PALREMIT DATA PRIVACY POLICY
Privacy Statement
Your privacy is important to us. This Privacy Policy (“Policy”) explains how Palremit Corporation and its affiliates (“Palremit”, “We”, “Us” or “Our”) collect, use, store and disclose your Personal Information when you interact with our website, mobile application, Palremit services, social media platforms, support services and content, regardless of how you access them..
Personal Information
Personal Information relates to information that identifies you as an individual such as your name, phone number, email address etc. By providing your Personal Information and/or continuing with the use of our website or services, you expressly consent to our collection, use, storage and processing of your Personal Information according to this Privacy Policy and such other terms or policies that we may publish from time to time.
Periodic Review
We reserve the right to review and update this Policy periodically to reflect changes in our privacy practices and to ensure compliance with applicable law. We encourage you to read this Policy carefully and regularly check this page to review changes we might make to the terms of this Policy. Any change to this Policy becomes effective when published. Your continued use of our services, website, content, support services, etc. shall be deemed as acknowledgment and acceptance of these changes.
Collection of Personal Information
4.1. Information We Collect
4.1.1. Generally, the information we collect during your interaction with Palremit or any of Our products or services may include the following:
a. Contact information: This may include your name, email address, residential address, phone number, date of birth and other information about you.
b. Videos and Images: This includes pictures uploaded for account verification. We may also collect images and videos of you through cameras when you visit our physical offices or attend our events.
c. Profile Information: This includes your username and other profile information.
d. Credentials: This includes your login details such as password, password hints, and other security information.
e. Financial and transaction information: This includes bank account information, wallet information, transaction details and transaction history.
f. Demographic information: : This includes information about your age, location, lifestyle etc.
g. Marketing and communication information:: This includes your preferred communication medium and your preference in receiving marketing information.
h. Device and usage information: This includes IP addresses, device IDs, performance data, operating system information etc.
i. Feedback, reviews, and user experience:: This includes feedback, surveys, suggestions and recommendations given by you or insights gotten by Palremit based on your experience using our services or interacting with us.
4.1.2. Sensitive Personal Information: We typically do not collect or require you to disclose sensitive Personal Information such as your race, ethnicity, biometric data, religious beliefs, political affiliation etc. However, sensitive Personal Information may be collected if needed for the provision of or your use of our services or as may be required by law. In the event that such sensitive Personal Information is required and requested by us; by providing such information you consent to us processing the information. You may choose not to provide sensitive Personal Information when requested by us however, this may restrict or prevent your use of our services.
4.1.3. Personal Information of Minors: Minors are to refrain from using our services as our services are not intended for and should not be accessed by minors. We do not knowingly collect the Personal Information of minors and shall take prompt steps towards deleting any Personal Information of a minor, immediately after we become aware of such fact.
4.2. How We Collect your Personal Information
4.2.1. Use of Palremit services: We request and collect Personal Information and financial information from you when you sign up for and/or use our services through our website or mobile app.
4.2.2. Use of support services: We also request and collect Personal Information from you when you interact or access Palremit support services through any medium.
4.2.3. Automatically collected information: When you access our website or use our app, certain information such as login details, device information, browser type, date and time stamp, app usage, IP address, geographical information, and information on transactions are automatically collected.
4.2.4. Communication and marketing: We collect your Personal Information when you sign up to receive updates on our promotional and marketing activities.
4.2.5. Information from third parties: We may collect Personal Information about you from third parties such as our verification service providers, partners, other users and other sources.
Basis for processing your Personal Information
Depending on the nature of your interaction with us, your Personal Information may be processed on any of the following basis:
5.1.1. Where you have freely given us your consent.
5.1.2. For the purpose of our contract with you or to provide services to you.
5.1.3. Where necessary in compliance with applicable laws, regulations or orders such as know-your-customers (KYC) and anti-money laundering requirements.
5.1.4. Where necessary to protect your vital interest or that of another natural person.
5.1.5. Where necessary in circumstances and for purposes connected with public interest.
5.1.6. Within the confines of law for our legitimate business or that of a third party.Where necessary in circumstances and for purposes connected with public interest.
Basis for processing your Personal Information
We may aggregate or de-identify your Personal Information in a manner that it can no longer identify you. Once aggregated or de-identified, such information ceases to be Personal Information.
Use of your Personal Information
7.1 We use your Personal Information to:
7.1.1. Provide our services such as processing transactions etc.
7.1.2. Prevent fraud, money laundering, and any other illegal activity.
7.1.3. Verify the information you provide to us with third parties for purposes such as KYC.
7.1.4. Derive analytics to improve our services or develop new products that meet users' needs.
7.1.5. Personalise our products and make recommendations to you.
7.1.6. Administer our site and for internal operations, including troubleshooting, data analysis, profiling and segmentation analysis, testing, research, statistical and survey purposes.
7.1.7. Operate our business.
7.1.8. Deliver marketing and promotional information to you when you sign up for notification.
7.1.9. Measure or understand the effectiveness of advertising we serve to You and others, and to deliver relevant advertising to You.
7.1.10. Prevent, detect and manage security risks associated with the provision of services.
7.1.11. Comply with legal requirements for the delivery of our services to you.
7.1.12. Provide customer support and resolve complaints.
7.1.13. Prevent, detect and manage technical issues in the use of our services.
7.1.14. Prevent, detect and manage violations of Palremit’s policies.
Cookies
8.1 Our services use the following cookies:
8.1.1. Strictly necessary cookies: which are required for the operation of the Services. Without them, for example, you would not be able to register or log in or access the services that we offer.
8.1.2. Analytical/performance cookies: which allow us to recognize and count the number of visitors, to learn how visitors navigate our services, and to help us to improve the way our services function.
8.1.3. Functionality cookies are used to recognize you when you return to our website or services. KYC.
8.1.4. Google Analytics: which is a Google service that collects information about use of our services. Google Analytics does not identify individual users.
8.2 Your Control of Cookies
Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies, or to alert you when a cookie is placed on your computer, mobile device, or tablet. You also may be able to reject mobile-device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.
8.3 Our Policy on Do Not Track (DNT) Signals
Some web browsers including Chrome, Firefox, Internet Explorer, and Safari incorporate a DNT or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain Personal Information about the browser's user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Palremit, do not respond to DNT signals. In connection with using certain Palremit Services, we may automatically collect certain data relating to the performance and configuration of the Palremit Services, and our customers' and their end-users' consumption of and interaction of such services (Usage Data). Usage Data is generally technical information obtained from product software or systems hosting the services, devices accessing these products and services, and/or log files generated during such use which typically does not directly identify an end-user.
Disclosure and International Transfer of Your Personal Information:
9.1 We may disclose or transfer your Personal Information as follows:
9.1.1. With your consent.
9.1.2. Upon your instruction to share your Personal Information with a third party.
9.1.3. For business and commercial purposes such as reorganisation, merger, sale etc.
9.1.4. To provide services to you.
9.1.5. With our third affiliates and third-party service providers such as financial institutions, payment processors, security service providers etc.
9.1.6. Where required or provided by applicable laws and regulations or pursuant to a court or an administrative order.
9.1.7. With fraud prevention agencies and/or public agencies as may be required to prevent or investigate the occurrence of fraud, money laundering or breach of law.
9.2. We operate from various countries around the world to provide services to you, so do our affiliates, partners and third party service providers to whom we may need to disclose your Personal Information to in accordance with this Policy. This means that your data may be transferred to a different country with distinct data protection laws from the laws of the country you reside or are accessing our services or website. We ensure that your Personal Information, where so transferred, is transferred in accordance with this Policy and the applicable data protection laws of the other country.
Protection of Your Personal Information
10.1. We have implemented appropriate technical and organisational security measures designed to protect your Personal Information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing, in accordance with applicable law. 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 Personal Information transmitted to our site; and any transmission is at your own risk. Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorised access.
10.2. You are responsible for safeguarding your account information, login details, password and authentication details, as all instructions and transactions emanating from your account will be deemed to have been authorised by you. Hence, it is important to keep your password secure to prevent fraudulent use of your account. Do not disclose your password to anyone else and especially anyone who requests it from you by telephone or email. Please be aware of the following:
10.2.1. Change your password regularly and avoid using the same password on other websites to prevent hackers from accessing your account;
10.2.2. Avoid simple passwords that can easily be guessed;
10.2.3. Be aware that public WiFi networks are risky and hackers may capture your online transactions and Personal Information. Only connect to a network you can trust;
10.2.4. If you use a shared computer, make sure you log out immediately after you have finished using the website; and
10.2.5. Beware of ‘phishing’ where criminals may attempt to steal your information by sending you bogus emails.
10.3. Our website or app may contain links to third-party sites or services and third-party sites may contain links to our website and services. We neither control nor endorse nor bear responsibility for the content or privacy practices of any of these third-party sites. You are hereby encouraged to read the privacy policy and evaluate the security of such sites before you disclose your Personal Information on such sites.
10.4. We are not responsible for the protection of any Personal Information shared by you socially
Retention of Your Personal Information
11.1. 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. In addition, after you have ceased to be a Customer, we may take steps to delete your Personal Information or hold it in a form which no longer identifies you (for example, we may still use your data in an anonymised format for research and other business purposes).
11.2.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 6 years after the end of your relationship with us. For more details of the retention periods we apply to your Personal Information please contact us at [email protected]
Your Rights and Controls
12.1. As it pertains to your Personal Information, you are entitled to the following rights:
12.1.1. Right of access, rectification and erasure of Personal Information: You may request access to a copy of your Personal Information collected by us. You may also request an update, rectification or erasure of such Personal Information collected by us.
12.1.2. Right to data portability: Subject to applicable law, you may request the transmission of your Personal Information to another Data Controller.
12.1.3. Right to object, restrict or withdraw consent for processing: You may object to or restrict the processing of your Personal Information. Where we are processing your Personal Information based on your consent, you may withdraw such consent. However, such withdrawal shall not affect processing conducted prior to such withdrawal nor continued processing on other lawful basis than consent.
12.1.4. Right not be subject to automated decision making: You may object to decisions arrived at exclusively by automated decision-making where such decisions may bear legal consequences for you or significantly affect you.
12.1.5. Right to lodge a complaint: : In the unlikely event that you are aggrieved by any decision we have taken in relation to your Personal Information which is in violation of the applicable data protection laws, you may lodge a complaint with Palremit at [email protected].. You may also lodge a complaint with the applicable data protection authority regarding the use of your Personal Information by us.
12.2. All rights contained within this Policy are subject to limitations under applicable laws or orders from a court of competent jurisdiction. Exercise of rights recognised in this Policy shall be made via a written request to our Data Protection Officer (DPO) at [email protected].
12.3. We will only process your data subject rights’ request where we are satisfied that we have successfully verified your identity, and you are the one asking for your Personal Information to be processed. We will not process personal data where we are in doubt of the identity of the requestor. You may be asked to prove your identity when making a data subject request.
Contact Us
If you have any questions, comments or requests about this Policy or your Personal information, kindly contact our DPO at [email protected].
7.2. Mode
Our processing of Personal Information for these purposes include both automated and manual (human) methods of processing. Our automated methods may however be supported by our manual methods.
7.3. Further Processing
If we intend to process your Personal Information for any purpose beyond those contained in this Policy or any of our other policies, we shall seek your consent and provide any information you may require.