27th February 2017

FreshPay PRIVACY POLICY

At FreshPay, we are keenly aware of the trust our users place in us, and our responsibility to protect their privacy. We believe transparency and choice are the foundations of privacy. We strive to let users know what information we collect when they use our products and services, and give users meaningful choices about what information they provide to Fresh Pay and all our other services.

The FreshPay Privacy Policy describes how we treat personal information when you use FreshPay products and services. In addition, the following describes our privacy practices that are specific to FreshPay. You accepted this policy when you signed up for our Service. We may amend this policy at any time by posting a revised version on our website.

INFORMATION WE COLLECT AND HOW WE USE IT

Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customized experience. We may use your personal information to:

  • provide the services and customer support you request;
  • process transactions and send notices about your transactions
  • resolve disputes, collect fees, and troubleshoot problems;
  • prevent potentially prohibited or illegal activities, and enforce our Terms of Service;
  • customize, measure, and improve our services and the content and layout of our website;
  • send you targeted marketing, service update notices, and promotional offers based on your communication preferences;
  • compare information for accuracy and verify it with third parties.

REGISTRATION INFORMATION

When you sign up for a FreshPay Account, we ask for your personal information so that we can provide you with the service. The information we require to register for the service includes your name, mobile number, and email address.

This information allows us to process payments and protect users from fraud. The information we collect is stored in association with your FreshPay Account.

TRANSACTION INFORMATION

When you use FreshPay to conduct a transaction, we collect information about each transaction, including but not limited to the transaction amount, a description provided by the seller of the goods or services being purchased, and the names of the seller and buyer.

INFORMATION ABOUT YOUR USE OF THE SERVICE

In order to protect you from fraud, phishing, and other misconduct, we may collect information about your interaction with the service to help validate your identity or detect potentially fraudulent conduct. For example, in some circumstances we may try to determine service usage patterns (such as how quickly you type) so that we can try to detect and prevent unauthorized attempts to access your account (such as automated hacking attacks, or the use of stolen usernames or passwords). Any such information we collect will only be used to detect and prevent fraud or other misconduct, unless you explicitly grant us permission to use it in another manner.

LOG INFORMATION

When you access FreshPay Webpages, our servers automatically record information that your browser sends to us. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.

USER COMMUNICATIONS

When you send email or other communication to us, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.

LINKS

We may present links in a format that enables us to keep track of whether these links have been followed.

We use this information to improve the quality of our search technology, and customized content.

In addition to the above, we use the information we collect to:

  • Provide our products and services to you, including the display of customized content;
  • Perform auditing, research and analysis in order to maintain, protect and improve our services;
  • Ensure the technical functioning of our platform; and
  • Develop new services.

We process personal information on our servers in Ghana and the United States of America. We may process personal information to provide our own services.

INFORMATION SHARING

We will not sell or rent your personal information to companies or individuals outside of Mulanji. If you are making a purchase with FreshPay, we will not share any of the personal information you provided us during registration of your account; except in the limited circumstances described below. In addition, we will only share your personal information with other companies or individuals outside of Mulanji in the following circumstances:

As necessary to process your FreshPay & banking transactions and maintain your account. As with any financial institution, if you process a transaction through our service, we need to share some information (for example, your business and account number) with our partner banks and the Bank of Ghana. Some sellers may require that their buyers provide a contact information (for example, a telephone number) in order to process a transaction. In those cases, the merchant will specifically request that information from you from their website before or after your FreshPay transaction. We will not share your telephone number with the merchant, and where necessary, we will inform and request your permission online before you complete your transaction.

As a standard policy to protect our users, FreshPay does not allow or approve of merchants who request for user’s FreshPay details on their website. Any such merchant has not been certified by FreshPay and users are advised to report immediately and not to transact with the merchant.

You may be given a choice on a seller-by-seller basis whether you’d like to receive promotional emails from the seller. If you decide later that you don’t want to receive promotional emails from a seller, you will need to contact the seller directly.

To detect, prevent, or otherwise address fraud, security or technical issues.

  • We have your consent. We require opt-in consent for the sharing of any sensitive personal information.
  • We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this 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:

  1. a) Satisfy any applicable law, regulation, legal process or enforceable governmental request,
  2. b) Enforce applicable Terms of Service including investigation of potential violations thereof,
  3. c) Detect, prevent, or otherwise address fraud, security or technical issues, or
  4. d) Protect against imminent harm to the rights, property or safety of Mulanji, its users or the Public as required or permitted by law.
  • We may share aggregated non-personally identifiable information with third parties. For example, we may disclose that a certain percentage of our users have a billing address in a particular geographic area, or that a certain percentage of users are of a particular gender. However, if we do share this aggregated information, we do not include personally identifiable information without your explicit opt-in consent or in the limited circumstances described above.
  • If Mulanji or its subsidiaries become involved in a merger, acquisition, or any form of sale of some or all of their assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

INFORMATION SECURITY

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical and technical security measures to guard against unauthorized access to systems where we store personal data. For example, your email address will always be stored in an encrypted form (except when you provide it to us in a communication outside of our web page or mobile app interface).

The security of your account also depends on keeping your account password confidential, and you should not share your account name or password with anyone. If you do share your account information with a third party, they will have access to your account and your personal information.

DATA INTEGRITY

FreshPay processes personal information only for the purposes for which it was collected and in accordance with this Privacy Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services or as otherwise permitted under this Policy. We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.

ACCESSING AND UPDATING PERSONAL INFORMATION

You can review and update your payment information by logging in to your FreshPay Account and going to the “Account Settings” page, where you can update your personal information.

You can disable or close your FreshPay account by contacting us. If you do so, your FreshPay account will no longer be able to conduct transactions. However, in order to meet our reporting and auditing obligations, and to detect, deter, and prevent fraud or other misconduct on our systems, your account information will be retained in our systems. If you disable FreshPay, your personally identifiable information will not be used by Mulanji or shared with third parties except for these purposes. We may delete these records over time if permitted or required by law.

Disabling your FreshPay Account does not close or cancel your FreshPay Account. This Privacy Policy continues to apply to the personal information we maintain after you disable or close or cancel your FreshPay Account.

ENFORCEMENT

FreshPay regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or FreshPay’s treatment of personal information by contacting us through this website.

CHANGES TO THIS POLICY

Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Policy without your explicit consent. We will post on our Web Pages any Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including notification in your account interface or SMS notification). Each version of this Policy will be identified at the top of the page by its effective date, and we will also keep prior versions of this Privacy Policy in an archive for your review.

If you have any questions about this Policy, please feel free to contact us through our website or write to us at  info@gofreshbakery.com.

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