5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and
other tracking technologies to collect and store your information.
We may use
cookies and similar tracking technologies (like web beacons and pixels) to gather information
when you interact with our Services. Some online tracking technologies help us maintain the
security of our Services and your account, prevent crashes, fix bugs, save your preferences,
and assist with basic site functions.
We also
permit third parties and service providers to use online tracking technologies on our Services
for analytics and advertising, including to help manage and display advertisements, to tailor
advertisements to your interests, or to send abandoned shopping cart reminders (depending on
your communication preferences). The third parties and service providers use their technology
to provide advertising about products and services tailored to your interests which may appear
either on our Services or on other websites.
To
the extent these online tracking technologies are deemed to be a
"sale"/"sharing" (which includes targeted
advertising, as defined under the applicable laws) under applicable US state laws, you can opt
out of these online tracking technologies by submitting a request as described below under
section "
DO UNITED STATES RESIDENTS
HAVE SPECIFIC PRIVACY RIGHTS?
"
Specific
information about how we use such technologies and how you can refuse certain cookies is set
out in our Cookie Notice
.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information
for as long as necessary to fulfill the purposes outlined in this Privacy Notice
unless otherwise required by law.
We will
only keep your personal information for as long as it is necessary for the purposes set out in
this Privacy Notice, unless a longer retention period is required or permitted by law (such as
tax, accounting, or other legal requirements). No purpose
in this notice will require us keeping your personal information for longer than
the period of time in which users have an account with us
.
When we
have no ongoing legitimate business need to process your personal information, we will either
delete or anonymize
such information, or, if this is not possible (for example, because your personal
information has been stored in backup archives), then we will securely store your personal
information and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your
personal information through a system of organizational
and technical security
measures.
We have
implemented appropriate and reasonable technical and
organizational security measures designed to
protect the security of any personal information we process. However, despite our safeguards
and efforts to secure your information, no electronic transmission over the Internet or
information storage technology can be guaranteed to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or other
unauthorized third parties will not be able to
defeat our security and improperly collect, access, steal, or modify your information.
Although we will do our best to protect your personal information, transmission of personal
information to and from our Services is at your own risk. You should only access the Services
within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly
collect data from or market to children under 18 years of
age.
We do not
knowingly collect, solicit data from, or market to children under 18 years of age, nor do we
knowingly sell such personal information. By using the Services, you represent that you are at
least 18 or that you are the parent or guardian of such a minor and consent to such minor
dependent’s use of the Services. If we learn that personal information from users less than 18
years of age has been collected, we will deactivate the account and take reasonable measures
to promptly delete such data from our records. If you become aware of any data we may have
collected from children under age 18, please contact us at
bctsdev@gmail.com
.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short:
Depending on your state of residence in the US or in some regions, such as the
European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and
control over your personal information.
You may review, change, or terminate your account at any
time, depending on your country, province, or state of residence.
In some
regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection
laws. These may include the right (i) to request access and obtain a copy of your personal
information, (ii) to request rectification or erasure; (iii) to restrict the processing of
your personal information; (iv) if applicable, to data portability; and (v) not to be subject
to automated decision-making. In certain circumstances, you may also have the right to object
to the processing of your personal information. You can make such a request by contacting us
by using the contact details provided in the section "HOW CAN
YOU CONTACT US ABOUT THIS NOTICE?
" below.
We will
consider and act upon any request in accordance with applicable data protection laws.
Withdrawing your consent: If we are
relying on your consent to process your personal information,
which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any
time. You can withdraw your consent at any time by contacting us by using the contact details
provided in the section "HOW CAN
YOU CONTACT US ABOUT THIS NOTICE?
" below or updating your preferences.
However, please note that this will not affect the lawfulness of
the processing before its withdrawal nor, when applicable law
allows, will it affect the processing of your
personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional
communications: You can unsubscribe from our marketing and
promotional communications at any time by
replying "STOP" or
"UNSUBSCRIBE" to the SMS messages that we send,
or by contacting us using the details provided in the
section "
HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?
" below. You
will then be removed from the marketing lists. However, we may still communicate with you — for
example, to send you service-related messages that are necessary for the administration and use
of your account, to respond to service requests, or for other non-marketing purposes.
No
mobile information will be shared with third parties or affiliates for marketing or promotional
purposes. Information sharing to subcontractors in support services, such as customer service,
is permitted. All other use case categories exclude text messaging originator opt-in data and
consent; this information will not be shared with third parties.
Account Information
If you
would at any time like to review or change the information in your account or terminate your
account, you can:
-
Contact us using the contact information provided.
Upon
your request to terminate your account, we will deactivate or delete your account and
information from our active databases. However, we may retain some information in our files to
prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms
and/or comply with applicable legal requirements.
If
you have questions or comments about your privacy rights, you may email us at info@belcash.com.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web
browsers and some mobile operating systems and mobile applications include a Do-Not-Track (
"DNT")
feature or setting you can activate to signal your privacy preference not to have data about
your online browsing activities monitored and collected. At this stage, no uniform technology
standard for recognizing and implementing DNT signals has been finalized. As
such, we do not currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a standard for online
tracking is adopted that we must follow in the future, we will inform you about that practice
in a revised version of this Privacy Notice.
California law requires us to let you know how we respond to web
browser DNT signals. Because there currently is not an industry or legal standard for recognizing or
honoring DNT
signals, we do not respond to them at this time.
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of
California, Colorado, Connecticut, Delaware, Florida,
Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey,
Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you
may have the right to request access to and receive details about the personal information
we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or
delete your personal information. You may also have the right to withdraw your consent to
our processing of your personal information. These rights may be limited in some
circumstances by applicable law. More information is provided
below.
Categories of Personal Information We Collect
The table below shows the categories of
personal information we have collected in the past twelve (12) months. The table includes
illustrative examples of each category and does not reflect the personal information we
collect from you. For a comprehensive inventory of all personal information we process, please
refer to the section "WHAT INFORMATION DO WE
COLLECT?
"
|
Category |
Examples |
Collected |
|
A.
Identifiers
|
Contact details, such as real name, alias, postal
address, telephone or mobile contact number, unique personal identifier, online
identifier, Internet Protocol address, email address, and account
name
|
YES
|
|
B.
Personal information as defined in the California Customer Records
statute
|
Name, contact information, education, employment,
employment history, and financial information
|
YES
|
|
C. Protected
classification characteristics under state or federal law
|
Gender, age, date of birth, race and ethnicity, national
origin, marital status, and other demographic data
|
YES
|
|
D. Commercial
information
|
Transaction information, purchase history, financial
details, and payment information
|
NO
|
|
E. Biometric
information
|
Fingerprints and voiceprints
|
NO
|
|
F. Internet or other
similar network activity
|
Browsing history, search history, online behavior
, interest data, and interactions with our and other websites, applications, systems,
and advertisements
|
NO
|
|
G. Geolocation data
|
Device location
|
YES
|
|
H. Audio, electronic,
sensory, or similar information
|
Images and audio, video or call recordings created in
connection with our business activities
|
NO
|
|
I. Professional or
employment-related information
|
Business contact details in order to provide you our
Services at a business level or job title, work history, and professional
qualifications if you apply for a job with us
|
NO
|
|
J. Education
Information
|
Student records and directory
information
|
NO
|
|
K. Inferences drawn
from collected personal information
|
Inferences drawn from any of the collected personal
information listed above to create a profile or summary about, for example, an
individual’s preferences and characteristics
|
YES
|
|
L. Sensitive personal
Information
|
Account login information
, citizenship or immigration status
, drivers' licenses
, passport numbers
, precise geolocation
, state id card numbers
and sex life or sexual orientation
|
YES
|
We
only collect sensitive personal information, as defined by applicable privacy laws or the
purposes allowed by law or with your consent. Sensitive personal information may be used, or
disclosed to a service provider or contractor, for additional, specified purposes. You may have
the right to limit the use or disclosure of your sensitive personal information.
We
may also collect other personal information outside of these categories through instances where
you interact with us in person, online, or by phone or mail in the context of:
- Receiving
help through our customer support channels;
- Participation in customer surveys
or contests; and
- Facilitation in the delivery of our
Services and to respond to your inquiries.
We will use and retain the collected personal information as needed
to provide the Services or for:
- Category A - As long as the user has an
account with us
- Category B - As long as the user has an
account with us
- Category C - As long as the user has an account with us
- Category G - As long as the user has an account
with us
- Category K - As long as the user has an
account with us
- Category L - As long as the user has an
account with us
Will your information be shared with anyone
else?
We may use your personal information for our own
business purposes, such as for undertaking internal research for technological
development and demonstration. This is not considered to be "selling"
of your personal information.
We have not disclosed, sold, or shared any personal
information to third parties for a business or commercial purpose in the preceding
twelve (12) months. We will not sell
or share personal information in the future belonging to website visitors, users,
and other consumers.
Your Rights
You have rights under certain US
state data protection laws. However, these rights are not absolute, and in certain
cases, we may decline your request as permitted by law. These rights include:
- Right to know whether or not we are
processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your
personal data
- Right to request the deletion of your
personal data
- Right to obtain a copy of the personal
data you previously shared with us
- Right to non-discrimination for exercising
your rights
- Right to opt out of the processing of your
personal data if it is used for targeted advertising
(or sharing as defined under California’s privacy law), the sale of personal data, or profiling
in furtherance of decisions that produce legal or similarly significant effects (
"profiling")
Depending upon the state where you live, you may also
have the following rights:
- Right to access the categories of personal data being
processed (as permitted by applicable law, including the privacy law in Minnesota)
- Right to obtain a list of the categories of third parties
to which we have disclosed personal data (as permitted by applicable law, including
the privacy law in California, Delaware, and
Maryland
)
- Right to obtain a list of specific third parties to which
we have disclosed personal data (as permitted by applicable law, including the
privacy law in Minnesota and Oregon)
- Right to review, understand, question, and correct how
personal data has been profiled (as permitted by applicable law, including the
privacy law in Minnesota)
- Right to limit use and disclosure of sensitive personal
data (as permitted by applicable law, including the privacy law in
California)
- Right to opt out of the collection of sensitive data and
personal data collected through the operation of a voice or facial recognition
feature (as permitted by applicable law, including the privacy law in
Florida)
How to Exercise Your Rights
To exercise these rights, you can contact us by submitting a data subject access
request,
by emailing us at
bctsdev@gmail.com,
or by referring to the contact details at the bottom of
this document.
Under certain US state data protection laws, you can
designate an authorized agent to make a request on your behalf.
We may deny a request from an authorized agent that does not submit proof that
they have been validly authorized to act on your behalf in accordance with
applicable laws.
Request Verification
Upon receiving your request, we
will need to verify your identity to determine you are the same person about whom we
have the information in our system. We will only use personal information provided
in your request to verify your identity or authority to make the request. However,
if we cannot verify your identity from the information already maintained by us, we
may request that you provide additional information for the purposes of verifying
your identity and for security or fraud-prevention purposes.
If you submit the request through an authorized
agent, we may need to collect additional information to verify your identity
before processing your request and the agent will need to provide a written and
signed permission from you to submit such request on your behalf.
Appeals
Under certain US state data
protection laws, if we decline to take action regarding your request, you may appeal
our decision by emailing us at
info@belcash.com
. We will inform you in writing of any action taken or
not taken in response to the appeal, including a written explanation of the reasons
for the decisions. If your appeal is denied, you may submit a complaint to your
state attorney general.
California "Shine The Light" Law
California Civil Code Section
1798.83, also known as the "Shine The Light" law, permits our users who are
California residents to request and obtain from us, once a year and free of charge,
information about categories of personal information (if any) we disclosed to third
parties for direct marketing purposes and the names and addresses of all third
parties with which we shared personal information in the immediately preceding
calendar year. If you are a California resident and would like to make such a
request, please submit your request in writing to us by using the contact details
provided in the section "HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?
"
12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have additional rights based on the country
you reside in.
Australia
and
New Zealand
We collect and process your personal information under
the obligations and conditions set by Australia's
Privacy Act 1988
and
New Zealand's Privacy Act 2020 (Privacy Act).
This Privacy Notice satisfies the notice requirements
defined in both Privacy Acts, in particular: what personal information we
collect from you, from which sources, for which purposes, and other recipients of
your personal information.
If you do not wish to provide the personal information
necessary to fulfill their applicable purpose, it may affect
our ability to provide our services, in particular:
- offer you the products
or services that you want
- respond to or help with
your requests
- manage your account
with us
- confirm your identity
and protect your account
If you are unsatisfied with the manner in which we
address any complaint with regard to our processing of personal information, you can
contact the office of the regulator, the details of which are:
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update
this notice as necessary to stay compliant with relevant
laws.
We may update this Privacy Notice from time to time.
The updated version will be indicated by an updated
"Revised" date at the top of
this Privacy Notice. If we make material changes to this Privacy Notice, we may
notify you either by prominently posting a notice of such changes or by directly
sending you a notification. We encourage you to review this Privacy Notice
frequently to be informed of how we are protecting your
information.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice,
you may
email us at bctsdev@gmail.com or
contact us by post
at:
Belcash Technology Solutions PLC
47 Queen Elizabeth, Addis Ababa, Ethiopia
Addis Ababa
, Addis Ababa
1000
Ethiopia
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?
Based on the applicable laws of your country
or state of residence in the US, you may
have the right to request access to the personal
information we collect from you, details about how we have processed it,
correct inaccuracies, or delete your personal information. You may also have
the right to withdraw your consent to our
processing of your personal information. These rights may be limited in some
circumstances by applicable law. To request to review, update, or delete your
personal information, please fill out and
submit a
data subject access
request
.