Updated November, 2022
We are Alexpay Africa Limited, a payment technology corporation with office at 158 Mabani Plaza, 4th Norla Street, Accra, Ghana with company number CS028170121.
Alexpay Africa Limited and its affiliates (“We”, “Us”, Our” or collectively, “Alexpay”) is committed to a policy of protecting the rights and privacy of individuals in accordance with the Data Protection Act, 2012 (‘the Act’). This policy applies to all personal data processed by Alexpay. This includes processing relating to Users.
The privacy of our Users is important to us, and we are committed to safeguarding it. This Privacy Policy explains your Personal Data which we collect, why we collect it, and what we do with it.
This Privacy Policy describes a User’s privacy rights regarding how and when we collect, use, store, share and protect your information across our website, payment platforms (“Platforms”), APIs, Software Applications, (“Apps”), email notifications and tools regardless of how a User uses or accesses them.
This Privacy Policy is applicable to the Website, web applications, software applications (“Apps”) and/or payment platforms (“Platforms”) offered by Alexpay or affiliated companies collectively referred to as Alexpay Services”
Account: means a profile created by a User on any Alexpay platform or Alexpay product..
Alexpay means Alexpay Africa Limited and its affiliates.
Personal data: Any information that can be used to identify a living person including email address, mobile number, residential address, payment card, financial information such as bank account number, etc.), Government-issued Identity card, and/or tax payer identification. It may also include anonymous information that is linked to a User, for example, your internet protocol (IP), log-in information, address, location, device, or transaction data.
Sites: means any platform including but not limited to mobile applications, websites, and social media platforms.
User: means an individual who uses the Services or accesses the Sites and has agreed to use the end services of Alexpay.
Special Categories of Personal Data: means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, criminal behavior, information about your health, information about a child, genetic and biometric data
This Privacy Policy statement is to provide all individuals whose personal data we hold with description of the types of Personal Data we collect, the purposes for which we collect that Personal Data, how and why the data is processed, and the measures we take to protect the security of the data.
Accordingly, we have developed this privacy policy in order for you to understand how we collect, use, communicate, disclose and otherwise make use of Personal Data.
Alexpay focuses on the following core principles
- To empower the individual: Alexpay wants you to be in charge of your Personal Data and to make your own voluntary choices about your personal data.
- To keep and secure Personal Data: Alexpay and its affiliates (collectively, “Alexpay”) do not take your trusting us with your information for granted. We take responsibility to ensuring that appropriate security measures are put in place and your Personal Data is protected.
- To be transparent, open and to educate users: For you to know what Personal Data is, how we collect Personal Data, for what purpose and how we secure Personal Data.
- To abide by local laws: Alexpay is a global company with local privacy expertise. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. Specific privacy notices may apply to some of our products and services. Please visit the webpage or digital asset of the specific product or service to learn more about our privacy and information practices in relation to that product or service in Ghana.
- To collect and store Personal Data on the “need to collect” basis: Alexpay collects Personal Data to perform its services for you. We work to have measures in place to prevent collecting and storing personal data beyond what we need.
1. Personal Data we may collect about you;
2. How we get your Personal Data and why we have it;
3. How we may use your Personal Data;
4. Data security and retention
5. Disclosing your Personal Data;
6. Marketing
7. Your data protection rights and choices
8. Cookies
9. Use by Minors
10. International Data transfers
11. Data Protection Supervisor
12. Training
13. Dispute Resolutions and Filing a Complaint
14. Reviews
15. Updates to our privacy policy 16. Contact Us
We may collect, use, process, store, or transfer Personal Data such as:
● Identity Data: Information such as, your full name(s), your government-issued identity number, and your date of birth. This data is to enable us to verify your identity in order to offer our services to you;
● Contact Data: This is data that is needed to reach out to you, such as your contact address, email address, telephone number, details of the device you use and billing details;
● Identification documents :(such as your passport or any Government-issued identity card), a photograph (if applicable) and any other registration information you may provide to prove you are eligible to use our services;
● Log/Technical information: When you access Alexpay services, our servers automatically record information that your browser sends whenever you visit a website, links you have clicked on, length of visit on certain pages, unique
device identifier, log-in information, location and other device details.
● Financial Data: Information, such as personal account number, the merchant’s name and location, the date and the total amount of transaction, and other information provided by financial institutions or merchants when we act on their behalf.
● Transactional Data: These are information relating to a payment when you as a merchant (using one or more of our payment processing services) or as a customer, are using our products or services.
● Marketing and Communications Data: This includes both a record of your decision to subscribe or to withdraw from receiving marketing materials from us or from our third parties.
● Records of your discussions with us if we contact you and if you contact us.
We may also collect, store, use and transfer non-Personal Data or anonymized data such as statistical or demographic data.
As a principle, we do not collect any Special Categories of Personal Data. If we do collect Special Categories of Personal Data, we will ensure compliance with the Data Protection Act, 2012 (the DPA) and other applicable laws and regulations on data protection in Ghana.
This Privacy Policy applies to Alexpay services only. We do not exercise control over the sites displayed or linked from within our various services. These other sites may place their own cookies, plug-ins or other files on your computer, collect data or solicit Personal Data from you. Alexpay does not control these third-party websites and we are not responsible for their privacy statements.
Please consult such third parties’ privacy statements.
The Personal Data we have about you is directly made available to us when you:
⇒ Sign up for an Alexpay Account;
⇒ Use any of our services;
⇒ Contact our customer support team;
⇒ Fill our online forms;
⇒ Contact us;
The lawful basis we rely on for processing your Personal Data are:
⇒ Your consent;
Where you agree to us collecting your Personal Data by using our Services.
⇒ We have a contractual obligation:
Without your Personal Data, we cannot provide our Services to you.
⇒ We have a legal obligation
To ensure we are fully compliant with all applicable financial legislations such as the Anti-Money Laundering Act, 2020 (Act 1044) and other applicable Anti-Money Laundering & Counter Terrorist Financing Laws, to collect and store your Personal Data. We protect against fraud by checking your identity with your Personal Data
We may use your Personal Data we collect to:
● Create and manage any accounts you may have with us, verify your identity, provide our services, and respond to your inquiries.
● Process your payment transactions (including authorization, clearing, chargebacks and other related dispute resolution activities).
● Protect against and prevent fraud, unauthorized transactions, claims and other liabilities.
● Provide, administer, and communicate with you about products, services, offers, programs and promotions of Alexpay, financial institutions, merchants and partners.
● Evaluate your interest in employment and contact you regarding possible employment with Alexpay.
● Evaluate and improve our business, including developing new products and services.
● To target advertisements, newsletter, and service updates.
● As necessary to establish, exercise and defend legal rights.
● As may be required by applicable laws and regulations, including for compliance with Know Your Customers and risk assessment, Anti-Money Laundering, anti-corruption, and sanctions screening requirements, or as requested by any judicial process, law enforcement or governmental agency having or claiming jurisdiction over Alexpay or Alexpay’s affiliates.
● To use data analytics to improve our Website, products or services, and user experiences.
● For other purposes for which we provide specific notice at the time of collection.
The security of your Personal Data is important to Alexpay. We are committed to protecting the information we collect. We maintain administrative, technical and physical controls designed to protect the Personal Data you provide, or we collect against loss or theft, as well as against any unauthorized access, risk of loss, disclosure, copying, misuse or modification.
Other security measures include but not limited to, secure servers, firewall, data encryption and granting access only to employees in order to fulfil their job responsibilities.
Where you use a password for any of your Accounts, please ensure you do not share this with anyone, and the password is kept confidential at all times.
We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of your Personal Data is protected and maintained. Transmitting information online is not entirely secure. As such, we cannot guarantee that all information provided online is secure. We would take all reasonable steps to ensure that your Personal Data is secured and well-protected.
We will only retain Personal Data on our servers for as long as is reasonably necessary and as long as we are providing Services to you. Where you close your Account, your information is stored on our servers to the extent and duration necessary to comply with regulatory and anti-money laundering obligations and for the purpose of fraud monitoring, detection and prevention. Where we retain your Personal Data, we do so in compliance with limitation provisions under the DPA.
We may disclose or share your Personal Data with third parties which include our affiliates, employees, officers, service providers, agents, suppliers, subcontractors as may be reasonably necessary for the purposes set out in this policy. Alexpay only shares Personal Data with third parties in the following limited circumstances:
● We have your consent. We require opt-in consent for the sharing of any Personal Data. We share Personal Data with third parties directly authorized by you to receive Personal Data, such as when you authorize a third-party application provider to access your account. The use of your Personal Information by an authorized third party is subject to the third party's privacy policy and Alexpay shall bear no liability for any breach which may arise
from such authorization by you.
● We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing Personal Data on our behalf. We require that these parties agree to process such information
based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
● We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:
a. satisfy any applicable law, regulation, legal process or enforceable governmental request;
b. enforce applicable terms of service, including investigation of potential violations thereof;
c. detect, prevent, or otherwise address fraud, security or technical issues; or
d. protect against imminent harm to the rights, property or safety of Alexpay, its users or the public as required or permitted by law.
If Alexpay becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before Personal Data is transferred and becomes subject to a different privacy policy
We may process your Personal Data in order to contact you or send you marketing content and communication about our products, services or surveys. You may exercise your right to object to such contact from us or opt out from the marketing content (please see Section 16 below). Please note however that if you opt-out of marketing content, we may still send you messages relating to transactions and our Services
By virtue of the DPA, below are the rights you have as a user in relation to your personal data:
- Right to be informed.
- Right to request access or copies to your Personal Data held by us by signing into your Account or contacting us.
- Right to request that Alexpay erase your Personal Data. You have the right to ask us to erase your Personal Data. Please note that this is a limited right which applies where the data is no longer required, or the processing has no legal justification or we are not required by law to retain your information. The exceptions to this right is where the applicable law requires Alexpay to retain a historical archive or where we retain a core set of your personal data to ensure we do not inadvertently contact you in future where you object to your data being used for marketing purposes.
- Right to correct or rectify any Personal Data that you provide which may be incorrect, out of date or inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Right to object to the processing of your Personal Data for marketing purposes. You have a right to ask us not to contact you for marketing purposes by adjusting your notification preference on the settings page or by opting out via the unsubscribe link in marketing emails we send you.
- Right to object to processing: You have the right to object to the processing of your Personal Data in certain circumstances. Please note that where you object to us processing your Personal Data, we might be unable to provide the services to you.
- Right to not be subject to a decision based solely on automated
processing.
The basis of Alexpay processing your Personal Data is your consent. You also have the choice at any time to withdraw consent which you have provided.
You also have a choice to deactivate your Account at any time.
You may contact us should you wish to de-activate your Account at
any time via the Contact Us segment below or send us an email at
contact@alexpay.com. If you wish to exercise any of the rights set above, please contact us using the contact information provided in the Contact Us segment below. Where we are unsure of your identity, we might ask you for proof of your identity for security reasons before dealing your request.
Like many other websites, we use cookies to distinguish you from other users and to customize and improve our services. Some browsers may automatically accept cookies while some can be modified to decline cookies or alert you when a website wants to place a cookie on your computer. If you do choose to disable cookies, it may limit your ability to use our website. For detailed information on the cookies and how we use them see our Cookie Policy.
Alexpay’s websites and applications are not directed at persons under the age of eighteen (18) and we do not collect any Personal Data knowingly or directly from minors who fall within this category.
Where you have any belief that Alexpay has mistakenly or unknowingly collected information from a minor, please contact us using the information provided under the Contact Us section to enable us to investigate and restrict such data
Our business is global with affiliates and providers located around the world. As such, we may need to disclose your Personal Data to our affiliated, subsidiary companies or providers, for the purpose of implementing and providing any of our products or services to You. Whenever your data is processed or stored outside Ghana, we shall ensure that there is adequate data protection safeguards in the recipient country, your consent is obtained and that your Personal Data is handled securely in line with the DPA.
Alexpay has appointed a Data Protection Supervisor (DPS) responsible for overseeing the Company's data protection strategy and its implementation to ensure compliance with the DPA requirements.
Alexpay ensures that employees who collect, access and process Personal Data receive adequate data privacy and protection training in order to develop the necessary knowledge, skills and competence required to effectively manage the compliance framework under this Policy and the DPA, with regard to the protection of Personal Data. On an annual basis, Alexpay develops a capacity building plan for its employees on data privacy and protection in line with the DPA
If you have any complaints regarding this Privacy Policy, please contact us at contact@alexpay.com We will investigate and work on resolutions for complaints and disputes regarding use and disclosure of Personal Data within thirty (30) days in accordance with this Privacy Policy and in accordance with the DPA.
Periodically, Alexpay shall conduct Data Privacy Impact Assessment and data privacy internal reviews for the identification of reasonably foreseeable internal and externalrisks to personal data, monitoring, investigation, report on the observance, maintenance of appropriate safeguards against identified risks and promotion of the protection of the right to privacy and of personal data.
Alexpay shall permit the performance of such other functions as may be prescribed by other applicable laws or as the Data Protection Commission considers necessary for the promotion, implementation enforcement of the provisions of the DPA.
From time to time, we may change, amend, or review this Privacy to reflect new services or changes in our Privacy Policy and place any updates on this page. All changes made will be posted on this page and where changes will materially affect you, we will notify you of this change by placing a notice online or via mail. If you keep using our Services, you consent to all amendments of this Privacy Policy.
All access requests, questions, comments, complaints, and other requests regarding the privacy policy and your personal data should be sent to contact@alexpay.com
We may request additional details from you regarding your complaints and keep records of your requests and resolution.
© Alexpay Africa Ltd. (Ghana) 2022 All rights reserved.