RealPay and its businesses adhere to a set of core RealPay privacy principles.
These principles apply to all persons and organisations whose personal information (also referred to as personal data) we hold. We focus in particular on the following core principles:
1.1 Payment processing: RealPay shall receive from the User all lawful and accurately captured Payment Instructions delivered to RealPay timeously for onward transmission to the bank.
1.2 Collect and retain the personal information we need: RealPay shall provide the User access to industry compliant software, enabling the User to capture and deliver Payment Instructions.
1.3 Maintain data integrity: of Payment Instructions submitted by the User and accepted by RealPay, by not applying any amendments thereto, unless specifically instructed to do so by the User in writing.
1.4 StrictlyadheretoallActs,Statutes,Conventions and Directives:relating to the Service as may now or in the future become applicable.
1.5 Terms and Conditions of this Privacy Policy (“Policy”) is subject to the Parties responsibilities and obligations outlined in the RealPay Contract
Personally, Identifiable Information is information that identifies a specific person. When you engage in certain activities via the RealPay Service, including but not limited to creating an account, sending feedback, or otherwise participating in the RealPay Service (collectively, “Identification Activities”), we may ask you to provide certain information about yourself.
If you elect to engage in an Identification Activity we may ask you to provide us with certain personal information about yourself, such as your name, address (including zip code), email address, telephone number and/or any other information you provide to us, to process your transaction, send communications about them to you, and populate forms for future transactions.
Depending on the Identification Activity, some of the information we ask you to provide may be identified as mandatory and some identified as voluntary. If you do not provide mandatory information for an Identification Activity, you will not be permitted to engage in that Identification Activity with the RealPay Service. Depending on the Identification Activity, RealPay might not re-ask you for Personally Identifiable Information if such are already stored with us.
If you enrol in the RealPay Service through a third party (such as Facebook or Google) then RealPay may receive Personally Identifiable Information from such third party and by using the RealPay Service, you consent to such receipt of Personally Identifiable Information and its use pursuant to this Privacy Policy by RealPay.
We may use or share Personally Identifiable Information to provide products and/or services to you, to enable Third-Party advertisers to provide products and/or services to you, administer sweepstakes and contests, enhance the operation of the RealPay Service, improve our marketing and promotional efforts, analyze use of the RealPay Service, improve the RealPay Service, and tailor your experience with third parties as provided below in this Privacy Policy.
We may also use Personally Identifiable Information to troubleshoot, resolve disputes, accomplish administrative tasks, contact you, enforce our agreements with you, including our Terms of Service and this Privacy Policy, comply with applicable law, and cooperate with law enforcement activities.
2.1 How we use your personal data. In this Section 2 we have set out: (a) The general categories of personal data that we may process; (b) The purposes for which we may process personal data; and (c) The legal bases of the processing.
Payments Data (or Transactional Data): This data includes 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;
2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, Apps, payment platforms and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
2.4 We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
2.5 We may process information contained in any inquiry you submit to us regarding goods and/or services ("inquiry data"). The inquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
2.6 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include first and last names, an email address to be used as a login, billing contact information and a password. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests.
2.7 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
2.8 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
2.9 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.11 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
We may also collect, use and share non personal information or anonymised data such as statistical or demographic data.
As a principle, we do not collect any Special Categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
3.1. We may disclose your personal data to any member of our group of companies, this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2. Financial transactions relating to our website and services may be processed by RealPay, as a registered service provider, and will share transaction data, upon request and subject to the provision to disclose information that is lawfully required by any court, government, lawful authority, Bank or regulatory authority.
3.3. We may disclose your inquiry data to one or more of those selected third-party suppliers of services via APIs identified on our website for enabling them to connect your account with their Services. Each such third party will act as a data controller in relation to the inquiry data that we supply to it. Each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.
3.4. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
We use Non-Personally Identifiable Information to troubleshoot, administer the RealPay Service, analyse trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We may also share this information with our authorized Third-Party Service Providers to measure the overall effectiveness of our products and services. We have summarized the rights that you have under data protection law. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
a. the right to access
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
b. the right to rectification
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
c. the right to restrict processing
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest
d. the right to object to processing
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public.
To the extent that the legal basis for our processing of your personal data is: Consent;
that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
e. the right to data portability.
the right to complain to a supervisory authority
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
f. the right to withdraw consent.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal
Contact us:
RealPay has appointed a data protection officer (DPO). If you have any questions or want to report a privacy concern you can contact us at info@realpay.co.za