Privacy Policy
for ASAL Express
1. INTRODUCTION
Transfer Service. The Asal Xpress Money Transfer Service was created to assist you to send money to and receive money from family and friends around the world. The Asal Pay Money Transfer Service is operated in Somalia by Asal Pay.
1.2 Asal Pay is a private company incorporated in the Federal Republic of Somalia with company number 179/2020 whose registered address is Makkah – Almukarramah, KM-4, Mogadishu, Somalia.
1.3 Your privacy and keeping your personal information secure is extremely important to us. We are committed to protecting and respecting Your privacy and handling Your information in an open and transparent manner.
1.4 This Privacy Policy (“Policy”) explains among other things: what we do with your personal information; what we do to keep it secure; with whom we share your information; your rights in relation to the personal information we hold about you; and who you can contact for more information.
1.5 We will regularly amend or update this Policy to reflect changes in our practices with respect to the processing of personal information, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make to the terms of this Policy.
2. INFORMATION WE COLLECT
2.1 We may collect, record and use information about You in physical and electronic form and will hold, use and otherwise process this data in accordance with the Privacy Laws and as set out in this Policy.
2.2 The personal information we collect and use may include, amongst other things
2.2.1 Your name;
2.2.2 Your contact information such as Your email address, postal address and telephone number (or any telephone number used to call our customer services);
2.2.3 Your demographic information such as age, education, gender, and interests;
2.2.4 evidence of Your identity (for example passport information);
2.2.5 any correspondence or complaint made to us;
2.2.6 unique identifiers such as Your username, account number and password;
2.2.7 Your profiles and postings on any other social media applications and services that we provide or that You make available to us;
2.2.8 Your payment details and other financial data (for example, Your bank or payment method provider’s name and Your account number and sort code); and
2.2.9 information about Your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
2.3 We also collect from You information in relation to other people (for example, details of the recipients of Your money transfers), where You provide us with such information. In providing this information you confirm to us that you have obtained all necessary permissions from them to the reasonable use of their information for the purposes and in the manner described in this Policy, or are otherwise permitted to give us this information on their behalf. Please also ensure that those other people are aware of this notice and that the provisions of this notice are clearly communicated to them.
3. HOW WE COLLECT THE PERSONAL INFORMATION
3.1 You give to us when You use our services.: If You use our services You will need to provide certain information including Your name, address and card number, as well as the name and other details of the recipients of the money transfers that you instruct us to carry out. This information must be complete and accurate, and if not, we may have to take additional steps to complete the transaction.
3.2 Your communication with us: We also keep a record of any email correspondence you send us. This helps us provide you with better customer service, and to improve the experience of our customers overall. Telephone calls made to and from the Contact Centre will be recorded for quality, training and monitoring purposes.
3.3 Other information You give to us: This is information about You that You give us by filling in forms on our website (for example, the ‘contact us’ section) or when you communicate with us by phone, e-mail or you take part in competitions, surveys, or questionnaires about our products or services, or otherwise. It includes, for example, information You provide when You register on the website for us to contact You, when You inquire about any of our Services, and when You report a problem with our website. The information You give us may include, among other data, Your name and email address.
3.4 From other members of the Asal Pay Group: We may collect information about You from other companies in the Asal Pay Group.
3.5 social media: Depending on Your settings or the privacy policies for social media and messaging services such as Facebook, LinkedIn and Instagram, you might give us permission to access information from those accounts or services.
3.6 Other Sources: We may receive information about You from other sources, including publicly available databases and combine this data with information we already have about You. This helps us to update, expand and analyses our records and provide services that may be of interest to You.
4. INFORMATION WE COLLECT ABOUT YOU
4.1 Cookies: Like most websites, we use “cookies” to help us make our site – and the way You use it – better. Cookies mean that a website will remember You. They are small text files that websites transfer to Your computer (or phone / tablet). They improve website use and speed – for example by automatically filling Your name and address in text fields. Please see our Cookies Policy for further information.
4.2 Log Files: In addition, with regard to each of Your visits to our site, we will automatically collect certain information (for example, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data). We may combine this automatically- collected log information with other information we collect about You.
4.3 Social Media Widgets: Our website includes Social Media Widgets or Features, such as the Facebook Like button and Twitter button which are interactive mini-programs that run on our site to provide specific services from another company (e.g. displaying the news, opinions, music, etc). Personal information, such as Your email address, may be collected through the Widget. Cookies may also be set by the Widget to enable it to function properly. Information collected by this Widget is governed by the privacy policy of the company that created it.
5. PERSONAL INFORMATION FROM THIRD PARTIES
If we receive personal information about you that we do not request directly from you or from another party, we will decide whether we could have collected the information in accordance with this Policy and Privacy Laws. If so, we will keep the information and handle it in accordance with this Policy and applicable Privacy Laws. If we decide that we could not have collected the personal information in accordance with this Policy and applicable Privacy Laws, we will destroy or anonymize the information if it is reasonable and lawful to do so.
6. COOKIES AND SIMILAR TECHNOLOGIES
When you visit our site or use a Mobile App we may place cookies or similar trackers (“Cookies) onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may use your personal information through Cookies and similar technologies.
7. HOW WE USE YOUR PERSONAL INFORMATION
7.1 Our primary purpose in collecting user information is to provide You with a safe, smooth, efficient, and customized experience and to provide the services You have requested from us. We may also use the information that You have provided to ensure that the content on our site is presented in the most effective manner for You and Your computer or device.
7.2 We use Your information for the following specific purposes:
7.2.1 to carry out our obligations arising from any contracts entered into between You and us or from applicable law, and to provide You with the Services in accordance with our terms and conditions and with this Policy;
7.2.2 to register You with a Asal Pay account;
7.2.3 to fulfil Your Transaction / (Airtime Top Up) Request;
7.2.4 to send You confirmations;
7.2.5 to notify You about temporary or permanent changes to our services or other service-related messages;
7.2.6 to assist you where online applications are not completed;
7.2.7 to prevent fraud, money laundering, and any other illegal activity that may cause you, us or others harm including in relation to the Services;
7.2.8 comply with our legislative and regulatory requirements in any jurisdiction, including customer due diligence (i.e. know your customer);
7.2.9 to ensure that content from our site is presented in the most effective manner for You and for Your computer;
7.2.10 to promote our business;
7.2.11 to send You Marketing communications except you tell us not to do so.
7.2.12 to administer our site and for internal operations, including troubleshooting, data analysis, profiling and segmentation analysis, testing, research, statistical and survey purposes;
7.2.13 as part of our efforts to keep our site, Mobile App and our services safe and secure;
7.2.14 to measure or understand the effectiveness of advertising we serve to You and others, and to deliver relevant advertising to You;
7.2.15 to make suggestions and recommendations to You and other users of our site about services that may interest You or them;
7.2.16 to train, monitor and assess the effectiveness of the manner in which we provide the Services to You;
7.2.17 to consider and investigate any concerns or complaints you may have; and
7.2.18 to display personal testimonials of satisfied customers on our website in addition to other endorsements, where You have agreed with a third-party review site that we may do so. If You wish to update or delete Your testimonial, You can contact us using this form.
8. AUTOMATED DECISION MAKING
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, except if: (i) the automated decision-making is required or authorised by law; (ii) is necessary for entering into or performing the contract, or (iii) is based on your individual explicit written consent.
9. DIRECT MARKETING
We may use the contact details you provided to send you marketing communications by email, telephone, direct mail or other communication formats about similar products or services where permitted by applicable law (unless you have opted out).
10. WHO WE MIGHT SHARE YOUR PERSONAL INFORMATION WITH
10.1 Your personal information is very important to us. However, there are circumstances where it is necessary for us to share your information in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality and professional secrecy. In addition, we may disclose your personal information to:
10.1.1 Our affiliates – we share your information with other companies within the AsalPay Group, for our internal business, operational, management and service needs; for compliance, regulatory and audit activity and in connection with legal, regulatory and tax claims and investigations; to understand and support our Customers who use our services, apps and sites, as well as visitors to those apps and sites; and to send Marketing communications.
10.1.2 Third party processors which include people with whom we do business or who provides services to us. If we engage a third-party processor to process your information, the Processor will be subject to binding contractual obligations to: only use the personal information in accordance with our prior written instructions; and use measures to protect the confidentiality and security of the personal information, together with any additional requirements. We may disclose data to provide our services, to respond to legal requirements, enforce our policies, liaise with judicial or regulatory authorities where required under applicable law, and protect our rights and property. ;
10.1.3 Companies that capture or analyse information to help us understand how our services, sites and Mobile Apps are used and perform or to tailor our services and promotions, including for the purpose of allowing us to improve the services we provide;
10.1.4 Companies that provide us with marketing assistance, including: the management of email marketing operations, SMS and other services that deploy marketing on the internet or social media platforms (such as Facebook and Google); the running of surveys and other feedback activity; as analysis of the effectiveness of any marketing or customer engagement we do;Banks, payment card processors and other service providers that process bank transfers, credit and debit card payments or otherwise provide financial infrastructure services to enable us to provide our services;
10.1.5 Our service providers, including those who provide data hosting services, fraud prevention services; technology services, and technology tools that allow us to monitor, test and improve our services, sites and Mobile Apps;
10.1.6 Companies that we have instructed to provide services to or for us for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted;
10.1.7 Other business entities should we plan to merge with, or be acquired by, or be invested in by that business entity, or if we undergo a corporate reorganisation; and
10.1.8 Any successor in business to us.
10.1.9 Fraud Prevention Agencies – Where we have a good reason to suspect fraud, money laundering, counter terrorist financing or any other illegal activity, we can upon request or where legally obliged share your personal information with crime prevention agencies and other third parties for the purpose of detecting, preventing or reporting crime or for actual or suspected breach of any applicable law or regulation. These third parties may include business partners and companies that provide services to us, law enforcement bodies, regulatory and supervisory authorities, providers of fraud prevention and detection services. Please note, we may suspend activity on your account or any transaction, refuse access to your account or cancel any transaction you may want to make, if we think there is a risk of any illegal activity.
10.1.10 Public Agencies – We release accounts or other personal information when we consider it appropriate to comply with the law or an order of a court or tribunal, to enforce our Terms and Conditions and any other agreement to protect the rights, property, health or safety of Asal Pay, our employees or Customers, our business partners or others or the public. In these circumstances, we will only provide them with the information they require to perform their function.
10.1.11 FaceBook – We may share with Facebook actions that you take on our website such as your visits to our website, your interactions on our website, use of Facebook Connect and information collected from cookies or similar technologies including the Facebook Pixel. This allows us to measure the effectiveness of our advertising, improve our marketing practices, and helps us deliver more relevant advertising to you and people like you (including on social media such as Facebook). This arrangement means that Asal Pay has to provide you this notice, but you should contact Facebook if you wish to exercise your data protection rights. Further information, including how Facebook enables you to exercise your data protection rights, and subsequently processes your information can be found in FaceBook Data Policy. If you would like to know more please contact us using the details below.
10.1.12 Google. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Sites and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online services. You can learn about Google’s practices by going to google.com/policies/privacy/partners, and opt out of them by downloading the Google Analytics opt-out browser add-on.
10.1.13 Research companies – We may share personal information in a secure way to allow research companies and feedback providers to contact you directly on our behalf to get your opinions on or refuse to take part in the research or surveys.
11. SECURITY
11.1 Asal Pay shall take all reasonable technical and organizational steps to secure the content of the Website and your personal information from unauthorized access and/or disclosure. However, Asal Pay does not make any warranties or representations that the content shall be entirely safe or secure.
11.2 We have implemented appropriate technical and organizational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law.
11.3 Unfortunately, the transmission of information via the internet (including by email) is not completely secure. Although we will do our best to protect Your personal information, we cannot guarantee the security of Your data transmitted to our site; and any transmission is at Your own risk. Once we have received Your information, we will use strict procedures and security features to try to prevent unauthorized access
11.4 Asal Pay will make all reasonable attempts to exclude viruses (and similar destructive devices) from the Website but cannot guarantee the exclusion of viruses (and similar destructive devices) and you should take appropriate steps in respect of this risk.
12. HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR
12.1 We take every reasonable step to ensure that your personal information is only retained for as long as it is required for the purposes set out in this Policy. Therefore, we will only keep the information we collect about You for as long as required for the purposes set out above, or as required to comply with any legal or regulatory obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.
12.2 The period for which we will retain information about You will vary depending on the type of information and the purposes that we use it for. In general, unless applicable law requires a longer retention period, we will keep our records for as long as you are our Customer and for 5 years after the end of your relationship with us.
13. CONTACT DETAILS
13.1 Contact details for any purposes related to this policy:
13.1.1 E-mail: info@asalexpress.so
13.1.2 Phone: +252615 302 478.
