Privacy Policy
SCOPE
This Privacy Policy applies to the payment products and services provided by LINKEDPAY, SOCIEDADE PRESTADORA DE SERVIÇOS DE PAGAMENTOS, S.A., hereinafter referred to as LinkedPay.
In the event that one of the products/services provided by LinkedPay has a specific Privacy Policy, the Privacy Policy of that product/service shall take precedence. For content not covered by it, the content of this Privacy Policy shall prevail.
If you have any questions, complaints or comments related to the policy, please contact LinkedPay at the following contact details:
-Via e-mail (suporte@LinkedPay.co.ao); and
- Mobile number: +244 945291843.
LinkedPay is committed to analyzing the reported problems as soon as possible and, after confirming the identity of the complainant, will respond within the deadlines defined by Law.
LinkedPay attaches great importance to protecting the privacy of the user, also referred to as the "Customer".
The privacy policy will help the Client understand the following:
1. Procedures for collecting information;
2. Procedures for the use of cookies and similar technologies;
3. Information storage and protection procedures;
4. Procedures for the use of information;
5. Procedures for providing information to third parties;
6. Procedures for you to access and manage your information;
7. Declaration of responsibility for third parties;
8. procedures for the protection of the rights and interests of minors;
9. Procedures for updating the policy.
The process of using LinkedPay's products/services presupposes the automatic collection of information based on different situations and according to the defined methods.
The information you provide when using the service may be used to optimize the quality of our services, ensure the security of your accounts, funds and comply with legal requirements:
I. Comply with obligations related to the Anti-Money Laundering and Countering the Financing of Terrorism Act and perform identity management in accordance with the Act.
II. By registering, the Client registers an account in the application.
When authenticating for the first time, you will be required to provide your basic identity information such as name, personal details and mobile phone number (details can be found in the Terms and Conditions).
If the Client does not provide the information mentioned above, he/she will not be able to register and, consequently, prevented from using the products/services.
In case of requiring enhanced validation, the Customer must provide the information and the mobile phone number registered with the Bank.
In the event that the Client does not provide the information mentioned above, he or she will not be able to use the service that requires enhanced identity verification.
In order to verify the accuracy, truthfulness, authenticity and completeness of the information submitted by the Customer, LinkedPay reserves the right to consult and validate the information provided with the government agencies responsible for providing the information as well as with its associated Commercial Bank in its LPay account, if applicable.
· In order to ensure compliance with the Law, the Client undertakes to provide personal information, including, but not limited to, your name, contact, occupation, number and expiration date of identity documents.
In specific circumstances, in accordance with the law, regulations and regulatory requirements, the Client will be obliged to provide the updated colour copy of the identity card or photograph. In specific circumstances, you may be required to provide the color photo.
If the Client does not provide the information indicated, LinkedPay reserves the right not to accept the registration.
III. Information Required at the time of Registration or use of the LinkedPay product/service.
Based on LPay's application and other software, we provide you with payment services. We offer the possibility of purchasing various products and services.
For example, you may use our payment products and services to make purchases in registered online stores, transfer to third parties, pay for electricity, water, etc.
Based on your need to use the corresponding payment service, we may request your personal information in the following ways:
· In order for you to be able to use your digital wallet balance payment service, we will record your wallet balance information and transaction information if you do not agree, you will not be able to use the service.
· In order to be able to use the transfer service, clarify and execute your payment instructions, you need to provide the payment password, the name and amount of the transfer, and the mobile phone number of the recipient according to the product page. If this information is not provided, you will not be able to make the transfer, which, however, will not affect the use of other functions available in the LPay application.
· When you use the payment service for energy, water, etc., you may be required to provide your mobile phone number, name, identification number, home address and other information according to the specific scenarios.
· In accordance with the laws and regulations to provide the information enquiry service, when the Client conducts transactions through the LPay application, it will be necessary to record and manage the transaction information. For this purpose, it will be necessary to collect information related to the transaction directly or through the partner merchants (including transaction number, name of both parties, transaction amount, time of transaction, product name, payment method, delivery information, etc.). If you do not agree to record the transaction information, you will not be able to complete the transaction.
· If you use other functions of services provided by the LPay application that require the collection of personal information, LinkedPay undertakes to explain separately the purpose of the information collection and will be subject to your consent.
1. Information That Needs to Be Collected for the Security of Your Account, Funds, and Payments
Identification Authentication
1.1 Access Authentication
In order to access your LPay account with more security and convenience, you will need to create an access password and a payment password to make transactions.
1.2 Money Order Verification
When you use a payment account for transactions, you will need to verify your identity to ensure the security of your account and funds.
LinkedPay may provide various ways to authenticate your identity and you may choose to use your static password, digital certificate, electronic signature, one-time password or biometric information to complete verification.
Whenever the level of risk increases, LinkedPay may request that you validate the data. If you do not agree to provide the above information, you may not complete the transaction, which will not affect your use of other services.
In order to be able to use the payment service in a more secure and convenient way, and if the equipment and version of the LPay Application support the fingerprint function or the facial recognition function, the Customer may choose to use the payment service by fingerprint or facial recognition. You will need to enter your fingerprint or facial recognition information on your device.
Whenever you make a payment by fingerprint or facial recognition, you will need to complete the verification of the information on your device. LinkedPay will only collect verification results and not your fingerprint or facial recognition information. If you do not want to use fingerprint verification or facial recognition, you may pay in other ways.
1.3 Operational Behavior Verification
To ensure the security of your account and funds, you will need to verify your identity whenever you need to recover your password, report the loss of your account on the App, freeze transaction funds or request an electronic receipt.
You will need to provide some information that can identify you, such as a copy of your identity card, contact information, a certificate that can prove the transaction, and a certificate that proves that you have legal rights to the payment account and the funds in the account. If you do not agree to provide this information, you will not be able to complete operations such as recovering payment passwords, reporting account loss, freezing transaction funds and requesting electronic receipts, but this will not affect the completion of other transactions or use the other functions.
1.4 Safety Management
To improve the security of the use of our services and to prevent risks, we may collect information about the use of LinkedPay's services, including the device's hardware model, device identifier, information about the version of the software you use, IP address, region, mobile network information, standard network log data and network usage habits, and LinkedPay's service operations log.
In the event that the Client does not agree to provide the above information, it may affect the security check of the trading environment.
1.5 Collection of Information Through Third Parties
In the event that LinkedPay needs to indirectly obtain your personal information from a third party for the purpose of providing services, we will clearly show the source, type and scope of your personal information before obtaining it.
1.6 Situation in which the Client authorizes LinkedPay
To make the use of the LPay App more accessible, your personal information may be collected and used in the following additional settings. If you do not provide it, it will not affect the use of the LPay App, you may, however, not be able to use some specific functions or you will need to manually fill in some information repeatedly.
1.6.1 Read and Storage Enrollment Permissions: When you install the LPay App, you will be asked for this permission. The aim is to ensure the stable operation of the Application.
The Application will read or store the necessary information.
1.6.2 Enabling Location Services: Only location information will be collected at that time and your location will not be tracked. After enabling the location service, you will be able to obtain your location information directly.
1.6.3 Camera Access Permission: You can use the camera to scan documents, take photos directly and upload them for sharing. If you need facial recognition, you will need to turn on the camera for this.
1.6.4 Album Access Permission: By opening the Album Access Permission function, the Customer can directly select the photos or images on their mobile phone to comment or provide evidence to Customer service about the products/services purchased.
1.6.5 Permission to access the Contact List: When you recharge your mobile phone and fill in the contact information, you will be able to use the information in the contact list. After opening and giving this permission, you will be able to directly select and import the selected contact information from the contact list. Only the selected contact information will be loaded.
1.6.6 Calendar Access Permission: When using LPay's calendar function to manage its personalized events conveniently, you need to open this function by setting the system calendar-based reminder function for important matters.
1.6.7 Enabling Microphone Permissions: Customer may use voice assistant search to find specific services or implement voice communication when communicating with Customer service. After choosing, enabling permissions, if you click on the voice button to record sound, your voice content will be collected for the necessary processing.
If you do not provide this personal information, it will not affect your use of the app, but you may not be able to use the specific functions or you may have to manually fill in some repetitive information.
1.7 Special Situations of Collection, Use and External Supply
In accordance with relevant law and regulations, in the following situations, we may collect, use or provide your personal information to third parties with or without your consent:
· Defense and national security;
· Safety, public health and major public interests;
· Criminal investigation, prosecution, trial and execution of sentences;
· Protection of your life and other persons, property and other legal rights;
· Information of a public nature or information obtained from public sources;
· Other situations defined by laws and regulations.
1.8 Other
The Client must understand that the services that LPay provides are constantly updated and developed. If you choose to use other services that are not covered in the previous instructions, and LinkedPay needs to collect information based on the service you have opted for, LinkedPay will separately explain the scope and purpose of the information collection by means of on-page alerts, interaction processes, agreements and LinkedPay will obtain your consent. LinkedPay will use, store, provide to the outside world and protect your information in accordance with this policy and the corresponding user agreement. If you choose not to provide the above information, you may not be able to use a service or part of the service, but this will not affect LPay's use of other services provided. By accessing the service page operated by a third party, the Customer will have access to the services provided by the third party. If it involves the collection of personal information, it is recommended that you carefully check the Privacy Policy or agreements defined by these entities.
2. Use of Cookies and Similar Technologies
2.1 When using LinkedPay's products/services, your password access may be saved, allowing you to assign one or more "Cookies" (a small text file). For example: when you access information or a service that requires your password, when you access the password, the password name will be encrypted and stored in your computer's Cookies file. Because it is irreversibly encrypted storage, even if other people can use your computer, they will not be able to recognize your access name. You don't need to do any extra work. All the work of collecting, storing, and encrypting is done automatically by the system.
2.2 The Cookie file will be saved on your computer's hard drive or in the flash memory of the device's terminal and can only be read by the server that configured them.
2.3 In order to provide the most convenient, fast, easy, and personalized services to the Customer, we will provide the following services through Cookies and other technologies:
Ø Remember your account. For example, the Cookie can help eliminate the need to repeatedly enter an account to use LinkedPay's products/services.
Ø Analyze the use of LinkedPay's products/services. For example, we may use Cookies and other technologies to understand the specific use of LinkedPay's services or which web pages or services are most popular for you;
Ø Advertising optimization. We may show you product or advertising information that may be of interest to you based on statistical information about your visits to related websites. This statistical information does not include any personal information that can be used to measure the effectiveness of advertising. Cookies and other technologies help us deliver related advertising based on your information and not provide general advertising.
Ø We may also use web beacon technology to compile anonymously accessed data. Similarly, this statistical information does not include your personal information;
Ø You can also choose "not to use Cookies" in your browser. If you choose to do so, it may affect your use of some products/services or you may not enjoy a safer, faster, easier and more personalized product/service. However, this will not affect the normal use of other products/services we provide.
Ø Cookie and web beacon technologies may also be provided by LinkedPay's partners. The collection and use of such information by Cookie and web beacon by them is not subject to this policy, but is subject to the Privacy Policy of those partners. We suggest that you carefully read and decide whether or not to comply with the Privacy Policy of the partners before using the services provided by them through Cookie and web beacons.
3. Storage and Protection of Information
3.1 LinkedPay will store your personal information collected in the country of origin in accordance with laws and regulations and we will strictly keep this information confidential.
3.2 We will store your personal information on a need-to-use basis for your use of LinkedPay's products/services, and within the timeframes prescribed by law. By way of example, we will keep your identity information and transaction records in accordance with the timeframe stipulated by law and anti-money laundering and countering the financing of terrorism regulations. After the period prescribed by law, we will delete or omit your personal information in accordance with the law.
3.3 To ensure the security of your information, once we have collected it, we will take a number of reasonable and necessary steps to protect it. For example, in the technology development environment, we only use anonymous information for statistics and analysis. When providing research reports to the outside world, identification is omitted from the reports.
3.4 To ensure the security of your information, we will take reasonable and necessary steps to protect your information at the existing technical level. Adopt physical protection, security technology, management system and other measures to reduce the risk of loss, misuse, unauthorized access, disclosure and alteration, including but not limited to encrypted data transmission, firewall and encrypted storage, physical access control and information access authorization control. To this end, we have established a security program to prevent your information from being stolen by unauthorized access. All personal information is stored, encrypted, and placed on internal systems strictly protected by firewalls.
3.5 To ensure the security of your information, we have established a special management and organization system to ensure the security of the information. For example, we strictly limit the number of people who access the information and require them to comply with confidentiality obligations and perform audits.
3.6 When using the LinkedPay product/service, please keep your LPay account and password with care, as we will identify your identity through your account and password. If you lose it, you may lose your information with legal consequences. If you lose your password for any reason, you should contact LinkedPay immediately so that we can take appropriate action in time to prevent or reduce related losses.
3.7 In the event of a security incident, such as the disclosure of personal information, we will initiate an emergency plan to prevent the spread of security incidents and will immediately inform you of the incidents via message, telephone and announcement etc. In the event that it is not possible to contact the customer under the above terms, LinkedPay will publish the relevant information and notices through its official website. We ask you to please stay tuned to the official website.
3.8 If you actively cancel your LPay account and terminate your use of the LinkedPay product/service, we will stop collecting and using your personal information, unless otherwise stipulated by law, regulations or regulatory authorities. If our products or services cease operations, we will also suspend the collection and use of your personal information in a timely manner. At the same time, we will notify you about the suspension of the operation by individual announcement or by posting on the official website of LinkedPay.
4. Use of Information
On the basis of relevant national legal provisions and regulations and with the aim of providing excellent products/services, permanently improving the quality of products/services, providing a safe, smooth, efficient and personalized experience (including supporting us in the development of new products or improving existing product functions), we may use your relevant information in the following situations and take sufficient measures to ensure safety during the use:
4.1 Based on the purpose of the above-mentioned collection and to provide LinkedPay's products/services.
4.2 Report to the relevant bodies in accordance with the requirements of the relevant national bodies and authority.
4.3 Whenever you use our services, the information you provide will be used for identity verification, customer service, security precautions, fraud monitoring, prevention or prohibition of illegal activities, archiving and backups to ensure the security of the products and services we provide.
4.4 Let us know how to access and use the LinkedPay product/service to meet your personalized needs.
4.5 To improve the experience of using the LPay application, we will recommend new services based on your information and habits through advertisements that may be of interest to you. If you do not wish to receive it, you can choose to unsubscribe from the agreement.
4.5.1 Other Customer-Authorized Uses
In the event that LinkedPay needs to use your personal information for purposes other than those specified in this policy, it will ask for your confirmation.
The customer consents to the sharing of their personal data with the regulator and operators of the Angolan Payment System, for the purposes of superintendence, management and operation of said system, and LinkedPay undertakes to safeguard compliance with the provisions of article 92 of the Angolan Payment System Law.
5. Provision of Information to Third Parties
Sharing with third parties
We will keep your personal information strictly confidential and may share it with third parties under certain conditions. We will keep your personal information strictly confidential and may share it with the third party's main party (hereinafter referred to as the third party) under certain conditions. Third parties are considered to be our related companies, partner Financial Institutions and other partners. Before providing your information, we will fully assess the legality, legitimacy and necessity of the third parties. If so, relevant legal documents will be signed with third parties and we will require compliance with the law whenever Customer's personal information is used.
In addition, specific contracts will be drawn up for each situation and the customer's consent will be obtained in the form of notices or we will confirm that consent has been obtained.
In the course of providing services and/or product functions, these may be made available substantially by us in conjunction with our partners or suppliers. The above services may only be provided to you when you share your personal information with third parties. For example, when you pay your mobile phone bill through the lifetime payment service, we will share the mobile phone information you provide with the partner telecommunications operator so that you can complete the payment.
To process your payment and receipt, we may share your information with your recipient. For example, when the third party uses LPay's service to transfer money to you, we will share a portion of your registration information so that they can confirm that the payment information is correct.
When you use LinkedPay's products/services through the third-party platform, if necessary, we may also share some of your identity information with them. If you do not agree to provide this information, you may not be able to use the services provided by third parties. For example, when you purchase goods or services through a third-party platform and pay through LinkedPay's products/services, we will send relevant payment information to the seller to help them complete the transaction.
We may cooperate with third parties to organize marketing activities and share some necessary information generated during the activities to complete them. In order for you to participate in the activities, our partners may contact you and distribute prizes, on the rules page of the activities or through other means. You will be informed in a timely manner about the type of personal information to be provided to third parties, in accordance with the requirements of the law.
5.1 Access to Third Parties
Whenever you access a third-party website through your LPay account so that you can use the third-party website conveniently and quickly, we may provide some of your personal information to the third party based on your explicit authorization and consent. These third-party websites are subject to their own privacy protection rules, so before providing your personal information to third parties, it is recommended that you carefully review the privacy protection rules of third-party websites.
5.2 Complaint Handling
In the event that we register complaints from others, we will provide their identity details and transaction information to INADEC and other bodies to resolve complaint disputes, unless prohibited by law.
5.3 Consultation of other Users
To ensure the accuracy of the transfer and receipt and to avoid the loss of funds due to incorrect data entry, the payer can consult their data such as email, mobile phone number or LPay account and profile.
Ø To comply with legal requirements and prevent fraud and reduce risk, we may exchange information with other financial entities and institutions.
Ø In accordance with legal provisions, the requirements of the competent authority or in accordance with laws to protect our legal rights and interests and those of our customers or with your express consent.
Ø In accordance with the "LinkedPay Services Agreement" and your relevant agreement to share with third parties.
Ø Other agreements regarding information sharing between the customer and LinkedPay
5.4 Transfer
We will not actively transfer your personal information to third parties except in the following cases:
· The transfer has been made with your express consent;
· In accordance with the legal provisions and the requirements of the competent authority, you will need to transfer your personal information.
In addition, when transferring or disclosing your information to a third party that compromises unrelated rights to complete the acquisition or transfer of funds, we will continue to protect or require partners to continue to protect your personal information in accordance with laws and regulations and no less than the standards set forth in this policy.
5.5 Public Disclosure
We will not disclose your personal information, if disclosure is necessary, we will inform you about its purpose, the type of information to be disclosed and the sensitive information that may be involved and we will obtain your express consent.
5.6 Service Outsourcing
In order to increase the efficiency of processing, information management and reduce costs, we may entrust a competent affiliated company or other professional organization to handle the information on our behalf. We will require the trust company to comply with strict confidentiality obligations and adopt effective confidentiality measures through written agreements, on-site audits, etc., and we will prohibit the use of the information for unauthorized purposes. When the delegation relationship is dissolved, the trust company will no longer hold personal information. We take responsibility for that.
· In accordance with the law, we may share, transfer and publicly disclose your personal information without obtaining your consent in the following situations:
Ø Directly related to national security and defence;
Ø Directly related to public safety and health and other public interests;
Ø Directly related to criminal investigation, prosecution, trial and execution of sentences;
Ø For reasons of defending important legal rights and interests, such as your life or that of others, personal property, but which are difficult to obtain your personal consent;
Ø Personal information you disclose to the public;
Ø Personal information collected from lawfully disclosed information, e.g., legal news, disclosure of government information, etc.
6. Consultation and Management of your Data
6.1 Upon cancellation, all information contained in your relevant account will be deleted and LinkedPay will not collect, use or share personal information related to that account. However, the above information will still have to be kept for the period required by the supervisor and the competent authorities who will continue to have the right to investigate for the period it is stored.
6.2 If you discover that we have collected or used your personal information in violation of the law, or in violation of a contract, you may contact online customer service or customer service to request deletion of your personal information.
6.3 If you discover that your personal information collected and retained is incorrect, you may contact online customer service or customer service to request correction. To ensure the security of your information, we first need to verify your identity and credential data. We have established a Customer complaint management mechanism that includes the follow-up process.
7. Statement of Liability for Third Parties
Please note that your transactions with the other party, the operators of the third-party websites you visit, the third-party services that are accessed through LinkedPay. For example: applications provided by third parties on the LPay application and the third parties that receive your personal information from LinkedPay may have their own privacy protection policies. When you visit web pages created by third parties or use applications developed by third parties, they may place their own Cookies or Web Beacons.
Such Cookies or Web Beacons are not under our control and use is not subject to this policy. LinkedPay will endeavor to request that these entities take steps to protect your personal information by suggesting that you contact them for details of their privacy policies. If you discover that web pages created by third parties or applications developed by third parties are risky, we recommend that you cease the relevant operations to protect your legal rights and interests.
8. Protection of the rights and interests of Minors
We take the protection of children's personal information very seriously.
In accordance with relevant laws and regulations, if you are a minor, it is recommended that your parent or guardian carefully read this policy and submit your personal information.
Minors can only join the LPay Application with the permission of their parents or guardians. If parents or guardians do not agree to the submission of their personal information or the use of the LinkedPay product/service, they must immediately suspend the submission of information or the use of our service, notifying us as soon as possible so that we can take effective action.
If you are a minor, in the event that we collect your information with the consent of your parent or guardian, we will use it only where permitted by law and regulations and with the explicit consent of the parent or guardian.
If you are a parent or guardian of a minor, when you have questions about the personal information of the minor under your guardianship, please contact us using the contact information above.
9. Updating the Policy
All LinkedPay products/services apply to this policy, unless a relevant service has a separate privacy policy or there is a special agreement in the corresponding user service agreement.
This policy will be updated when the following significant changes occur:
· Significant changes to the service model we provide for the purpose of processing personal information, the type of personal information processed and the manner in which the personal information is used, etc.;
· Significant changes in our entity, such as changes of ownership due to business adjustments, mergers and acquisitions from bankruptcy, etc.;
· Changing the primary purpose of the disclosure of personal information;
· Changing the period of retention or destruction of personal information;
· Significant changes in the way users access and control their personal information;
· In the event of a change in the authorities responsible for processing the security of personal information, contact details and complaint channels;
· When the personal information security risk assessment report indicates that there is a high risk.
Due to the large number of users of the platform, in case this policy is updated, the Client will be informed by means of a push notice from the Application, pop-up notice, sending emails, short messages or publishing advertisements on the official website of LinkedPay. In order for you to receive timely notifications, it is advisable that you inform us when you make the change to your data. If you continue to use LinkedPay's products and services after the policy update has been updated, you have fully read, understood and accepted the updated policy and are willing to be bound by it.