SOCIAL INSURANCE

Privacy Policy

1           INTRODUCTION & PURPOSE

This Privacy Policy spells out how Titan Payment System Limited (Titan PS, MyCashBox, Us, We, Our) will protect your information as you use MyCashBox, our digital financial services.

In order to operate an account on MyCashBox and to reduce the risk of fraud We will ask you to provide Us with information about yourself. By consenting to, and agreeing to the terms of this Privacy Policy, you expressly consent and agree to us processing your data in the manner set out in this document. This Privacy Policy describes the information we collect, how we use that information and how We secure it. We take the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Policy.

We will not sell your personal information to third parties for any purpose. However, in order to offer better services to you, we may share some or all of your personal information with third parties under Strict Privacy Restrictions. It is important for you to review this Privacy Policy as it applies you.

By accepting this Privacy Policy at registration, you expressly give your consent to our use and disclosure of the information you provide Us according to this Privacy Policy.

2           NOTIFICATION OF CHANGES

This Privacy Policy may be revised from time to time and the revised version posted on our website on the legal pages and will be effective at the time of posting. Where the change to this Privacy Policy is substantial in nature, we will provide users with at a 30 day prior notice. We will send the notice by e-mail, SMS and social media to inform you of the changes. After expiration of notice period, you will be considered as having expressly given your consented to all revisions to the Privacy Policy. If you disagree with the terms of this Privacy Policy, you may close your account on MyCashBox at any time.

3           THIRD PARTY WEBSITES OR PLATFORMS

In our operation, we may integrate with third party platforms and websites. These sites are governed by their own privacy statements and We shall not be responsible for their operations, including their information practices. Users should review the privacy policy of these third parties before submitting their personal information to or through them.

4           USERS UNDER SIXTEEN YEARS OF AGE

Users under sixteen years of age are not eligible to register and use our services on their own. Parents who wish that their children use MyCashBox can easily sign them up and send them MCB credits. Parents have full view and control over the activities of their children.

5           INFORMATION WE COLLECT

5.1          PERSONAL INFORMATION

 

To open an account on MyCashBox or use Our Services, you must provide us with the following basic personal information;


·         Your name

·         Your preferred username/login name

·         Mobile phone number

·         Email address (optional)

·         Date of birth

·         Biological gender

·         National ID card type – voter card, Ghana card, driver’s license, passport

·         National ID number

·         Issuance Date

·         Expiry Date

Depending on the nature of the services you request, you may have to furnish Us with additional information as may be required in order for Us to be compliant with the requirements of the laws. Additional personal information requested may include, but not limited to the following;

 

·         Residential address – House number, street name, area name

·         Ghana post digital address

·         Image of national ID – side with your photo and personal information

·         Marital status

·         Place of work

·         Occupation

 

We may also collect and store information relating to your mobile devices including but not limited to device ID and geolocation data.

 

5.2          TRANSACTION INFORMATION

 

When you transact using MyCashBox, we may collect information about that transaction. This information may include;


·         Recipient name

·         Recipient mobile phone number

·         Recipient email

·         Transaction amount

·         Transaction description

·         Time of transaction

 

We may also collect information relating to your IP address and geolocation. We retain such information so that we can enhance Our services and also protect you against instances of unauthorised transactions.


5.3          CUSTOMER SERVICE CORRESPONDENCE

 

Whenever you interact with Us through emails, SMS, voice or by other means, we retain such information on our systems so that we can keep records of our relationship, to measure and improve our services to you.

 

5.4          YOUR INFORMATION WITH THIRD PARTIES

 

By your consent, we may collect your information with Third Party platform such as Google, Facebook, Microsoft and Yahoo to improve our service delivery to you. We implemented the OpenID Connect / OAuth protocols to allow you to sign-up and login to MyCashBox using your information from these platforms.


5.5          SURVEYS AND PROFILE DATA

 

From time to time, We may conduct surveys and collect information that we can use to serve your better. Information collected may include demographics or relating to interests and needs. You will be informed prior to participating in such surveys and how we intend to use the information collected.


5.6          NON-USERS

 

When a registered user sends cash to a non-user, We will keep the information that the registered user submits to Us such as;


·         Recipient name

·         Recipient mobile phone number

·         Recipient email

·         Transaction amount

·         Transaction description

·         Time of transaction

 

6           HOW WE USE AND DISCLOSE INFORMATION

6.1          INTERNAL USES

 

Our primary objective for collecting your personal information is to improve Our services to you and enhance your experience. You agree that We may use your personal information to;

·         Improve Our services to you,

·         Provide you with support services,

·         Resolve your complaints and disputes,

·         Prevent fraud or other illegalities,

·         Reach you directly with new services and promotions,

·         Deliver direct marketing and advertising base on your preferences and

·         Verify and authenticate information you provided from third party sources.

 

6.2          CONTENT POSTED BY YOU FOR PUBLICATION

 

When you provide Us with content or you post the content yourself for publication using MyCashBox, you grant Us (MyCashBox and Titan PS) a non-exclusive, worldwide, perpetual, irrevocable, royalty-free, sub-licensable right to exercise any and all copyright, publicity, trademarks, database rights and intellectual property rights you have in the content, in any media known now or in the future. Further, to the fullest extent permitted under applicable law, you waive your moral rights and promise not to assert such rights against the Titan PS or MyCashBox, its sub-licensees or assignees.


6.3          DISCLOSURE OF YOUR INFORMATION TO OTHER USERS

 

If you are a registered user, only your full name and username or login name are made available to users you transact with. Private users cannot search for other private users but can search for businesses. If you are a registered Business using MyCashBox, your website address and contact information will be made available to both private and business users.

We may however disclose your information to third parties when you use these third parties to access Our services. We will disclose your information to no one unless we are required to do so by the order of a court or other legal processes.


6.4          DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

 

We will not sell or let any of your personal information to third parties for marketing activities and will only disclose this information in limited circumstances and for the purposes described in this policy.

You consent to and direct us to do any and all of the following; disclose information including, without limitation to transaction information, personal information and the contents of your communications to;

a.       The police; security forces; government agencies, regulatory authorities, and agencies  we in good faith believe it is appropriate for us to cooperate with in investigations of fraud or other illegal activities or potential illegal activities.

b.      A civil or criminal legal process.

c.       Your agent or legal representative, the holder of a power of attorney that you grant, or a guardian appointed for you.

d.      Aggregated statistical data with our business partners or for public relations.

 

6.5          CONTACTING USERS

 

We communicate with our users via their account on MyCashBox, email, SMS, social media and by phone calls to:


·         Resolve complaints or claims related to their transactions

·         Provide support for requests

·         Inform users if we have reason to believe they are performing illegal transactions

·         Confirm a user's identity, business or MyCashBox activity

·         Conduct customer surveys

·         Investigate doubtful transactions

We use your account on MyCashBox, email and mobile number to alert you of payments that you have made and received and cash you have sent and received and to send you information about important changes to our services.

7           HOW WE SECURE YOUR INFORMATION

We are committed to handling your information with high standards of information security. We use computer safeguards such as;


·         Firewalls and data encryption

·         Enforce physical access controls to our premises and files

·         Authorise access to information on a need to know or use basis

·         Share privacy policy with customers on website, mobile app and social media

·         Report privacy issues through customer complaint channels

 

The security of your account also relies on how safe you keep your passwords or PINs;


·         You shall not share your password or PIN with anyone.

·         Our staff or representatives from partners and agents will never ask you for your password or PIN.

·         Any email or SMS or other communication requesting your password or PIN should be treated as fraudulent and forwarded to support@titanps.mycashbox.org.

·         If you believe someone else has obtained access to your password, please change it immediately by logging in to your account.

8           UPDATING YOUR INFORMATION ON MYCASHBOX

You can update your personal information on your account on MyCashBox anytime by accessing your account on MyCashBox, go to personal and make the changes you wish to make.

If you wish to close your account on MyCashBox, you will have to notify us by sending a message to support from within your account or an email to support@titanps.mycashbox.org. Note that even if We close your account on MyCashBox, it will be marked as “disabled” for a while then finally marked as “removed”. Your account information will, however, be kept on our database. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new one. However, if you close your account, your personally identifiable information will not be used by us for any further purposes except as necessary to prevent fraud and assist law enforcement, or as required by law.

9           EFFECTIVE DATE

The Privacy Policy will come into effect immediately upon approval by Managing Director and the Board of Directors.  

10        REVIEW OF THIS POLICY 

In the interests of dealing with the ever increasing risks, the contents of this Policy will be reviewed annually by the Business Risk department and tabled for approval from the MD.

11        QUESTIONS OR CLARIFICATIONS RELATED TO THIS POLICY

All questions or other clarifications of this policy and its related responsibilities should be addressed to the Business Risk Unit at compliance@titanps.mycashbox.org, who shall be responsible for the administration, revision, interpretation, and application of this policy.

12        APPROVAL

This Policy has been approved by the Board of Titan Payment System Limit.