Policies – Dusupay

Anti-money Laundering Policy

Version 3.0

Effective February 2021

Initiated by Legal Department,

Approved by Management.

1. Introduction and Background

This Policy sets out the obligations of DusuPay, a company registered in Uganda, whose registered office is at Kampala hereinafter referred to as “DusuPay” regarding taking measures to prevent criminals or their associates from holding or being the beneficial owner of a significant or controlling interest or holding a management function in a DusuPay account or its contents. The Policy is also meant to ensure that DusuPay or any service offered by it is not used by a person to commit or facilitate the crime of money laundering and financing of terrorist activities.
Our business operations are guided by the Anti-Money Laundering Act, 2013 and the Regulations made thereunder. Our management and employees are fully conversant with all Anti-Money Laundering guidelines and are aware of their responsibilities in the monitoring, reporting and disclosure of any actions that raise suspicion or give cause for concern.
DusuPay has thus created this policy to regulate transactions with its customers who own DusuPay private as well as Business accounts and to ensure funds and their source are fully traced and accounted for in light of the requirements set out by Bank of Uganda and the Financial Intelligence Authority (FIA).
This policy is also in compliance with obligations as set out under international Anti-Money Laundering legislation and it encompasses the need to have adequate controls and systems in place to avoid or limit the risks of DusuPay being used to facilitate financial crime, economic or otherwise.

2. Prohibition of Money Laundering

The Anti- money laundering Act, 2013 defines “money laundering” as the process of turning illegitimately obtained property into seemingly legitimate property and it includes concealing or disguising the nature, source, location, disposition or movement of the proceeds of crime and any activity which constitutes a crime under the Act;
It is prohibited for any person to through DusuPay intentionally convert, transfer, transport or transmit property, knowing or suspecting that such property to be the proceeds of crime, for the purpose of concealing or disguising the illicit origin of the property or making use of their DusuPay account to assist any person who is involved in the commission of the crime generating the proceeds to evade the legal consequences of his or her actions.
It is prohibited to use one’s DusuPay account to conceal, disguise, or impede the establishment of the true nature, source, location, or ownership with respect to property knowing that such property are the proceeds of crime. This prohibition also applies to assisting another to benefit from known proceeds of crime or to facilitate a conspiracy, participation, association, attempting, aiding or betting the commission of a crime.
It should be noted that money laundering is a crime distinct from and in addition to other crimes under the laws of Uganda, including the crime generating the proceeds subject to the money laundering and you may be charged without having been convicted of the crime of generating the proceeds of money laundering.

3. Know Your Customer (KYC)

Knowing your customer (KYC) entails the process of identification and verification of the identity of clients. This process involves the consistent review, verification and recording of customer identification and transaction information, as well as the handling of inaccurate, incomplete or suspicious information.
In order to avert crimes related to money laundering and counter terrorism financing, DusuPay has developed the following keystone procedures to ensure it is compliant with the regulations set forth in the Anti-Money Laundering Regulations, 2015;

4. Customer Identification Requirements

DusuPay employees are required to review customer identification and ensure they are:
1. Currently valid
2. Government issued
3. Contain a photograph
4. Contain the customer’s name.
DusuPay employees must determine that the form of identification is acceptable by the Competent Authority. As such, the only acceptable identification documents shall be a valid Passport and a National I.D
In the case of Corporate Bodies, employees are required to review the copies of the relevant documents, that is:
1. Certificate of incorporation or business registration certificate;
2. Memorandum and articles of association;
3. Company headed paper;
4. Tax Identification Number (TIN); in case of need
5. Trading License in case of need
6. DusuPay employees are required to review the identification of the individual representing the Corporate Body and the evidence that he/she has the necessary authority to do so and verify this with the company’s board resolution.
7. They are further required to review identification of the principal or substantial shareholders, the directors (including the managing director) and all authorized signatories in line with the requirements for individual customer as provided hereinabove.
8. Each DusuPay employee is required to look at and handle the customer’s ID to verify their identity and its authenticity. If an ID is not provided, does not match the customer or is fake; the employee must refuse the transaction.

5. Anti-Money Laundering Monitoring

DusuPay has taken measures to identify customers who maintain accounts with DusuPay to ensure that they maintain such accounts in the true name of the account holder, and do not open or keep anonymous accounts or accounts which are in fictitious or incorrect names.
DusuPay shall not initiate a business relationship or carry out an occasional transaction, including the opening of a new account or entering into a fiduciary transaction, performing a cash transaction over a capped amount, without undertaking customer due diligence measures, including recording and verifying by reliable means the identity of the client, including their true name as provided by the authorised identification document. Subject to our Privacy Policy, the information you give to us may enable us access your address including postal and residential, employment, and occupation and this may also apply to your representative or whoever has been appointed to act on your behalf.
DusuPay also undertakes further customer due diligence measures to verify the DusuPay customer’s identity using reliable, independent source documents, data or information, such as passports, birth certificates, driver’s licenses, identity cards, voter’s card, utility bills, bank statements, partnership contracts and incorporation documents or other identification documents prescribed by regulations made under the law.
Alongside this, we shall verify the beneficial owner of the account and take reasonable measures to understand the ownership, control and structure of the customer obtaining information. This shall include conducting on going due diligence on the business relationship and where necessary the source, purpose and destination of the funds.
DusuPay shall verify the identity of the customer and beneficial owner before or during the course of opening a DusuPay account or conducting a transaction through DusuPay and this shall apply to each of our customers although the extent may be dependent on the risk sensitiveness of each customer so that for higher risk classified customers, we shall perform an enhanced due diligence.
In that regard, DusuPay shall undertake enhanced customer due diligence measures to determine the true identity of the client if—
1. there are any doubts that a client is acting on his or her own behalf, particularly in the case of a juridical person who is not conducting any commercial, financial, or industrial operations in Uganda where it has its headquarters or domicile;
2. the client is a high risk Politically Exposed Person (PEP);
3. there are any doubts about the veracity or adequacy of obtained customer identification data;
4. there is a suspicion of money laundering or terrorist financing;
5. in addition to normal due diligence measures, in relation to politically exposed persons DusuPay shall have appropriate risk management systems to determine whether a customer is a politically exposed person;
6. establish appropriate guidelines to monitor business relations with such customers;
7. take reasonable measures to establish the source of wealth or funds;
8. conduct on-going monitoring of the business relations; and;
9. obtain the approval of senior management before establishing a business relationship with the customer;
at the point of withdrawing or depositing, the source of funds shall be questioned through a reference system;
no bank transfers are allowed in our system, only peer to peer transfers;
the Anti-Money Laundering Officer shall monitor accounts which have been idle for a long time and have them blocked;
DusuPay operate an open API linking the system to Anti-Money Laundering authorities’ databases like the Financial Intelligence Authority.

6. Data Protection and Retention

DusuPay as a Data Controller shall comply with its obligations under the Data Protection and Privacy Act, 2019 Laws of Uganda.
DusuPay as a Data Controller shall archive or destroy data after 10 years upon request by the Data Subjects.
DusuPay shall store Customer Data on the cloud through Amazon Web Services (AWS).

7. Politically Exposed Persons

“Politically Exposed Persons”(PEP’s) means individuals who are or have been entrusted with prominent functions in a country, for instance, Heads of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, and important party officials as well as family members or close associates of such individuals;
These at times, pose a significant risk in the financial sector as they may be agents or beneficiaries of economic crime. DusuPay’s Anti-Money Laundering Officer shall therefore implement appropriate risk management systems to determine whether a person or customer is a politically exposed person.
DusuPay considers Ugandans from the political level of L.C.5 and above as PEP’s.
DusuPay’s Anti-money Laundering Officer shall take the following measures where a person or customer is a Politically Exposed Person—
1. Obtain written approval from senior management to transact or establish a business relationship with that person;
2. Take adequate measures to establish the source of wealth and the source of funds involved in the proposed business relationship or transaction;
3. Obtain information on the immediate family members or close associates of the person who may have transaction authority over the account;
4. Determine the purpose of the transaction or account and the expected volume and nature of account activity;
5. Review public sources of information on the politically exposed person; and
6. Conduct enhanced on-going monitoring of the business relationship, once the account has been established.
7. DusuPay shall take such measures as are reasonably necessary toensure that neither it nor any service offered by it is used by a person to commit or facilitate the crime of money laundering and financing of terrorist activities.
8. DusuPay shall establish and maintain for at least ten years the information obtained about the true identity of the person on whose behalf a business relationship is initiated or a transaction is conducted and establish and maintain, during the period in which business relations are in effect, and for at least ten years after their conclusion, in readily recoverable form, the records of the information and documentation required this policy.
9. DusuPay shall carry out annual reviews on these PEP’s.

8. Risk Classification

The Risk classification of DusuPay Users will be divided into:
1. Low Risk; these are by and large nationals of a country who are not PEP’s or on any sanction list of any country or from non-restricted countries.
2. High Risk; these are foreigners from restricted countries or people that trade with restricted countries or people that deal in high risk businesses or PEP’s.
The determination of whether or not one is a Low or High Risk will be determined at on-boarding from the additional information gathered from that individual or from the nature of transactions carried out by DusuPay User.

9. Customer Refresher

DusuPay shall from time to time update its data about its customers by sending them messages to update their information or else have them lose their accounts.

10. Statement of our Policy

The company supports the fight against money laundering and terrorism by adopting this AML Compliance Policy to prevent the DusuPay’s financial services from being used to promote such criminal activity.
Cooperate with all the authorities, to the extent that is permitted by applicable Laws, so as to help them in their efforts to prevent or fight money laundering, and the financing of terrorism proliferation.
DusuPay will fully comply with both the intent and letter of all laws and Regulations relating to AML, the prevention of terrorist financing and economic sanctions.
DusuPay will train its employees to comply with these laws and Regulations.
Maintain all customer/transactions related records for at least 10 years or for longer period if the Law in the country requires so.

Privacy Policy

Version 3.0

Effective February 2021

Initiated by Legal Department,

Approved by Management.

This privacy policy sets out how DusuPay Limited (hereon referred to as DusuPay) uses and protects any information that you give DusuPay when you use this website. This is important; we hope you will take time to read it carefully.

DusuPay is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

DusuPay may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

1. What we collect
We may collect the following information:

Your name
Your contact information including email address
Business name, type, address, email and phone number.
Registered & Certified Certificate of Incorporation
Brief company profile including the website details
Identity Documents of Primary and related parties (National ID (for nationals) OR Passport (for Foreigners) OR Refugee ID and Refugee attestations (for refugees).
Proof of Address
Trading License.
other information relevant to customer surveys and/or offers

2. What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

Internal record keeping.
We may use the information to improve our products and services.
We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone or fax .
We may use the information to customize the website according to your interests.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at [email protected]

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

You may request details of personal information which we hold about you under the Data Protection Laws. If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.

Data Protection Policy

Version 3.0

Effective February 2021

Initiated by Legal Department,

Approved by Management.

Introduction
1. This document sets out the data protection policy for DusuPay, a payments company headquartered in Uganda with operations all over Africa and in the UK. Users of the DusuPay are hereafter referred to as “data subjects”. The policy covers the rights of the data subjects and the obligations of the Companies under the respective legislation of the countries in which they are situated
2. “Personal data” is defined as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
3. This Policy sets out the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.
4. The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

2. The Data Protection Principles

This Policy aims to ensure compliance with all relevant legislation and sets out the following principles with which any party handling personal data must comply. All personal data must be:
1. Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
2. Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.
3. Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
4. Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.
5. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the Data Protection and Privacy Act in order to safeguard the rights and freedoms of the data subject.
6. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

3. The Rights of Data Subjects

The Data Protection and Privacy Act, 2019 sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):
1. The right to be informed (Part 12).
2. The right of access (Part 13);
3. The right to rectification (Part 14);
4. The right to erasure (also known as the ‘right to be forgotten’) (Part 15);
5. The right to restrict processing (Part 16);
6. The right to data portability (Part 17);
7. The right to object (Part 18); and
8. Rights with respect to automated decision-making and profiling (Parts 19 and 20).

4. Lawful, Fair, and Transparent Data Processing

The Data Protection and Privacy Act seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The Act states that processing of personal data shall be lawful if at least one of the following applies:
1. The data subject has given consent to the processing of their personal data for one or more specific purposes;
2. The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;
3. The processing is necessary for compliance with a legal obligation to which the data controller is subject;
4. The processing is necessary to protect the vital interests of the data subject or of another natural person;
5. The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or
6. The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
7. If the personal data in question is “special category data” (also known as “sensitive personal data”) (for example, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation), at least one of the following conditions must be met:
  1. The data subject has given their explicit consent to the processing of such data for one or more specified purposes (Unless the law prohibits them from doing so);
  2. The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law;
  3. The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;
  4. The data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal data is not disclosed outside the body without the consent of the data subjects;
  5. The processing relates to personal data which is clearly made public by the data subject;
  6. The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;
  7. The processing is necessary in public interest reasons,
  8. The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services in line with the law pursuant to a contract with a health professional.
  9. The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices in line with the law; or
  10. The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with the Data Protection and Privacy Act, 2019 base which shall be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

5. Specified, Explicit, and Legitimate Purposes

The Company collects and processes the personal data set out in Part 21 of this Policy. This includes:
1. Personal data collected directly from data subjects and;
2. Personal data obtained from third parties.
3. The Company only collects, processes, and holds personal data for the specific purposes set out in Part 21 of this Policy or for other purposes expressly permitted by the Data Protection and Privacy Act, 2019.
4. Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data. Please refer to Part 12 for more information on keeping data subjects informed.

6. Adequate, Relevant, and Limited Data Processing

The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as under Part 5, above, and as set out in Part 21, below.

7. Accuracy of Data and Keeping Data Up-to-Date

The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out in Part 14, below.
The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

8. Data Retention

The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed. (the data subjects’ data will be deleted once the data subject deletes his account with the company).
When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.
For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy.

9. Secure Processing

The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided in Parts 22 to 27 of this Policy.

10. Accountability and Record-Keeping

The Company shall have a Data Protection Officer.
The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the Data Protection and Privacy Act, 2019 and other applicable data protection legislation.
The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
1. The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors;
2. The purposes for which the Company collects, holds, and processes personal data;
3. Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;
4. Details of any transfers of personal data to outside of the country of origin including all mechanisms and security safeguards;
5. Details of how long personal data will be retained by the Company (please refer to the Company’s Data Retention Policy); and
6. Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

11. Data Protection Impact Assessments

The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data [which involve the use of new technologies and the processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the Data Protection and Privacy Act 2019.
Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:
1. The type(s) of personal data that will be collected, held, and processed;
2. The purpose(s) for which personal data is to be used;
3. The Company’s objectives;
4. How personal data is to be used;
5. The parties (internal and/or external) who are to be consulted;
6. The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;
7. Risks posed to data subjects;
8. Risks posed both within and to the Company; and
9. Proposed measures to minimise and handle identified risks.

12. Keeping Data Subjects Informed
The Company shall provide the information set out in Part 12.2 to every data subject:

Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and
Where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:
1. if the personal data is used to communicate with the data subject, when the first communication is made; or
2. if the personal data is to be transferred to another party, before that transfer is made; or
3. as soon as reasonably possible and in any event not more than one month after the personal data is obtained. The following information shall be provided:
  1. Details of the Company including;
  2. The purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 21 of this Policy) and the legal basis justifying that collection and processing;
  3. Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
  4. Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
  5. Where the personal data is to be transferred to one or more third parties, details of those parties;
  6. Where the personal data is to be transferred to a third party that is located outside the country of origin, details of that transfer, including but not limited to the safeguards in place (see Part 28 of this Policy for further details);
  7. Details of data retention;
  8. Details of the data subject’s rights under the Data Protection and Privacy Act;
  9. Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;
  10. Details of the data subject’s right to complain to the “supervisory authority” under the Data Protection and Privacy Act;
  11. Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of personal data and details of any consequences of failing to provide it; and
  12. Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.

13. Data Subject Access

Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.
Data subjects wishing to make a SAR should do using a Subject Access Request Form, sending the form to the Company’s Data Protection Officer at the physical address of the company.
Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.
All SARs received shall be handled by the Company’s Data Protection Officer.
The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

14. Rectification of Personal Data

Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.
The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

15. Erasure of Personal Data

Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:
1. It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;
2. The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
3. The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 18 of this Policy for further details concerning the right to object);
4. The personal data has been processed unlawfully;
5. The personal data needs to be erased in order for the Company to comply with a particular legal obligation OR
6. The personal data is being held and processed for the purpose of providing information society services to a child.
7. Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
8. In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

16. Restriction of Personal Data Processing

Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.
In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

17. Data Portability

The Company processes personal data using automated means.
Where data subjects have given their consent to the Company to process their personal data in such a manner, or the processing is otherwise required for the performance of a contract between the Company and the data subject, data subjects have the right, under the Data Protection and Privacy Act, to receive a copy of their personal data and to use it for other purposes, namely transmitting it to other data controllers.
To facilitate the right of data portability, the Company shall make available all applicable personal data to data subjects.
Where technically feasible, if requested by a data subject, personal data shall be sent directly to the required data controller.
All requests for copies of personal data shall be complied with within one month of the data subject’s request. The period can be extended by up to two months in the case of complex or numerous requests. If such additional time is required, the data subject shall be informed.

18. Objections to Personal Data Processing

Data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes.
Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.
Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.
Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the Data Protection and Privacy Act, “demonstrate grounds relating to his or her particular situation”. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.

19. Automated Decision-Making

The Company uses personal data in automated decision-making processes, for example matching with a service provider on the DusuPay platform.
Where such decisions have a legal (or similarly significant effect) on data subjects, those data subjects have the right to challenge to such decisions under the Data Protection and Privacy Act, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from the Company.
The right described in Part 19.2 does not apply in the following circumstances:
1. The decision is necessary for the entry into, or performance of, a contract between the Company and the data subject;
2. The decision is authorised by law; or
3. The data subject has given their explicit consent.

19. Automated Decision-Making

The Company uses personal data in automated decision-making processes, for example matching with a service provider on the DusuPay platform.
Where such decisions have a legal (or similarly significant effect) on data subjects, those data subjects have the right to challenge to such decisions under the Data Protection and Privacy Act, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from the Company.
The right described in Part 19.2 does not apply in the following circumstances:
1. The decision is necessary for the entry into, or performance of, a contract between the Company and the data subject;
2. The decision is authorised by law; or
3. The data subject has given their explicit consent.

20. Profiling

The Company uses personal data for profiling purposes.
When personal data is used for profiling purposes, the following shall apply:
1. Clear information explaining the profiling shall be provided to data subjects, including the significance and likely consequences of the profiling;
2. Appropriate mathematical or statistical procedures shall be used;
3. Technical and organisational measures shall be implemented to minimise the risk of errors. If errors occur, such measures must enable them to be easily corrected; and
4. All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling (see Parts 22 to 26 of this Policy for more details on data security).

21. Personal Data Collected, Held, and Processed
The following personal data is collected, held, and processed by the Company (for details of data retention, please refer to the Company’s Data Retention Policy).

22. Data Security – Transferring Personal Data and Communications
The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:

All emails containing personal data must be marked “confidential”;
Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted.
Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient; and
All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”.

All emails containing personal data must be marked “confidential”;
Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted.
Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient; and
All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”.

23. Data Security – Storage
The Company shall ensure that the following measures are taken with respect to the storage of personal data:

All electronic copies of personal data should be stored securely and protected by a password;
All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;
No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of the data protection officer and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary; and
No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Data Protection and Privacy Act (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).

24. Data Security – Disposal

When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Policy.

25. Data Security – Use of Personal Data
The Company shall ensure that the following measures are taken with respect to the use of personal data:

No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from the Data Protection Officer;
No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of the Data Protection Officer;
Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;
If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and
Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the Data Protection Officer to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.

26. Data Security – IT Security
The Company shall ensure that the following measures are taken with respect to IT and information security:

All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols. All software used by the Company is designed to require such passwords;
Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;

27. Organisational Measures
The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Data Protection and Privacy Act and under this Policy, and shall be provided with a copy of this Policy;
Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;
Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;
The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Data Protection and Privacy Act and this Policy by contract;
All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Data Protection and Privacy Act; and
Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

27. Organisational Measures
The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Data Protection and Privacy Act and under this Policy, and shall be provided with a copy of this Policy;
Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;
Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;
The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Data Protection and Privacy Act and this Policy by contract;
All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Data Protection and Privacy Act; and
Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

28. Transferring Personal Data to a Country Outside the Country of Origin

The Company may from time-to-time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the country of origin.
The transfer of personal data to a country outside of the country of origin shall take place only if one or more of the following applies:
1. The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the supervising Authority has determined ensures an adequate level of protection for personal data;
2. The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses (as provided for in the Data Protection and Privacy Act); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
3. The transfer is made with the informed consent of the relevant data subject(s);
4. The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);
5. The transfer is necessary for important public interest reasons;
6. The transfer is necessary for the conduct of legal claims;
7. The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
8. The transfer is made from a register that, under applicable law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

29. Data Breach Notification

All personal data breaches must be reported immediately to the Company’s Chief Executive Officer.
If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g., financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the supervising Authorities Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 29.2) to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
Data breach notifications shall include the following information:
1. The categories and approximate number of data subjects concerned;
2. The categories and approximate number of personal data records concerned;
3. The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);
4. The likely consequences of the breach;
5. Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

Any questions regarding this Policy, the retention of personal data, or any other aspect of Data Protection compliance should be referred to the Data Protection Officer ([email protected]).

Cookies Policy

Version 3.0

Effective February 2021

Initiated by Legal Department,

Approved by Management.

1. Introduction
DUSUPAY (“we” or “us” or “our”) may use cookies, web beacons, tracking pixels, and other tracking technologies when you visit our website dusupay.com, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”) to help customize the Site and improve your experience.

We reserve the right to make changes to this Cookie Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Cookie Policy. Any changes or modifications will be effective immediately upon posting the updated Cookie Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Cookie Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Cookie Policy by your continued use of the Site after the date such revised Cookie Policy is posted.

2. Use of Cookies
A “cookie” is a string of information which assigns you a unique identifier that we store on your computer. Your browser then provides that unique identifier to use each time you submit a query to the Site. We use cookies on the Site to, among other things, keep track of services you have used, record registration information, record your user preferences, keep you logged into the Site, facilitate purchase procedures, and track the pages you visit. Cookies help us understand how the Site is being used and improve your user experience.

3. Types of Cookies
The following types of cookies may be used when you visit the Site:

Name	Provider	Purpose
amplitude_id_{id}dusupay.com	Amplitude	Uniquely identifies user’s machine
fpestid	ShareThis	fpestid is a ShareThis cookie ID set in the domain of the website operator.
_ga	Google Analytics	Used to distinguish users on the Google analytics platform and track their statistics and page
_gid	Google Analytics	Used to distinguish users on the Google analytics platform and track their statistics and page
Apbct_visibile_fields Ct_screen_info ct_ps_timestamp apbct_cookies_test apbct_page_hits ct_pointer_data ct_has_scrolled apbct_timestamp ct_timezone ct_sfw_pass_key ct_checkjs ct_checked_emails ct_fkp_timestamp	CleanTalk	Used to prevent spam on our comments and forms and acts as a complete anti-spam solution and firewall for this site
1PA_JAR	Google	Set by Google. This group sets a unique ID to remember your preferences and other information such as website statistics and track conversion rates. Google’s policies can be viewed at https://policies.google.com/technologies/types
_gat_gtag_UA_*_1	Google Analytics	Stores and tracks conversions
ORA_WWV_APP_2020	Apex (Oracle)	This cookie contains the reference of the authenticated session of the application. The presence of this cookie in the browser, allows access to the apex application resources through a specific session ID.

Advertising Cookies
Advertising cookies are placed on your computer by advertisers and ad servers in order to display advertisements that are most likely to be of interest to you. These cookies allow advertisers and ad servers to gather information about your visits to the Site and other websites, alternate the ads sent to a specific computer, and track how often an ad has been viewed and by whom. These cookies are linked to a computer and do not gather any personal information about you.

Analytics Cookies
Analytics cookies monitor how users reached the Site, and how they interact with and move around once on the Site. These cookies let us know what features on the Site are working the best and what features on the Site can be improved.

Our Cookies
Our cookies are “first-party cookies”, and can be either permanent or temporary. These are necessary cookies, without which the Site won’t work properly or be able to provide certain features and functionalities. Some of these may be manually disabled in your browser, but may affect the functionality of the Site.

Personalization Cookies
Personalization cookies are used to recognize repeat visitors to the Site. We use these cookies to record your browsing history, the pages you have visited, and your settings and preferences each time you visit the Site.

Security Cookies
Security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorized parties.

Site Management Cookies
Site management cookies are used to maintain your identity or session on the Site so that you are not logged off unexpectedly, and any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.

Third-Party Cookies
Third-party cookies may be place on your computer when you visit the Site by companies that run certain services we offer. These cookies allow the third parties to gather and track certain information about you. These cookies can be manually disabled in your browser.

4. Control of Cookies
Most browsers are set to accept cookies by default. However, you can remove or reject cookies in your browser’s settings. Please be aware that such action could affect the availability and functionality of the Site.

For more information on how to control cookies, check your browser or device’s settings for how you can control or reject cookies, or visit the following links:

Apple Safari
Google Chrome
Microsoft Edge
Mozilla Firefox
Opera

In addition, you may opt-out of some third-party cookies through the NetworkAdvertising Initiative’s Opt-Out Tool