PRIVACY POLICY
Date: June
2022
Zawadi, a product of Financial Inclusion (Africa) Limited, Registration Number 13683719of Building 18, Gateway 1000, Whittle Way, Arlington Business Park, Stevenae, Hertfordshire, SG1 2FP(hereafter referred to as “Zawadi”, “we”, us” “our”) recognises the importance of protecting your privacy in respect of your Personal Information collected by us when you use our website, digital app and/or our services.
For purposes of this Privacy Policy:
"Personal Information" means any information about you as defined in the Protection of Personal Information Act 4 of 2013;
"Process" means the collection, recording, organisation, storage, updating or modification, retrieval, consultation, use, dissemination, distribution or making available in any form, merging, linking, blocking, erasure or destruction of information.
"Zawadi App" means the proprietary digital application owned and/or licensed to Zawadi and which enables registered users to access Zawadi Content and share Personal Information to selected Brands in return for rewards, as well as such other functionalities as may be made available from time to time.
"Zawadi Content" means any information, data, opinions, images, documents, text, features or other materials that Zawadi makes available on the Zawadi App for whatever purpose, but specifically excluding user content.
By accessing or using our Zawadi App or any of our services, you consent to the data practices as described in this Privacy Policy and you acknowledge that you have read, understood and you agree to be bound by both our Zawadi App Terms and Conditions as well as this Privacy Policy.
At Zawadi, we take data privacy very seriously; we understand the importance of protecting and respecting your personal data. This Privacy Policy describes the information we collect, how use that information, who we pass the information onto, your rights as well as key contact information.
To enable you to use the Zawadi App and for you to earn rewards, we need to collect information about you. Any information we receive about you will be subject to strict controls. These strict controls minimise the risk of misuse, unauthorised access to, or disclosure of your personal data.
This Privacy Policy applies to your access to and/or use of the Zawai App. It forms part of our agreement with you; read it together with our Zawadi App Terms and Conditions and any other applicable documents referred to.
When we use the term “includes”, “including”, “such as”, “following” and “in particular” please interpret these terms, without limitation.
By visiting and/or using the Zawadi App you accept and expressly consent to our use and disclosure of your Personal Information and direct us to do so in the manner described in this Privacy Policy.
This includes consenting to the lawful processing of any sensitive personal information you provide, as described below in section 4. It also includes information you provide when you register on the Zawadi App, complete a survey on the Zawadi App, request to be contacted, enter a competition or promotion and when you contact us for any other reason.
If you have any concerns about the terms of this Privacy Policy, please contact us by sending a message via the Zawadi App. Click on the “more” icon on the bottom panel of the screen then click on “Report an issue”.
A special note about children
Children are not eligible to use the Zawadi App. We respectfully ask that minors (persons under the age of 18) do not submit any information to us or use the Zawadi App in any way.
The type of information we may collect about you:
Information you supply to us willingly: The type of information we may collect from you includes your name and surname, e-mail address, demographic information such as your location, postcode and telephone number (which includes mobile number), answers to security questions, year of birth, gender, race, type of house, level of education, whether you are employed, monthly income, details about your family life, shopping habits, religion, whether you own a car, funeral policy, computer or pet or related items and selected other personal habits and hobbies.
Information collected automatically from your mobile device: We may collect information that is sent to us automatically by your mobile device. This information typically includes details about your mobile device, operating system, local time zone, date and time of each visit.
Aggregate Information: We may aggregate and/or anonymize and/or pseudonymize all information that we collect from you. This may be done for the purpose of market research and improving our service.
The lawful basis we rely on for processing this information are:
Your consent. You may withdraw your consent at any time. Keep in mind though that if you withdraw your consent, we may not be able to provide you with access to the Zawadi App and/or benefits and rewards. We may also be legally required to keep certain information you have given us on the basis of consent.
We have a contractual obligation.
We have a public interest.
We have a legitimate interest.
We have a legal obligation.
Sensitive or Special data
Data privacy regulations prohibit the processing of ‘special categories of personal data’, also called ‘sensitive data’ unless you have given your consent or if there is another lawful basis for us to collect and process that information.
Sensitive data includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning health, sex life or sexual orientation. There are also restrictions on processing of criminal convictions and offences.
If you complete surveys on the Zawadi App, you may be asked to reveal some sensitive data such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health, sex life or sexual orientation.
If you yourself reveal sensitive data to us via the Zawadi App, you will be giving express consent for us to process that information. You further understand that your sensitive data will be made available, in anonymized form, to brand owners and/or marketing agencies listed on the Zawadi App.
By submitting your information to us and using the Zawadi App you agree that we may use your information for the following purposes:
Fulfilling your requests
We will use your information to:
provide you with the information, products and services that you request from us;
complete any transaction you are undertaking with us;
verify your information;
administer any promotion, survey or competition that you enter.
Compliance and risk management
We may use your information for security, administrative or legal purposes, for example combatting fraud, ensuring network and information security and for internal administrative purposes.
Communication and customer service
We may process your information in relation to:
responding to requests for customer service;
confirming information concerning a user's identity or account activity;
informing users if we believe their accounts or any of their transactions have been used for an illegitimate purpose;
resolving customer complaints;
conducting customer surveys; and
investigating suspicious transactions.
We use your email address to:
confirm your registration as a Zawadi customer;
Users cannot opt out of these communications, but they will be primarily service-oriented rather than promotional.
Because we are obligated to send these communications to current customers, if you do not want to receive these communications at all, then unfortunately you must close your account. If you want to change the way in which you receive them, please contact us, and advise us of your preferred communication method.
We will also use your personal information to send you information about important changes to our products and services, including notice of any times that our services may not be available. If you want to use the Zawadi App you should reasonably expect to receive these communications as they are necessary and a proportionate means of communicating important information with customers and are therefore in our legitimate interests to send them.
Marketing
We also use the Zawadi App to send you other types of communications that you can control, including newsletters, customer surveys and special promotions. These communications are to:
provide you with information about services we offer that are similar to those that you have already enquired about or purchased;
provide marketing and advertising messages, updates on the services we offer, and promotional offers based on your activities when using the Zawadi App;
measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, which may be based on your activity on the Zawadi App;
make suggestions and recommendations to you and other users of our Zawadi App about services that may interest you or them, which may be based on your activity on our Zawadi App;
tell you about new products and features we are developing that you may find useful.
You can choose whether to receive some, all or none of these communications and the methods by which you receive them during the registration process (or thereafter) by sending an email to unsubscribe@zawadi.life
Service improvements and account management
We will use your information to deliver and improve the Zawadi App and manage your account, including:
verifying your identity, including during account creation and password reset processes;
validating the accuracy of information, and possibly verifying it with third parties;
resolving disputes, collecting fees and troubleshooting problems;
allowing us to manage risk and to detect, prevent, and/or remediate fraud or other illegal or prohibited activities;
detecting, preventing or remediating violations of any of our policies or other user agreements;
providing you with customer support services including notifying you of changes to our service, including any outages, and to send you notifications relating to your account and transactions on your account;
improving our existing, and developing new, products, services, Channels, apps and capabilities;
administering our customer and transaction systems and for internal business administration and operations purposes, including storage, backup, archiving, troubleshooting, data analysis, testing, research, statistical and survey purposes; and
as part of our efforts to keep our site safe and secure, including managing and protecting our information technology infrastructure.
Device information and Location information / IP (Internet Protocol) address
We will use this information to:
administer our Zawadi App for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
improve our Zawadi App to ensure that content is presented in the most effective manner for you and for your device;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our Zawadi App safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our Zawadi about goods or services that may interest you or them;
to verify your identity, protect against fraud, comply with anti-financial crime laws and to confirm your eligibility to use our products and services; and
to comply with our regulatory obligations.
Questionnaires, surveys, competitions, and profile data
From time to time we may offer you optional questionnaires, surveys and competitions. If you choose to answer these questionnaires, surveys or competitions, we may use your information to improve the Zawadi App, manage the competitions and for such purposes as collecting demographic information or assessing users' interests and needs. You also understand that the personal information you provide will be anonymized and shared with brand owners and marketing agencies listed on the Zawadi App for their research and marketing efforts.
Accessing and changing your information
You can review the information you have provided to us and make any desired changes to your information or to the settings by accessing the identity profile in the Zawadi App. Select the picture icon on the top right corner of the screen, then choose “identity profile”. To make changes, click on the lock icon.
We do not obtain information about you through the use of "cookies" on your devices. We will notify you in the future prior to installing and using cookies for data collection purposes.
We make use of third-party analytics services on the Zawadi App. The analytics services are provided by Advance Guidance. For more information see: https://www.advanceguidance.com/.
Your privacy is important to us, which is why it is our policy not to share your personal information with other companies without your consent. In particular, we will never sell your personal information. We will not provide any of your information to entities outside of Zawadi so as to permit them to market their goods or services to you.
You agree that we may transfer your information to the following people and organisations in order to process your data as set out in this policy:
We share your personal information with companies that help us to provide our Zawadi App and services to you and who have agreed to keep your information secure and to only use it for authorised purposes.
We use suppliers or service providers, freelancers, business consultants, companies or other external entities in their capacity as independent data processors who we trust to provide services to us and sometimes that involves sharing your information with them. They operate under strict requirements aimed at keeping your personal information secure and confidential and they will only use it for the purpose for which we have sent it to them.
We share anonymized versions of the personal information you provide to us on the Zawadi App with brand owners and marketing agencies listed on the Zawadi App that they are then able to use for their own research and marketing efforts. We will not share non-anonymized versions of your personal information with such parties without your consent.
To governmental, judicial, regulatory and law enforcement bodies and agencies, including any credit regulator.
To bodies aimed at anti-fraud, anti-money laundering, sanctions and risk management.
Mergers and acquisitions
We may disclose your information to the prospective seller or buyer of such business or assets, along with its professional advisers. If Zawadi or a substantial proportion of its assets are acquired by a third party, information held by us about our customers will be one of the transferred assets, and such successor company would continue to be bound by this Privacy Policy unless and until it is amended.
Analytics and search engine providers
We may share your IP address with analytics and search engine providers that assist us in the improvement and optimisation of our site, and for 3rd party advertising on 3rd party websites.
Where required by any other applicable law.
By accepting this Privacy Policy and maintaining an account with Zawadi, you expressly consent to the transfer of your data to those third parties.
Third party websites
Any information that you enter on a third-party website or application (and not directly through the Zawadi App) may be shared with the owner of any such third party website.
Please note that these websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any information to third party websites.
Zawadi is committed to adequately protecting your information regardless of where the data resides and to providing appropriate protection for your information where such data is transferred overseas.
The information that we collect from you may be transferred to, and stored in, a country overseas or over border. Data stored by us will be stored in secure servers in South Africa and the United States of America.
By submitting your information and making use of the Zawadi App, you agree to such transfers, storing or processing. We will take all steps reasonably necessary and legally required to ensure that your information is treated securely and in accordance with this Privacy Policy.
We will do our best to protect your information, however we cannot guarantee the security of your information transmitted to our App or sent to us by email or other non-secure electronic methods; any such transmission is at your own risk. Once we have received your information, we will use protective procedures and security features to try to prevent unauthorised access.
We will keep your Personal Information for only as long as is necessary for achieving the purpose for which it was collected or subsequently Processed, unless:
Law. we are required or authorized by law to keep your Personal Information for a longer period;
Lawful purposes. we require the Personal Information for lawful purposes relating to our functions or activities;
Legal rights. we require the Personal Information to exercise or defend our legal rights;
Statistics. we require the Personal Information for historical, statistical or research purposes (such information will be anonymized); or
Contractual. the Personal Information is required as a result of our contract with you.
Upon completion of our obligations in relation to processing your Personal Data under this Agreement, or upon your request at any time during the term of this Agreement, and if no ground exists supporting the retention of your Personal Data, we will either:
render all or part of the Personal Data anonymous or encrypted in such a manner that the data no longer constitutes personal data, in compliance with applicable law; or
permanently delete or render all or parts of the Personal Data unreadable.
If you have asked us not to contact you for marketing purposes, we will retain that information on a ‘do not contact’ list to reduce the risk of us contacting you in the future. Please note though that you cannot opt out of communications regarding your transactions and account.
Zawadi has security measures in place designed to prevent data loss, to preserve data integrity, and to control access to the data. Only persons authorised and our business partners processing data on our behalf have access to your Personal Information. All Zawadi employees who have access to your personal data are required to comply with our Privacy Policy. All business partners are requested by Zawadi to ensure that any of their employees who have access to your Personal Information are bound by confidentiality and data protection rules which offer the same level of protection. Contracts with business partners acting as data processors for Zawadi involving Personal Information require an adequate level of security and require that Personal Information is processed only as instructed by Zawadi.
System security and monitoring
To provide a secure environment for our Zawadi App, we utilise leading cloud hosting environments which are compliant with industry recognised security standards. This ensures high physical and technical security levels.
Password security
To help us protect your information, where the Zawadi App requires a username and password, we recommend you do the following:
Do not choose a password that could be easily guessed or is known by another person.
Avoid using personal information such as your name, birth date or telephone number, or ordinary words found in a dictionary.
Memorise your password - do not write it down.
Never reveal the password to anyone else. We will never ask you for your password and you should not disclose it to anyone claiming to work for us or our business partners.
Do not use the same password on other services.
Customer responsibilities
We keep our security technology up-to-date to protect your information, but we do not have control over the devices you use to access the Zawadi App.
It is your responsibility to safeguard your online information and transactions by taking all reasonable measures which may include the following:
Do not share your information or provide any opportunities for anyone to gain access to your information through your devices, including tablets, phones, watches, or laptops.
Do not share your login details with any other person and never share your login details with a Zawadi employee or agent for any reason.
Ensure that you use the latest version of your internet browser and that you have up-to-date anti-virus, firewall and other security software installed on your device.
You have the following rights:
To ask us to correct any information we hold about you if it is incorrect.
We will try to keep your information accurate, but we welcome your corrections. You can correct your profile at any time by going to your "Identity Profile" and clicking on the "lock" at the top of the page We may ask you for additional verification information if you are changing certain details such as your name or your address.
To ask us to erase your information if we no longer have any reason to hold it, also known as the ‘right to be forgotten’.
Our Data Retention Policy (see section 9 regarding data retention above) explains the circumstances when we can or are obliged to retain information. Outside of those periods we will delete your information in line with our Data Retention Policy and on request.
To ask us not to process your information where you previously gave consent or where we are exercising our legitimate interest.
If you make a request for us to stop processing your information, we will investigate to see if there is a compelling reason for processing to continue and will discuss the conclusion of the investigation with you.
You cannot object to processing which is a legal obligation or where we must process your information to satisfy a contract to which you are a party. If you previously gave consent and we processed your data on the basis of that consent, you cannot object to that past processing, however you can ask us to stop processing it in the future. You also understand that depending on the Personal Information being deleted, we may no longer be able to make the Zawadi App available to you.
To ask for a copy of the information we hold about you.
We will endeavour to respond to your request within 30 days, however at time of high demand we may need 90 days to compile a full response.
To ask us not to process your information for marketing purposes.
You can do this by contacting us at unsubscribe@zawadi.life
You may exercise any of the above rights by contacting us at unsubscribe@zawadi.life
The Responsible Party
The Responsible Party is Financial Inclusion (Africa) Limited a company incorporated under the laws of the United Kingdom with Registration Number 13683719, having its registered office at Building 18, Gateway 1000, Whittle Way, Arlington Business Park, Stevenage, Hertfordshire, SG1 2FP.
Contacting us with questions or requests
If you want to exercise your right to access your information or have any questions about this Privacy Policy, Zawadi’s information practices, or your dealings with Zawadi, you can contact us bysending a message via the Zawadi App. Click on the “more” icon on the bottom panel of the screen then click on “Report an issue”.
Complaints to the Information Regulator
You have the right to complain to the Information Regulator in the prescribed manner and form if you believe we have not handled your request in an appropriate manner. For information on contacting the SA Information Regulator please see their website.
We may amend this Privacy Policy at any time, as new features are added to the Zawadi App or as we incorporate suggestions from our customers. Any changes we may make will be posted on the Zawadi App so please check back frequently.
Your continued use of our Zawadi App after a posting of a new version of this Privacy Policy will constitute your acceptance of, and agreement to, any changes. If you disagree with the terms of this Privacy Policy, you may close your account at any time.