SEND MONEY TO AFRICA (SMA)
Privacy Policy
Introduction:
Your privacy and keeping your personal information secure are extremely important to us. At SMA, we are committed to protecting and respecting your privacy and handling your information in an open and transparent manner.
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.
We will amend or update this Policy regularly 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. If you don't want to read all the details, here are the highlights that you may really wish to know.
· SMA Ltd is an international payment service that provides international money transfer and remittance services in more than 130 countries and in over 70 currencies.
· you will know us by our brand: “SMA”.
· Where appropriate, we share your personal information within the SMA Group, affiliates, partners and other companies. Upon request or where we are legally obliged, we may share your information with public agencies.
· We also collect from you information in relation to other people (for example, details of the recipients of your money transfers). In providing this information you confirm to us that you have their permission to do so.
· We use some third parties to process your personal information on our behalf to perform our services for you, and due to the international nature of our business some of them are based outside the United Kingdom and the European Economic Area.
· you have several rights over your personal information, and the manner in which you can exercise those rights are contained in this Policy.
· We will send you direct Marketing if we are allowed to do so. We do this to encourage you to use our services and send you offers or promotions that may interest you. you can ask us to stop sending you marketing information at any time. Details of how to unsubscribe will be included on each email that we send you.
· We also use your personal information to display online adverts and Marketing relating to our services on our website, online media channels or by sending you push notifications if you use our mobile app.
· We do not intentionally use special category information and children’s information (our website and mobile application are not intended for children).
Who are we?
This website is operated and provided by SMA Ltd (“SMA”, “we”, “us”, “our”) having its registered office at …………………... If you reside in a country where we provide our services to you and are a user of our website https://www.sendmoneytoafrica.com/ (“our website”, “our site”) and/or of our mobile applications (the “Mobile App”), we are a data controller for the purpose of Data Protection Legislation (as defined below). In this Policy, references to “you” and “your” are references to a user of our website and/or of our Mobile Apps.
Definitions
To help clarify our meaning; we have used certain capitalised terms in this Policy. These terms and their meaning are:
“Data Protection Legislation” means the United Kingdom General Data Protection Regulations as tailored by the Data Protection Act 2018 and all other applicable legislation relating to privacy or data protection.
“Marketing” means any action or advertisement or promotion or marketing material like surveys, vouchers, research and events. This list is not exhaustive.
“Services” means SMA Money Transfer Service; SMA Digital Money
Account; and such other services or products that we may introduce from time to time.
The personal information we collect about you
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 Data Protection Legislation and as set out in this Policy. The personal information we collect and use may include, amongst other things:
· your name;
· your contact information such as your email address, postal address and telephone number or any telephone number used to call us;
· your demographic information such as age, education, gender, and interests; evidence of your identity (for example passport information);the reason for your transfer request;
· unique identifiers such as your username, account number and password;
· your profiles and postings on any other social media applications and services that we provide or that you make available to us;
· 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 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. 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.
How we collect your personal information
· Information 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.
· 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 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, when you sign up to receive notifications, and when you report a problem with our website. The information you give us may include, among other data, your name and email address. We may also record our telephone conversation with you for training and monitoring purposes.
· From other members of the SMA Group. We may collect information about you from our affiliates and other companies in the SMA Group.
· 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.
· 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 analyze our records and provide services that may be of interest to you.
The right to request for the erasure of your personal information.
This is also known as the right to be forgotten. We will keep a note of your name if you ask for your personal information to be erased;
The right that we restrict our use of or object to our use of your personal information;
Wherever we use legitimate interest as the ground for processing your personal information you can object to our use of it; the right to have certain personal information transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
Where we use your personal information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your personal information in reliance upon any other available legal basis); and the right to lodge complaints with a Data Protection Authority regarding the use of your personal information by us or on our behalf.
We may require proof of your identity before we can give effect to these rights. You should also be aware that some of these rights are qualified and not absolute; therefore exemptions or limitations may apply. For example, we can refuse to provide information if fulfilling your request would reveal the personal information about another person, or if you request that we delete information which we are
required to retain by law, have compelling legitimate interests to keep, or need access to fulfill our legal obligations.
The quickest and easiest way to make a data subject request is to contact us directly to exercise your rights by emailing info@sendmoneytoafrica.com. We will endeavor to respond within a reasonable period and in any event within one month (three months for complex or numerous requests), in compliance with Data Protection Legislation.
We reserve the right to charge a reasonable fee (reflecting the costs of providing the information) or to refuse to respond where requests are manifestly unfounded or excessive: in this case, we will explain the situation to you and we will inform you about your rights.
Identity Verification
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 data 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.
Requests made by third parties
In line with our privacy practices and to protect your rights and freedoms, we are unable to process a data subject rights request made by a third party (such as Rightly) where; there is doubt that the third party has the appropriate authority to act on your behalf; and where we are not satisfied adequate evidence has been provided in support of identity verification. We would always aim to ensure that a third party has the appropriate consent or authority to act on your behalf, and most significantly that you are fully aware that the third party has made contact specifically with us, regarding exercising your data subject rights.
Before we can process a data subject rights request made by a third party on your behalf, we require as a minimum from the third party:
A copy of an identity document for you;
Evidence of your address; and a physically signed authority by you; or a verbal authority provided directly to us from you and noted on your account; and if provided electronically the authority is to come directly from your email address that matches our records. We will not access or process your personal data without being confident we are acting on your specific instructions.
Cookies and similar technologies
When you visit our site or use a Mobile App we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your references and browsing habits. We may use your personal information through Cookies and similar technologies, in accordance with our SMA Products Cookie Policy.
Contact us
Questions, comments and requests regarding your personal information and our Policy are welcome and should be sent to info@sendmoneytoafrica.com addressed to:
The data Protection Officer, SMA Ltd. You may also use these contact details if you wish to make a complaint to us relating to your privacy. If you have any concerns about our use of your information, you also have the right to make a complaint to: The Information Commissioner's Office, which regulates and supervises the use of personal data in the United Kingdom, via their helpline on 0303 123 1113. If you are based in the EU or EFTA country, the national data protection
supervisory authority in such a country (a list can be found at:
http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.