Maisha Cash Privacy Policy

PRIVACY POLICY 

Maisha Cash is dedicated to handling Your information in an open and transparent manner while also preserving and respecting Your privacy.

 

You attest that you understand and agree to the collection, use, disclosure, and processing of your personal data (or the personal data of any individual you provide) as described in this Privacy Policy by continuing to interact with us, such as by submitting information to us or using our services.

 

We reserve the right to update or modify this Policy on a regular basis to reflect modifications to relevant law or changes in our procedures for processing personal data. We urge you to carefully read this Policy and to visit this page often to review any updates we may have made to its terms.

Who are we?

‍Maisha Cash is powered by Groupe Financier Salane inc and Salane Financial Group inc.

Definitions

To help clarify our meaning, we have used certain capitalised terms in this Policy. These terms and their meaning are:

“Customer” means any individual who has registered with us or used any of our Services or inquired about any of our Services.

“Privacy Laws” means the Personal Information Protection and Electronic Documents Act 2000 (the ‘Act’), and 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 Maisha Cash Money Transfer Service; Maisha Cash Digital Money Account; Airtime Top Up; and such other services or products that we may introduce from time to time.

The personal information we collect about you

Information about you may be gathered, recorded, and used by us in both hard copy and electronic forms. We will save, use, and handle your data in compliance with applicable privacy laws and this policy.

The personal information we collect and use may include, amongst other things:

• details of the transactions you carry out when using our Services, including the geographic location from which the transaction originates;
• technical information, including the internet protocol (IP) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and, if you’ve installed the App, installed applications on your mobile device that have remote access permissions;
• Details about your visit, such as the entire Uniform Resource Locators (URL) clickstream to, through, and from our Website or App (including date and time), the products you viewed or searched for, the length of visits to specific pages, the download errors that occurred, the methods you used to navigate away from the page, and the products you viewed or searched for;
• information about your marketing and communication preferences.

When You give us information about another person, we also gather that information from You (such as the recipients of Your money transfers). By giving us this information, you attest to our having received all required consents from them for the fair use of their data for the goals and in the ways specified in this policy, or that you have other authorization to provide this data on their behalf. Additionally, kindly make sure that those other individuals are informed of this notice and its contents in a clear and understandable manner.

Sensitive personal information

Sensitive personal information is a category for some types of data. This includes details or opinions regarding a person’s political views, philosophical or religious affiliations or beliefs, membership in trade, professional, or political associations, sexual preferences or practices, criminal history, health or genetic information, or biometric data used for biometric verification or identification.

We will only collect, hold or disclose Sensitive Information if You have consented, or the collection is required or authorised by or under Privacy Laws or a court / tribunal order.

How we collect your personal information

• Information You give to us when You use our services.

If you make use of our offerings You will be required to furnish specific details, such as your name, address, and credit card number, in addition to the recipients’ names and other information for any money transfers you direct us to execute. If this information is not accurate and full, we might need to take further action in order to finish the transaction.

• 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.

• Other information You give to us.

This is information that you provide to us about yourself when you participate in contests, surveys, or questionnaires concerning our goods or services, or when you fill out forms on our website (such as the “contact us” section). It includes the data you submit, for instance, when you register on our website so we can get in touch with you, when you ask questions about any of our services, or when you report an issue with our website. Your name and email address are only a couple of the details you may provide to us.

• 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 might add information we already have about You to that which we learn about You from other sources, such as publicly accessible databases. This aids in the expansion, updating, and analysis of our records and enables us to offer services that might be useful to you.

• Information we collect about You.

Like most websites, we use “cookies” to improve both our site and how You use it. Cookies allow a website to keep track of you. Websites download these brief text files to your computer (or phone / tablet). They increase the usability and performance of websites by, for instance, automatically entering your address and name in text boxes.

• 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.

• Social Media Widgets.

Social media features and widgets, like the Facebook Like and Twitter buttons, are interactive mini-programs that operate on our website and offer particular services from other businesses (e.g. showing the news, thoughts, music, etc). Through the Widget, personal data, including your email address, might be gathered. The Widget may also set cookies in order for it to work properly. The privacy policy of the firm that built this widget governs the information gathered by it.

Personal information from third parties.

In the event that we obtain personal information about you from a source other than you or ourselves, we will assess whether or not we might have obtained the data in compliance with this policy and applicable privacy laws. If so, we will retain the data and manage it in compliance with this policy as well as any relevant privacy laws. If it is reasonable and legal for us to do so, we will erase or anonymize the personal information if we determine that we could not have gathered it in compliance with this policy and any relevant privacy laws.

Mobile App.

In addition to the data already stated, we also gather information about the kind of device you use, the version of your operating system, and system and performance details when you download our mobile app. Periodically, we might send You push notifications to inform You about events or possible promotions. You can disable these kinds of messages at the device level if you’d like to stop receiving them. We may employ mobile analytics software to better understand the functionality of our mobile software on Your device. We will need to gather some information about Your device, such as the operating system and user identifying information, in order to guarantee You receive the right notifications. This software may record information such as how often You use the Mobile App, the events that occur within it, aggregated usage, performance data, and where the Mobile App was downloaded from. We do not link the information we store within the analytics software to any personal information You submit within the Mobile App.

Cookies and similar technologies

When you visit our website or use one of our mobile apps, we may put cookies or other similar trackers (referred to as “Cookies”) on your device, or we may read existing Cookies. However, where it’s required and in accordance with the law, we will always obtain your permission. We use cookies to record information about your device, browser, and maybe even your surfing preferences. 

How we use your personal information

Our main goal in gathering user data is to fulfill your requests for services and to give You a secure, easy, effective, and personalized experience. In order to make sure that the content on our website is presented as effectively as possible for You and Your computer or device, we may additionally use the information you have provided.

We use Your information for the following specific purposes:

• 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;
• to register You with a Maisha Cash account;
• to fulfil Your Transaction / (Airtime Top Up) Request;
• to send You confirmations;
• to notify You about temporary or permanent changes to our services or other service-related messages;
• to assist you where online applications are not completed;
• to prevent fraud, money laundering, and any other illegal activity that may cause you, us or others harm including in relation to the Services;
• comply with our legislative and regulatory requirements in any jurisdiction;
• to ensure that content from our site is presented in the most effective manner for You and for Your computer;
• to promote our business;
• to send You Marketing communications except you tell us not to do so.
• to administer our site and for internal operations, including troubleshooting, data analysis, profiling and segmentation analysis, testing, research, statistical and survey purposes;
• as part of our efforts to keep our site, Mobile App and our services safe and secure;
• to measure or understand the effectiveness of advertising we serve to You and others, and to deliver relevant advertising to You;
• to make suggestions and recommendations to You and other users of our site about services that may interest You or them;
• to train, monitor and assess the effectiveness of the manner in which we provide the Services to You; 
• to consider and investigate any concerns or complaints you may have; and
• 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.

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Our legal grounds for processing your personal information

We only use your personal information for a specific purpose, and before we do so we must have a legal reason. Subject to applicable law, we will use your personal information where:

• We have obtained your prior consent to the processing.
• Processing is necessary:
  •  for the performance of a contract, or to take steps prior to entering a contract with us; 
  •  for compliance with any legal obligation which we are subject to other than the obligation imposed by a contract; 
  •  to protect your vitally important interest; 
  •  for the administration of justice;  –
  • to respond to a national emergency, comply with the requirements of public order and safety, or to fulfill functions of a public authority; 
  •  for the exercise of any functions conferred on any person by or under any law; or 
  •  for our legitimate interests or that of a third party (to the extent that such legitimate interests are not overridden by your interests).

Direct Marketing

If allowed by relevant law, we may use the contact information you gave us to send you marketing messages about comparable goods or services via email, phone, direct mail, or other communication forms (unless you have opted out). 

In other situations, we might contact you with marketing materials regarding goods and services that Maisha Cash and other affiliates are offering, but only with your permission.

Opting Out of Direct Marketing

If you have a Maisha Cash account, you may change your email or SMS subscriptions by clicking the unsubscribe link or by adhering to the opt-out message that will be included in the message. This will allow you to choose not to receive Maisha Cash marketing messages. 

Alternatively, simply send an email to help@maishacash.com with “URGENT – UNSUBSCRIBE REQUEST” in the subject line and the email address that you wish to be removed within the email.

We may still send you service and administrative communications (such transfer updates and other crucial or transactional information) even if you ask us to stop sending you marketing messages.

Who we might share your personal information with

We value the privacy of your personal information very much. Nonetheless, there are situations in which we must disclose your information in compliance with the law, as well as any applicable professional and regulatory obligations pertaining to professional secrecy and confidentiality. Furthermore, we might give your personal information to:

• Our affiliates

We share your information with Maisha Cash and other companies within the Salane 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.

• affiliates, business partners, suppliers and subcontractors for the performance and execution of any contract we enter into with them or you and to help them improve the services they provide to us;
• advertisers and advertising networks to select and serve relevant adverts to you and others;
• analytics and search engine providers that assist us in the improvement and optimisation of our site;
• our group entities and subsidiaries, which can be found by clicking here;
• in the event that we sell any of our business or assets or combine with another organisation, in which case we may disclose your personal data to the prospective buyer of such business or assets or prospective organisation with which our business or assets may be combined;
• limited information is sent to payment beneficiaries when you initiate a payment transaction;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Customer Agreement and other applicable agreements, or to protect the rights, property, or safety of Wise, our customers, our employees or others;
• to help us conduct or collaborate with investigations into fraud or other criminal activities when we feel it is reasonable and appropriate to do so, as well as to prevent and detect fraud or crime. Please be aware that we reserve the right to refuse to supply the services that are requested or to cease offering our current customers’ products and services if we or a fraud prevention agency judge that there is a danger of fraud or money laundering. The fraud prevention agencies will keep a record of any fraud or money laundering risk, which may cause others to decline to supply services.
• in response to a subpoena, warrant, court order, properly constituted police request or as otherwise required by law;
• to assess financial and insurance risks;
• to recover debt or in relation to your insolvency or to allow a party or a financial institution that sent money to recover money received by you in error or due to fraud;
• to develop customer relationships, services and systems; and
• if you consent, to share your details when using our Services

Facebook – Any actions you take on our website, including visits, interactions, usage of Facebook Connect, and data gathered from cookies or related technologies like the Facebook Pixel, may be shared with Facebook. This enables us to track the success of our advertising, enhance our marketing strategies, and provide you and others who are similar to you with more relevant advertising (including on social media like Facebook). Because of this agreement, Maisha Cash is required to give you this notice; however, if you would like to exercise your right to data protection, you should speak with Facebook. Facebook’s Data Policy contains more details, such as how it allows you to exercise your rights regarding data protection and how it uses your information after that. 

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, available at tools.google.com/dlpage/gaoptout.

Research companies – We might securely share your personal information with research firms and feedback providers so they can get in touch with you directly to ask for your thoughts on the surveys or research, or to decline participation altogether.

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International transfer of your personal information

Owing to the global scope of our operations, we might be required to disclose your personal information to other Maisha Cash/Salane group of companies, recipients, and other third parties as mentioned in the section of this policy titled “Who we might share your information with.” We may, therefore, send your personal information to other nations that might not have the same laws and regulations for data protection compliance as your own country.

 

When recipients are based outside of Canada, we make sure that the information will be protected by measures such as contractual clauses, safeguards similar to Canada’s privacy laws, or by making sure the recipient is governed by laws in another country that offer similar protections to Canada’s privacy laws.

We also ensure that our data protection and information security controls applying to your personal information in Canada continue to apply in the hands of our affiliates or contracted service providers located overseas.

How we keep your personal information secure

In compliance with applicable law, we have put in place the necessary organizational and technical security measures to guard your personal information against unauthorized access, disclosure, alteration, accidental or unlawful destruction, and other unauthorized or unlawful forms of processing.

 

Regrettably, information transmitted over the internet—including over email—is not entirely secure. Despite our best efforts to safeguard Your personal information, any submission of Your data to our site is at Your own risk and we are unable to guarantee its security. We shall attempt to prevent unauthorized access using stringent procedures and security features once we have acquired Your information.

Your Rights

Subject to applicable law, you may have a number of rights regarding our processing of your relevant personal information, including:

• the right not to provide your personal information to us (however, please note that we may be unable to provide you with the full benefit of our site, our Mobile App, or our services, if you do not provide us with your personal information);
• the right to request access to your personal information, together with information regarding the nature, processing and disclosure of those personal information;
• the right to request for the correction of any inaccuracies in your personal information;
• the right to prevent processing for direct marketing purposes as stated in the “Direct Marketing” section of this policy;
• 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) this right is subject to contractual or legal restrictions as may be applicable; and
• the right to lodge complaints with the Office of the Privacy Commissioner of Canada regarding the use of your personal information by us or on our behalf.

Before we can put these rights into action, we might need documentation proving your identity. Additionally, keep in mind that some of these rights are qualified and not unqualified, thus there may be exclusions or restrictions. For instance, we may decline to provide information if doing so would require disclosing the personal information of another individual, or if you ask that information be deleted that we are legally obligated to keep, have compelling legitimate interests in keeping, or require access to in order to comply with legal requirements.

You can contact us at help@maishacash.com if you want to enforce any of these rights. We will comply with our legal obligations as regards Your rights as a data subject. 

All requests for access to Your personal data must be made in writing, and we promise to get back to you as soon as possible. This will usually happen 30 days after the date of your request. If the situation warrants it, we might extend this time frame. In cases where requests are clearly excessive or unwarranted, we have the right to refuse to reply or to charge a reasonable price (which reflects the costs of supplying the information). In such cases, we shall notify You of your rights and explain the situation to you.

How long will we keep your personal information for

We make every effort to guarantee that your personal data is only kept for as long as necessary to fulfill the objectives outlined in this policy. Consequently, we will only retain the data we gather about You for as long as it’s necessary to fulfill the aforementioned goals or to ensure that we abide by any applicable laws or regulations. This will entail our routinely going over our files to make sure the data is correct, current, and still needed.

 

Depending on the type of information and the purposes for which we use it, we may keep information about You for a different length of time. In general, we will retain our records for as long as you are a customer of ours and for six years following the termination of your connection with us, unless relevant law mandates a different retention period.

For more details of the retention periods we apply to your personal information please contact help@maishacash.com

How to make a privacy complaint?

Please use the contact us page on our website or send an email to help@maishacash.com if you think there has been a violation of the Act or any parts of this Policy, or if you have any questions regarding how Maisha Cash is treating your personal information. The Privacy Officer should be the recipient of your privacy complaint.

 

Please note that we aim to respond to complaints within thirty (30) days of receipt. If you are not satisfied with our response to your complaint, you can also refer your complaint to the Office of the Privacy Commissioner of Canada by:

Writing to: 30 Victoria Street, Gatineau, Quebec K1A 1H3 Canada

Telephone: 1-800-282-1376 (Toll free)