ClickSendNow (Pty) Ltd - Privacy Notice

1. Introduction

The right to privacy is an integral human right recognised and protected in the South African Constitution and the Protection of Personal Information Act 4 of 2013 (“POPIA”). POPIA aims to promote the protection of privacy by providing guiding principles that are intended to be applied to the processing of personal information in a context-sensitive manner.

Through the provision of quality services, the organisation is necessarily involved in the collection, use, and disclosure of certain aspects of the personal information of clients, employees, service providers, and other stakeholders.

This privacy notice aims to demonstrate our commitment to safeguarding your personal information and to notify you how and why we collect information from you, the way we use your information, and how we share or disclose your information, as required in terms of the Protection of Personal Information Act (“POPI Act”).

This Notice provides you with the following information:

An overview of ClickSendNow;

Our commitment to compliance;

A Summary of the compliance measures implemented;
A notification on the collection of personal information and how we use the information;
Your rights as a data subject;
How to contact us about this notice.

2. Overview Of Clicksendnow

ClickSendNow is a provider of digital wallets, e-money, and payment ecosystems. Clicksendnow operates its remittance service as an Authorised Dealer with Limited Authority (Category 3), authorized by the South African Reserve Bank to conduct cross-border remittance and payment services.

ClickSendNow has developed this privacy notice for our clients, services providers, employees, applicants for employment, and any other data subject to understand our commitment to compliance with the POPI provisions and how and why we collect, use, disclose, and safeguards their personal information.

3. Privacy Statement

ClickSendNow respects your right to privacy and is committed to safeguarding your personal information when processing your personal information in terms of the Protection of Personal Information Act (POPIA)

This privacy statement applies to natural and juristic persons whose personal information is processed by ClickSendNow, including potential clients, existing clients, services providers, and applicants for employment. In instances where ClickSendNow processes personal information as an operator for a responsible party in terms of a contract or mandate, we encourage you to read and understand that particular responsible party’s privacy notice.

Our privacy statement outlines our policy surrounding the protection and processing of your personal information and our commitment to comply with the conditions set out in the Protection of Personal Information Act (POPIA) when collecting, recording, storing, disseminating, and destroying personal information, and responding to government requests for our data subjects:

In our capacity as the responsible party, we shall inform you that we shall be processing personal information, the purpose or reasons for the collection of personal information and we shall endeavour to obtain information directly from you upon your consent or if we can demonstrate a justifiable reason for collecting personal information;
We shall process information for a specific, lawful reason and only adequate, relevant information which is limited to the purposes for which they are processed and which relates to the functions or the activity for which it is intended;
We shall delete or otherwise de-identify your personal information after the minimum storage periods required under our risk and statutory record-keeping periods have expired.
We shall take reasonable steps to ensure personal information obtained from our data subjects or third parties is complete, accurate, not misleading, and updated where necessary.
We take measures to ensure data is kept safe and prevent loss of, damage to, or unauthorized destruction of personal information, and unlawful access to or processing of personal information.
We undertake to review and update our security measures in accordance with future legislation and technological advances.
ClickSendNow is obligated to inform the Information Regulator and the affected data subject if there is a breach of personal information. We shall aim to assist in minimising any losses that may result from such a breach in security.
We shall not contact/solicit you unless you have given us your consent to do so;
We shall implement the necessary measures that will give effect to your rights as a data subject as provided in terms of POPIA.

4. Notification Of Personal Information Collected And Processing Activities

This notification applies to natural and juristic persons (which includes) potential clients, existing clients, services providers, and applicants for employment whose personal information is processed by the group in its capacity as a responsible party.

1. Information being collected

The type of personal information and special personal information we collect depends on the purpose and reason for which it is processed and relates to the functions or the activity for which it is intended.

Personal information is information that identifies a person, examples of personal information we collect are; your full name, ID number, date of birth; contact details; information surrounding your personal circumstances such as your race, gender, nationality, marital status, medical and financial history. Juristic persons may be identified by their registered or trade name, registration numbers, and business addresses. ClickSendNow may also collect information such as tax numbers, VAT numbers, and bank account details. ClickSendNow only collects special personal information and personal information of a child if it is necessary for the performance of the client engagement or required by law.

The following information is created and recorded automatically when you visit our website: IP address, the country from which you access information, pages visited, browser, operating system and platform information, information about your visit, and your behavior on our Website.

While using demo mobile apps and portals we kindly request users not to upload sensitive information except their phone number, email, and name. The following information is created and recorded automatically when you use our mobile apps: IP address, the country from which you access information, operating system, and device information, information about your visit, and your behavior within demo apps. To show some features of the demo app it may request the following:

access to contact book for demo P2P transfer by phone number;
access to photos and access to the camera for demo onboarding scenario and demo P2P and P2M transfers using QR code;
access to push notifications for demo notifications about events happening with user profile, such as access to biometric authentication functions of devices for demo authentication scenarios.

ClickSendNow shall only process personal in a lawful manner and based on-

Having consent from the data subject;
or for legitimate and justifiable reasons as provided for in the POPI Act.

2. Methods of collection

ClickSendNow collects personal information in several ways which include but are not limited to:

Online submission through our site or mobile application;
Correspondence via e-mail;
Whatsapp; and
Phone calls.

ClickSendNow collects information directly from you where you provide us with your details or if personal information is available in public records. In addition to the aforementioned, we may obtain information from third parties subject to your consent.

The personal information provided by you may be processed by ClickSendNow to ensure efficient interaction with ClickSendNow. Such information is processed, stored, and retained through ClickSendNow’s shared data technology platform.

3. Purpose of collection and use of personal information

ClickSendNow shall collect personal information for a specific, explicitly defined, and lawful purpose that relates to the function or the activity of our organisation for which it was intended. If ClickSendNow wants to process the personal information further or for additional purposes, it must be compatible or in line with the purpose for which it was collected.

The information collected by ClickSendNow may be used, transferred, stored, disseminated, shared, or processed for the following purposes:

Potential clients and existing clients:

To provide services to our clients and to carry out our responsibilities in terms of the engagement with the client;
To communicate and manage our relationship with you;
To enhance our apps and portals;
To respond to enquiries and complaints from clients;
To detect and prevent fraud, crime and money laundering, and other forms of malpractice;
To perform an analysis of the locations from which visitors access our website
For record-keeping purposes;
To protect and enforce ClickSendNow’s rights and remedies in terms of legislation and governing law;
Provide regulatory updates and newsletters;
To analyse complaints and suggestions from clients for services delivery;
To comply with legal obligations.

Service providers:

Obtain quotes and services proposal for the delivery of services;

For processing payments of invoices;

Liaising with the service provider on the services to be rendered in terms of the services level agreement.
Applicants for employment:
To determine whether the application is suitable for the position applied.

Employees:

To maintain the employer and employee relationship;
Comply with obligations imposed on the employer in terms of the South African conditions of employment legislation framework;
Administration of employee benefits;
Administration and submission of statutory submission and payments such as tax, UIF, etc;
Payment of salaries;
Resolving labour disputes.

4. Particular law authorising or requiring collection and other processing activities

ClickSendNow may process information to comply with legislative requirements which include:

Compliance with regulatory and legislative requirements such as FICA, BCEA, etc.;

Compliance with reporting requirements;
Record-keeping requirements;
Prevention of money laundering, terrorist financing, fraud, corruption, tax evasions, and other crimes;

5. Cookies

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. ClickSendNow sets cookies to help identify and track visitors, their usage of ClickSendNow ’s service, and their website access preferences. ClickSendNow visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using ClickSendNow ’s website, with the drawback that some features of ClickSendNow ’s websites may not function properly without the aid of cookies.

Kindly note:

1. Should you leave a comment on our site you may opt-in to saving your name, email address, and website in cookies. These are for your convenience and these cookies will last for one year.

2. Should you visit our login page, we will set a temporary cookie to determine whether your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

3. When you log in, we will set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for one year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

4. Should you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. This expires after one day (24 hours).

5. Embedded content from other websites:

Articles on our site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

6. Comments and Contact Form

Should visitors leave comments on the site, we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to ensure spam detection. Visitor comments and Contact Form data may be checked through an automated spam detection service like:

Google reCAPTCHA (see Google reCAPTCHA v3 for its Privacy Policies).

7. Analytics

Kindly note that we use the following analytics services:

Google Analytics (see https://analytics.google.com/ for its Privacy Policies)
Yandex Metrica (see https://metrica.yandex.com/ for its Privacy Policies)

8. Disclosure of personal information

During our various processing activities, ClickSendNow may disclose personal information with:

Our employees who are required to render the services to our clients liaise with applicants for employment and services providers;
Services providers involved in the rendering of services to the clients;
Service providers that provide software or programming services that enable ClickSendNow to perform our services efficiently;
Services providers, it is in engaged with such as compliance officers, administration, labour consultants, attorneys, etc.; and
Government organisations (such as SARS, CIPC, UIF, etc).

ClickSendNow may share personal information if it has a duty or a right to disclose the same in terms of law or certain industry codes; or if it is necessary to protect ClickSendNow’s or your legal rights and interests.

Access to client data from within our organisation is limited to essential staff or specialist contractors that are required to access our systems for client service or maintenance purposes, who are bound by the requirements of the legislation and are required to maintain safety and security measures.

The organisation will not transfer personal information to a third party in a foreign country without ensuring that it complies with the provisions of POPI or subscribes to similar personal information protection laws. Personal information shall not be shared with countries that do not subscribe to personal information protection laws unless ClickSendNow has entered into an agreement in terms of which the third party subscribes to the obligations for lawful processing of personal information.

5. Your Rights And Responsibilities

To ensure that ClickSendNow at all times has the correct information of the person to whom the personal information relates, we require our data subjects to inform ClickSendNow when their personal information changes.

A person to whom the personal information relates, a data subject, has a right to object to the use of personal information or complain about instances where any of their rights under POPI has been infringed upon. In certain instances failure to provide us with personal information may result in the inability to deliver said services to you, alternatively, you shall receive limited services or we shall not be able to enter into a business or employment relationship with you, as the case may be.

In addition to the right to the aforementioned right, you have the right to request access to personal information and where necessary, that the personal information held by ClickSendNow must be corrected, destroyed, or deleted.

6. Data Subject Engagement Procedures

Access to information requests can be made by email, addressed to the Information Officer. The Information Officer will provide the data subject with the prescribed form. Once the completed form has been received, the Information Officer will verify the identity of the data subject before handing over any personal information. All requests will be processed and considered against the organisation’s PAIA Policy, recordkeeping policies, and any other requirements in terms of the law.

ClickSendNow takes all complaints very seriously and will address all POPI related complaints by the following procedure:

POPI complaints must be submitted to the organisation in writing. Where so required, the Information Officer will provide the data subject with a “POPI Complaint Form”.
The Information Officer will provide the complainant with a written acknowledgement of receipt of the complaint.
The Information Officer will carefully consider the complaint and amicably address the complainant’s concerns. In considering the complaint, the Information Officer will endeavour to resolve the complaint in a fair manner and accordance with the principles outlined in POPIA.
Where the data subject is not satisfied with the Information Officer’s suggested remedies, the data subject has the right to complain to the Information Regulator.
The Information regulator’s contact details are as follows:

Complaints email: complaints.IR@justice.gov.za

General enquiries email: inforeg@justice.gov.za

JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

P.O Box 31533, Braamfontein, Johannesburg, 2017

Should you have any questions relating to this notice, you can contact the Information Officer. Our Information Officer is Tyler Slement at support@clicksendnow.co.za or 087 240 5400.

7. Policy Changes

This notice was last revised on 8 June 2021. Any material changes hereto will be published on our website or distributed to clients in writing. Your continued use of our services following the update means that you accept ClickSendNow’s updated notice.