ComCach

DATA PROTECTION AND PRIVACY POLICY!!

ComCach is committed to respecting the privacy rights of its customers at all times. This Data Protection and Privacy Policy (the Policy) details how we collect, protect and use the information we receive from customers online from our website visitors and users of our mobile money app. This Policy also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information.

Information collection

We collect information from you when you register on the ComCach Mobile Money App/website; contact our ComCach team through any means including, but not limited to, phone, Interactive Voice Response (IVR), and Secure Message Center, complete a form, enter a contest, respond to a survey or communication such as e-mail, or participate in another website or app feature. When registering or completing a form (secure or otherwise), we may ask you for your name, date of birth, email address, mailing address, ComCach ID, Tax Identification Number (TIN), phone number(s) or other information. We may contact you through any of the means you identified on the form (e.g., phone, mobile phone, e-mail).

When you use the App we will collect, amongst other things, your mobile device’s App Version, Device Type/Model, and Operating System. We also access the device file storage and camera sensor. You can opt out of this at the device level. We may collect the geolocation data from your device.

You may visit the Website and/or use some capabilities within the App anonymously without registering. We may or may not use “cookies” or similar technology to enhance your experience and gather information about visits to the Website or the App. We also receive and store session information, statistical data and other information about visits to the Website and the App. Tracking technologies collect anonymous data about users who interact with our website to help us provide a better user experience through the use of statistics and measurements of ComCach user satisfaction. Please see the section on “Use of Cookies” and online technologies for more information.

We may use the information we collect from you when you register, complete a form, enter a contest or promotion, respond to a survey or marketing communication, use the Website or the App, or use certain other site features in the following ways:

Visitors who register or participate in other features of the Website or the App such as marketing programs and partners’ content may or may not be given a choice as to whether they would like to be placed on our email lists and receive email communications from us. You may opt out of promotional or marketing emails by clicking on the unsubscribe link within any of the promotional or marketing emails that you receive.

We may also obtain information about you from other sources as the law allows and combine that with information, we collect directly from you. For example, we may collect information about you when you post content to our pages or feeds on third-party social media sites. In addition, website users may post comments to blogs. You should be aware that any personally identifiable information you submit there can be read, collected, or used by other users, and could be used to send you unsolicited messages. We are not responsible for personally identifiable information you choose to submit in comments on blogs.

Deletion request rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Information we disclose to nonaffiliated third parties

We do not sell, trade, or otherwise transfer your personally identifiable information to outside parties unless we provide you with advance notice, except as described in this Policy.

We reserve the right to disclose information to our service providers where necessary to facilitate services to you on our behalf. This includes sharing with Monty Mobile Limited and/or Comium the content of any calls you place to the ComCach team for quality assurance and training purposes.

We may share the contact information you provide on our website with our contractors and vendors in order to provide a requested service or transaction (e.g., to send you an e-mail or provide benefits to which you are entitled) subject to our confidentiality policies. We use third-party agents such as financial banking institutions and financial services companies, to fulfill your transactional and payment processing needs made on our websites. These third-party agents provide services for us in compliance with all the legal requirements of operating in this capacity and are authorized to use your shared personal information specifically and exclusively for fulfilling transactions on our behalf. We also may share information about you with nonaffiliates for our own analysis, market research and marketing purposes as permitted by law. Whenever nonaffiliated third parties provide products or services for us or on our behalf, we require them by contract to maintain appropriate safeguards designed to ensure the security and confidentiality of the information that we provide them.

We also may provide information to consumer reporting agencies.

Finally, we may disclose your personal information as otherwise permitted or required by the laws of The Gambia.

Information protection

We take the security of our customer’s information very seriously. We have implemented internal controls and security measures that comply with Gambian laws. These measures include technical, physical, and operational safeguards made to keep your data safe.

Access and opt-out

If your personal information changes, or if you no longer desire our service, you may correct, update, amend, delete or ask to have it removed from a public forum or directory on our site by accessing your account through the App or Website or by contacting us using our provided contact details. We will respond within a reasonable time as may be practicable.

If at any time you would like to stop receiving promotional emails from us, you may opt out of receiving these secondary communications. To opt out of promotional emails, you must select the “Unsubscribe” link present in each promotional email we send out to our customers. You can also unsubscribe by updating your account preferences when you access your personal account information. We reserve the right to send customers transactional and relationship/servicing emails, which are considered a part of your service.

If at any time you would like to change your preferences regarding receipt of text messages on your wireless phone regarding marketing or certain service- and security-related messages, you may update your preferences by responding to any text messages you receive from our systems with the word “STOP,” accessing your account through the app/website, calling our ComCach team on: (+220) ………………………………..).

Policy changes

We may update this Policy to reflect changes to our information security and sharing practices. If we make any material changes, we will notify you by email (sent to the email address specified in your profile) or by means of a notice on our Website and the App prior to the change becoming effective. We encourage you to periodically review our Website and the App for the latest information on our privacy services.

Use of cookies or other online technologies to collect information

When you browse or visit the Website or the App, we may store certain information on your computer or mobile device. This information may be in the form of a small text file called a “cookie” or similar technology and can help us to tailor our sites to your individual preferences and save you time if you visit the Website or the App again. We also store information about your session while you are using the Website or the App to allow you to utilize the Website and App to access your account.

Can I disable or delete cookies?

You can disable cookies by making the appropriate selection from your browser options to inform you when cookies are set or to prevent cookies from being set. However, if you choose to disable or delete cookies, you may limit the functionality we can provide when you visit our Website or App.

Do we track your online activity on the Comium Mobile Money Website/App?

We may use online tracking technologies, such as cookies, to gather anonymous, aggregate information about your visit to the Website or App. This information allows us to measure site activity and to create ideas for improving the Website and App and may include the time and length of your visit, the pages you look at on our site, the website you visited just before coming to ours and your internet service provider. If we provide you with a link from our Website or App to another site, we may track the fact that you clicked the link. This will help us understand which links are helpful to you when you visit our Website or App and will help us provide you with links that may be of interest to you when you visit our Website or App again.

Do we use online behavioural advertising (OBA) on third-party websites?

Yes, we utilize OBA on third-party websites and mobile apps that are not affiliated with us. The third parties with which we contract may use cookies, web beacons, or other technologies for OBA. Neither the third parties nor we collect any personally identifiable information (PII) through these mechanisms. We may also use aggregate data to display ads or content that may be relevant or of interest to you. Examples of aggregate data include but are not limited to, pages visited or keyword searches. Anyone receiving an online behavioural ad may opt out by clicking the third-party website’s Advertising Option icon (Ad Choices) associated with the ad or visiting the third-party website’s privacy policy for an opt-out mechanism, if any.

How do our websites respond to web browser “Do Not Track” signals?

They do not respond to web browser “Do Not Track” signals at this time. To prevent us or third parties from tracking, you can access your browser settings and disable or delete your cookies.

Information about children

We don’t intentionally collect or maintain data about children under 16. Our website is not intended for children under 16.

Blog/Forum

Our Website may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request the removal of your personal information from our blog or community forum, contact us at the number below. In some cases, we may not be able to remove your personal information, such as if you post to a blog, website, or other platform that we do not control, or if we are required by law to retain certain information about your engagement with us. If this is the case, we will let you know if we were unable to remove this information and why.

Social media widgets

Our Website may include Social Media features, such as the Facebook, Twitter and Instagram button and widgets, such as the “Share This” button or interactive mini-programs that run on our sites. These features may collect your IP address, the page you are visiting, and may set a cookie to enable the feature to function properly. Social Media features and widgets are either hosted by a third party or hosted directly on our sites. Your interactions with these features are governed by the privacy policy of the company providing them.

Mobile application

We use mobile analytics software to allow us to better understand the functionality of our App on your phone. This software may record information such as how often you use the App, the events that occur within the App, aggregated usage, performance data, and where the App was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the App.

Nonpublic personal information and former customers

When you are no longer our customer, we may continue to share your information as described in this policy. In addition, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Third-party links

It’s important to know that our Website and the App may contain links to third-party websites not controlled by us or covered by this online privacy policy. We recommend that you check the privacy statements of other sites you visit before providing any personal information.

Questions and feedback

We welcome your questions, comments, and concerns about privacy. Please send us any and all feedback pertaining to privacy or any other issue by contacting our team on the following: privacy@comcach.com

Your consent

By using our App or Website you consent to the terms of this Policy.

Additional information

Privacy notices are accurate as of the date they are provided to you and supersede all previously issued confidentiality and information-sharing disclosures. We reserve the right to change these notices and any of the practices described in these notices at any time upon proper notice to you as described above.

If you believe that we have not complied with this policy, you may contact us on: privacy@comcach.com