partners or agents involved in delivering the products and services you’ve ordered or used.
4.2.3 Partners or agents that conduct network performance and customer satisfaction surveys and any other surveys related to or services provided to you.
4.2.4 Where applicable, credit reference, fraud prevention or business scoring agencies, or other credit scoring agencies.
4.2.5 Debt collection agencies or other debt recovery organisations.
4.2.6 Law enforcement agencies, regulatory organisations, courts or other public authorities if we have to, or are authorised to by law.
4.2.7 We’ll release information if it’s reasonable for the purpose of protecting us against fraud, defending our rights or property, or to protect the interests of our customers;
4.2.8 Upon request by a third party making legitimate request for the purpose of protecting or exercising its rights in terms of PAIA and upon production of the supporting documentation in respect thereof.
4.2.9 In a situation of amalgamation, partnership, sale or merger with another organisation, we may transfer any personal information we hold about you to that organisation.

5. Unauthorised access to your information

Despite the security measures we have in place to protect your personal information (firewalls, password access and encryption methods) you acknowledge that it may be accessed by unauthorised third party, e.g. as a result of a hack or an illegal activity.

We would not be responsible for any unauthorised access or loss of personal information that is beyond our control.

We’ll never ask for your secure personal or account information by an unsolicited means of communication. You’re responsible for keeping your personal and account information secure and not sharing it with others.

6. International data transfers

This policy is based on the applicable Norwegian legislation including the General Data Protection Regulation. Given that we operate in various African countries, including but not limited to South Africa, Tanzania and Gambia, various communications may result in the transfer of information across international boundaries.

We may also need to transfer your personal information to our subsidiary companies, sister concerns, partner companies or service providers cross-border, in which case we will fully comply with applicable data protection legislation. This may happen if our servers or suppliers and service providers are based outside your country, or if our services are hosted in systems or servers in the European Economic Area (EEA) and/or if you use our services and products while visiting other countries. We will continue to make sure that your personal information is protected and enter into appropriate agreements to achieve this.

7. Your rights

7.1. You have the right to request that we correct, modify, update or delete any of your personal information that we have processed in accordance with this Privacy Policy. The personal information that you may request us to correct, modify, or delete could be inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully or that we are no longer authorised to retain.
7.2. You have the right to withdraw your consent for us to process your personal information at any time. The withdrawal of your consent can only be made by you on condition that:

7.2.1. It does not affect the processing of your personal information before the withdrawal of your consent; or
7.2.2. It does not affect the processing of your personal information if the processing is in compliance with an obligation imposed by law on us; or
7.2.3. It does not affect the processing of your personal information where such processing is necessary for the proper performance of a public law duty by a public body; or
7.2.4. It does not affect the processing of your personal information as required to finalise the performance of a contract in which you are a party; or
7.2.5. It does not affect the processing of your personal information as required to protect your legitimate interests or our own legitimate interests or the legitimate interests of a third party to whom the information is supplied.

7.3. You have the right to object to the processing of your personal information at any time, on reasonable grounds relating to your particular situation, unless the processing is required by law.
7.4. You can make the objection if the processing of your personal information is not necessary for the proper performance of a public law duty by a public body; or if the processing of your personal information is not necessary to pursue your legitimate interests; our legitimate interests or the legitimate interests of a third party to which the information is supplied.
7.5. You have the right to object to the processing of your personal information, at any time, if the processing is for purposes of direct marketing other than direct marketing by means of unsolicited electronic communications and you have not given your consent for that processing.
7.6. You have the right not to have your personal information processed for purposes of direct marketing by means of unsolicited electronic communications from third parties unknown to you or you have not given your consent for that processing.
7.7. You have the right not to be subjected to a decision which is based solely on the basis of the automated processing of your personal information intended to provide a profile of you.
7.8 Decisions that you may not be subjected to are decisions that result in legal consequences for you or affect you to a substantial degree:

7.8.1. Without being for the execution of a contract that you have received performance for; or
7.8.2. Decisions made that are not in terms of law or of a code of conduct that specifies what appropriate measure must be taken to protect your legitimate interests.

7.9. You have the right to submit a complaint to the Information Regulator an alleged interference with the protection of personal information processed in accordance with this policy.
7.10. You have the right to institute civil proceedings regarding an alleged interference with the protection of your personal information processed in accordance with this Privacy Policy.

8. Use of cookies

8.1. Cookies are pieces of information a website transfers to a user’s hard drive for record-keeping purposes. Cookies make surfing the web easier for you by saving your preferences and tracking your online habits, traffic patterns, and making sure you do not see the same advertisement too often. The use of cookies is an industry standard.
8.2. We may place a cookie on your browser to store and sometimes track the information referred to above in 8.1.
8.3. While most browsers are initially set up to accept cookies, you can reset your browser to refuse all cookies or indicate when a cookie is being sent. Please note that some parts of the website will not function properly if you refuse cookies.

9. Use of IP address

9.1. An Internet Protocol (IP) address is a number that is automatically assigned to a computer whenever it is connected to the Internet. We log IP addresses or the location of computers on the Internet.
9.2. We may collect IP addresses for the purposes of system administration and to audit the use of the website. We do not link IP addresses to personal information unless it becomes necessary to enforce compliance with the Privacy Policy or to protect our website or its users.

10. Links to other sites

10.1. When you are using the website or our services, you could be directed to other sites that are beyond our control. We are not responsible for the content or the privacy policies of those third party websites.
10.2 The same applies to any third-party websites or content you connect to using our services.

11. Contact Information

11.1. If you have any questions in relation to this Privacy Policy please email us at: support@wakandi.com
11.2. If you currently receive marketing information from us which you would prefer not to receive in the future please email us at support@wakandi.com

12. Governing law

The laws of Norway will govern any dispute or claim arising out of or relating to this privacy policy, your use of this website and our services.