Privacy & Conditions
CBA BL Limited.(“We”, ”Us”, “WingiPay”) recognize the importance of privacy and security of our customers' personal information. We value the trust you place in us to protect your personal information and respect your right to privacy. While new technologies have dramatically changed the way information is gathered, used and stored, preserving customer trust and the privacy of personal information at WingiPay remains a core objective. We believe it is important to make clear to our customers how information is being collected, used and shared at CBA BL Ltd, the benefits such use provides, and the protections put in place against unauthorized access and use. We respect your privacy and the confidentiality of your personal information, and we appreciate the opportunity for doing business with us.
Our commitment is to put users first. We strive to be transparent about how we collect and use your information, to keep your information secure and to provide you meaningful choices.
1. Our Privacy Principles
We will only collect, transfer, process and store your personal information with your express permission unless legally required to do so and will only use such information for the lawful purpose for which it is required.
- We will disclose the specific purpose for which we use, request and store your personal information.
- We will also keep a record of that personal information and the specific purpose for which we collect it.
- We will not use your personal information for any other purpose, other than that which we disclosed to you, unless you give us your express consent to do so, or unless we are permitted to do so by law.
2. Information we collect
2.1 We may collect information from you when you register on our mobile app. We may collect your name, e‐mail address, phone number, date of birth, gender, residential address, ID number, device ID, and device location depending on how you choose to register on our mobile app.
2.2 We may collect your bank card details including the numbers displayed on the card (Primary Account Number), the Expiry Date, the CVV2 (normally found at the back of the card) and or Card PIN from you during registration using our services. For registration using WingiPay services, we will collect for your Username and Password. Generally, we may also collect other personal information from our database system as part of your registration profile creation in the mobile app
2.3 We may collect and combine information when you register on our platform including information you provide to us, device IDs, cookies, and other signals, including information obtained from third parties, to associate accounts and/or devices with you. We collect information about you when we receive it from third parties and affiliates.
2.4 We may collect information from devices such as mobile phones and tablets about how you interact with our services and those of our third-party partners and information that allows us to recognize and associate your activity across devices and services. This information includes device specific identifiers and information such as IP address, cookie information, mobile device and advertising identifiers, browser version, operating system type and version, mobile network information, device settings, and software data.
3. How we use the information we collect
3.1 Services: We use your collected data to authenticate you and authorize access to our Services on the mobile app. Typical services may include customer registration, performing financial transactions, subscribing to insurance products, card management services, account management
services, payment of bills among others. We use your personal data to enable you perform the services listed below among others;
i. Customer Registration using our platform
ii. Payment of Bills
iii. Airtime Purchase
iv. Funds Transfer to an electronic wallet
v. Funds Transfer from a bank account to another bank account within the same country.
vi. Create and TopUp Virtual Cards
vii. TopUp Prepaid Cards
3.2 Communication: We will contact you through email, short message services (SMS), phone call, and other ways through our Services and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services and network updates.
3.3 Advertising: We serve you tailored advertisements both on and off of our Services. We may target advertisements to our customer both on and off our Services through a variety of ad networks and exchanges, using data from advertising technologies on and off of our service and information from advertising partners, publishers and data aggregators.
3.4 Marketing: We use data and content about our customers for invitations, promotions and communications solely for promoting our services.
3.5 Customer Support: We may use the data gathered to investigate, respond to and resolve complaints and Service issues.
3.6 Security, Fraud and Investigations: We may use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our User Agreement or this Privacy Policy and/or attempts to harm others
4. Legal Basis for Collecting and Processing Data
We collect and process personal data only when we have a legal basis for doing so. Data protection legislation gives us a list of possible legal basis. The following provide legitimate basis for processing personal data on our mobile app on web app.
- Consent given by our customers
- Performance of contract between the Bank and customers or third parties
- Legal Obligation due to Government banking laws and regulations and
- Legitimate interest of our company.
5. How we secure your information
Protecting our systems and our users’ information is our prime focus to ensuring our brand, websites, apps, advertising services, products, services or technologies (“Services”). To ensure our utmost customers enjoy a secure experience and trust. We have taken the following measures to protect their information:
5.1 We have the technical, administrative and physical safeguards in place to help protect against unauthorized access, use or disclosure of customer information we collect or store.
5.2 We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information.
5.3 We offer the use of a secure transmission, processing and storage services using standardized security safeguards.
5.4 All supplied sensitive/credit information are encrypted via transaction layer security (TLS) technology during transmission to avoid misuse of your data. Card Number (PAN), CVV and expiry date of any bank cards attached to the Mobile App are tokenized and stored on our system. We encrypt and/or hash all sensitive personal and transactional data during processing and storage.
5.5 Your personal information may be accessible only by those authorized, and having special access rights, authorized individuals are required to keep the information confidential. Information such as PINs and passwords are not accessible to our authorized personnel.
7. What choices do you have about your information?
7.1 Data Retention: We keep all your personal data for as long as your account is active. We retain the personal data that you provide while your account is in existence or as needed to provide you with our services.
7.2 Rights to Access and Control Your Personal Data: You may access your personal data from our services when you follow our procedures on data subject requests. You can always modify or update your personal data using our service apps.
When you wish to deactivate your account with us, you are required to send a request to privacy@wingiPay.com. We shall contact you within fourteen days to validate the request for processing. A de-activated account may still have transactional history kept on our systems in accordance with financial laws and our data retention policy.
7.3 Account Closure: We may retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security and prevent fraud.
8. Protecting Children’s Privacy
Our services are for a general audience. We do not knowingly collect, use, or share information that could reasonably be used to identify children under age 13 without prior parental consent or consistent with applicable law.
9. How to contact Us
If there are any questions regarding this privacy policy or a data breach incident you would like to report on, please contact us by email or write to us using the information provided below;
Address:
Data Protection Manager
Accra, Ghana
Email: privacy@wingiPay.com