Automatic Collection of Information
When you visit the Website or App our servers automatically record information about your computer hardware and software. This information may include technical data such as your browser type and version, domain names, operating system type and version, language preferences or the webpage you were visiting before you came to our Website or App, pages of our Website or App that you visit, the time spent on those pages, information you search for on our Website or App, access times and dates, and other statistics.
The aforementioned Information is collected automatically and is used only to identify potential cases of abuse and establish statistical information regarding your use of the Website or App. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.
Collection of Personal Information
When you use the Company’s Website, App, DinarPAY and/or Services (additional details on the associated services offered by Company can be found under Company’s Terms and Conditions), we may collect, use, store or transfer some or all of the following Personal Information:
- Your company information, first name, last name, title, and other identifiers that you may have provided at some time;
- Your contact information which includes data such as billing address, delivery address, email address, telephone numbers and any other data you have provided to us for the purpose of communication or the rendering of DinarPAY to you; and
- Your financial data such as your bank account and payment card details.
Retention Period for Personal Information
Company will retain and use your Personal Information for a period of one (1) year or for the period necessary to comply with our legal obligations, resolve disputes, and to enforce our agreements with you. Once the retention period expires, Personal Information shall be deleted.
Storing Personal Information
All Personal Information is stored on a dedicated server and in a backup vault; and all other data pertaining to the DinarPAY is processed and stored securely using SOAP over XML bindings, Byte Array, Java Class Files and are running under a highly secured firewall.
Use of Personal Information
Company’s use of your Personal Information will always have a lawful basis, being that (i) we have a contractual obligation with you as pertains to the provision of DinarPAY; or (ii) you have consented to our use of your Personal Information; or (iii) we are protecting Company’s legitimate interests (for instance for accounting purposes or more broadly for regulatory compliance purposes); or (iv) we have a legal obligation to divulge your Personal Information. More specifically, Company may use your Personal Information for the following purposes:
(i) Personal Information we process because we have a contractual obligation with you: When you use DinarPAY on Company’s Website or App, or otherwise agree to our Terms and Conditions (“Terms”), a contract is formed between you and Company. In order to carry out our obligations under that contract we must process the Personal Information you provide to us. We may use your Personal Information to: verify your identity for security purposes; and/or provide you with our services. Company shall continue to process your Personal Information until the contract between us ends or is terminated by either party in accordance with the Terms.
(ii) Personal Information we process with your consent: When there is no contractual relationship between you and Company, and through certain actions such as when you browse the Website and/or App or when you request that we provide you with more information about DinarPAY, you provide your consent for Company to process your Personal Information. Wherever possible, Company aims to obtain your explicit consent to process your Personal Information. We may continue to process your Personal Information on this basis until you withdraw your consent. You may withdraw your consent at any time by sending us an email at email@example.com. However, if you do so, please note that you may not be able to (a) access the Website and/or App, or (b) use DinarPAY further.
(iii) Personal Information we process for the purposes of legitimate interests: Company may process Personal Information on the basis that there is a legitimate interest (for example, for recordkeeping purposes, obtaining insurance advise and professional advice.) either to you or to us. Where we process your Personal Information on this basis, we shall do so after having given careful consideration to whether: (a) the same objective could be achieved through other means; (b) processing or not processing the Personal Information might cause you harm; (c) you would expect Company to process your Personal information, and (d) you would consider it reasonable for us to process your Personal information.
(iv) Personal Information we process because we have a legal obligation: Company may have to process your Personal Information in order to comply with a statutory obligation, which may include, but not be limited to providing your Personal Information to legal authorities upon a legal request to do so.
(v) Personal Information we process for the purposes of connecting you with our service providers: To facilitate your use of DinarPAY, we work with a number of service providers, who process data on our behalf. Our service providers include Banks in Libya, merchants, and email service providers.
You may exercise certain rights regarding the processing of your Personal Information by us. In particular, you have the right to:
- withdraw your consent where you have previously given your consent to the processing of your Personal Information, except to the extent that the basis of our processing your Personal Information is required by law;
- object to the processing of your Personal Information;
- access and ask for copies of your Personal Information;
- verify the accuracy of your Personal Information and ask for it to be updated or corrected;
- restrict the processing of your information, in which case, we will not process your Personal Information for any purpose other than for storing it;
- obtain the erasure of your Personal Information from us; and
- receive your information in a structured, commonly used and machine-readable format.
You may exercise any of your rights in relation to your Personal Information by written notice to us, using the contact details set out below. Should you have any cause for complaint about our use of your Personal Information, please contact us using the details provided below and we will endeavor to solve the problem for you.
Privacy of Children
If you have reason to believe that a child under the age of 18 years has provided Personal Information to us through our Website, App, DinarPAY and/or Services, please contact us.
We secure the information you provide to us on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. Company maintains reasonable administrative, technical, and physical safeguards in an effort to protect your information against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that:
(i) there are security and privacy limitations of the Internet which are beyond our control;
(ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Website, App, DinarPAY and/or Services cannot be guaranteed; and
(iii) any such information and data may be viewed or tampered with in transit by a third-party, despite our best efforts.
In the event Company becomes aware that the security of the Website, App, DinarPAY and/or Services has been compromised or Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected users if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law.
Company shall disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that such disclosure is necessary to:
- protect our rights,
- protect your safety or the safety of others,
- investigate fraud, or
- respond to a government request.
You can stop all collection of Personal Information by Company by not accessing the Website, App, DinarPAY and/or Services, or you can also request to opt-out via email, at firstname.lastname@example.org.
Should you have any questions or concerns regarding privacy while using the Website, App, DinarPAY and/or Services, please send us a detailed message to 196, Floor 19, Tower 2, Tripoli Tower, Tripoli, Libya, and we will use our best endeavours to resolve your concerns.
Effective Date: 10 March 2020