1. PERSONAL INFORMATION
Thawani only collects information about you that could reasonably be used to identify you personally (“Personal Information”). The Personal Information is relevant and required for the use of the Services and includes your name, e-mail address, mailing address and telephone number, browser type and internet protocol address, credit, debit, rewards, and other card information which may include card number, card issuer, card type (e.g., Visa), card expiration date, card security code, name of card holder, bank name, bank account number, bank account number and sort code, date of birth, social security number, demographic information, a password that you create, transaction history, mobile device type and a personal identification number that you create (“PIN”). It may be noted that Thawani might have to share your Personal Information to the payment processors and financial institutions when you make or accept a mobile payment ,which might also include the information in relation to amount, date, transaction description, names of the buyer and the seller and transaction location, last four digits of card used and authorization code issued by the card payment processor and/or financial institutions.
In addition to any Personal Information or other information that you choose to submit to Thawani, Thawani and/or the third party service provider (“TPSP”) may use a variety of technologies that automatically (or passively) collect certain information whenever you use the Services (“Usage Information”). This additional information may include the details of the browser that you are using, the URL that referred you to Thawani, IP address or other unique code identified for the Device which is automatically assigned to the Device (“Device Identifier”).
We may, from time to time, supplement the information we collect about you through the Website and/or the Mobile Applications or through the use of the Services and from the information provided by third parties.
The Services of Thawani are primarily provided through the Mobile Applications. Thawani may collect and use technical data and related information, including but not limited to, technical information about the Device, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and information (if any) related to the Mobile Applications.
When you use the Mobile Applications it may automatically collect and store some or all of the following information related to you from the Device, in addition to the Device Identifier, including without limitation:
• your preferred language and country site (if applicable);
• the manufacturer and model of the Device;
• the Device operating system;
• the type of the internet browsers you are using;
• your geolocation;
• information about how you interact with the Mobile Applications and any of the Websites to which the Mobile Applications links, such as how many times you use a specific part of the Mobile Applications over a given time periods, the amount of time you spend using the Mobile Applications, how often you use the Mobile Applications, actions you take in the Mobile Applications and how you engage with the Mobile Applications; and
• information to allow Thawani to personalize the Services and content available through the Mobile Applications.
2. HOW THAWANI USES YOUR PERSONAL INFORMATION
Thawani may use the Personal Information to provide you with services & products you explicitly requested for, to resolve dispute, troubleshoot concern, help promote safe service, inform you about offers, products, services, updates, customize your experience, detect and protect us against error, fraud and other criminal activity, enforce our terms and conditions.
Based upon the Personal Information you provided to us, when registering for an account, we will send you a welcoming email to verify your username and password.
We use the information collected from the Mobile Applications and/or the Websites so that we are able to serve you the correct application version depending on the Device type, for troubleshooting and in some cases, marketing purposes.
We use your Internet Protocol (“IP”) address to help diagnose problems with our computer server, and to administer the Websites. Your IP address is used to help identify you, but contains no Personal Information about you.
Thawani will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if the Services are temporarily suspended for maintenance, we might send you an email. If you do not wish to receive them, you have an option to deactivate your account.
In addition, we may use the Personal Information or the Usage Information that we collect about you:
(i) to provide you with information or services or process transactions that you have requested or agreed to receive including to send you electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties;
(ii) to enable you to participate in a variety of the Services’ features such as online or mobile entry sweepstakes, contests or other promotions;
(iii) to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or the Services’ policies;
(iv) for internal business purposes;
(v) for inclusion in our data analytics; and
We may also use the information collected from you for targeted advertising. This involves using information collected on an individual’s web or mobile browsing behavior such as the pages they have visited or the searches they have made. The information collected is only linked to an anonymous cookie ID (alphanumeric number); it does not include any information that could be linked back to a particular person, such as their name, address or credit card number.
3. HOW AND WHEN DO THAWANI DISCLOSE INFORMATION TO THIRD PARTIES
(a) When you agree to receive information from third parties
(b) Third parties providing services on our behalf
Thawani use third party companies and individuals to facilitate the Services, provide or perform certain aspects of the Services on our behalf – such as design and/or operate the Services’ features, track the Services’ analytics, process payments, engage in anti-fraud and security measures, provide customer support, enable us to send you special offers, perform technical services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Services‘ features), or perform other administrative services. These third parties will have access to user information, including the Personal Information to only carry out the services they are performing for you or for us. Each of these third parties are required to ensure the data protection to us and are obligated not to disclose or use the Personal Information for any other purpose.
TPSP may set and access their own cookies, web beacons and embedded scripts on the Device and they may otherwise collect or have access to information about you.
(c) Co-branded services
Certain aspects of the Services may be provided to you in association with third parties (“Co-Branded Services”) such as sponsors and charities, and may require you to disclose the Personal Information to them. Such Co-Branded Services will identify the third party. If you elect to register for products and/or services through the Co-Branded Services, you shall have deemed to consent to providing your information to both Thawani and the third party. Further, if you sign-in to a Co-Branded Service with a username and password obtained through the Services, the Personal Information may be disclosed to the identified third parties for that Co-Branded Service and will be subject to their posted privacy policies.
(d) Contests and promotions
Thawani may offer -promotions through the Services that may require registration. By participating in a promotion, you are agreeing to official rules that govern that promotion, which may contain specific requirements of you, including, allowing the sponsor of the promotion to use your name in advertising or marketing associated with the promotion. If you choose to enter a promotion, you agree that your Personal Information may be disclosed to third parties or the public in connection with the administration of such promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the promotion’s official rules, such as on a winners list.
(e) Administrative and legal reasons
Thawani cooperates with Government and law enforcement authorities to enforce and comply with the law. Thus, we may access, use, preserve, transfer and disclose your information (including the Personal Information, IP address, Device Information or geo-location data), to Government or law enforcement officials as we reasonably determine is necessary and appropriate: (i) to satisfy any applicable law, regulation, subpoenas, Governmental requests or legal process; (ii) to protect and/or defend the terms and conditions for online and mobile services or other policies applicable to any online and mobile services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of Thawani, the Services or any third party; (iv) to protect the safety of the public for any reason; (v) to detect, prevent or otherwise address fraud, security or technical issues; and /or (vi) to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity.
(f) When you share information
(g) Business transfer
Thawani may share your information, including the Personal Information and the Usage Information with our parent, subsidiaries and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process.
4. THIRD PARTY CONTENT AND LINKS TO THIRD PARTY SERVICES
The Services may contain content that is supplied by a third party, and those third parties may collect the Personal Information, the Usage Information and the Device Identifier, when web pages from any online or mobile services are served to your browser. In addition, when you are using the Services, you may be directed to other sites or applications that are operated and controlled by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third parties. For example, if you click on a banner advertisement, the click may take you away from one of the Websites onto a different web site. These other web sites may send their own cookies to you, independently collect data or solicit the Personal Information and may or may not have their own published privacy policies. We encourage you to read the privacy statements of all third-party web sites or applications before submitting any of the Personal Information to third parties.
5. SOCIAL MEDIA FEATURES AND WIDGETS
6. CHANGE OF INFORMATION AND CANCELLATION OF ACCOUNT
You are responsible for maintaining the accuracy of the information you submit to Thawani, such as your contact information provided as part of account registration. If your Personal Information changes, or if you no longer desire the Services contact us through email address mentioned on the Websites or on the Mobile Applications. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.
You may also cancel or modify your communications that you have elected to receive from the Services by following the instructions contained within an e-mail or by logging into your user account and changing your communication preferences.
If upon modifying or changing the information earlier provided to Thawani, we find it difficult to permit access to the Services to you due to insufficiency/ inaccuracy of the information, we may, in our sole discretion terminate your access to the Services by providing you a written notice to this effect on your registered email address.
If you wish to not use the Services or request that Thawani no longer use your information to provide you the Services, contact us through email address provided. We will retain the Personal Information and the Usage Information (including geo-location) for as long as your account with the Services is active and as needed to provide you the Services. Even after your account is terminated, we will retain the Personal Information and the Usage Information as needed to comply with our legal and regulatory obligations, resolve disputes, conclude any activities related to cancellation of an account, investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and for other business reason. After a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide the Services effectively, but our use of the anonymized data will be solely for analytic purposes.
Thawani shall take all precautions to maintain the confidentiality of personal and sensitive information / data pertaining to its customers/users and business associates by imparting proper training to its employees and by providing restricted access to persons who may require access to such data strictly on a need to know basis. Thawani maintains reasonable physical, electronic, and procedural safeguards to protect the security of the Personal Information. These safeguards include encrypted storage of some of the Personal Information and limiting third-party decryption of the Personal Information to that which is reasonably desirable or appropriate for Thawani, merchants, card issuers, payment processors, and Thawani contractors to provide the Services. Thawani uses firewalls and other security technology to protect its network and systems from external attack, and by requiring you to enter a unique username, password and PIN to access or update the Personal Information. All users must enter their PIN when confirming changes to their Personal Information or executing transactions. Merchants agree with Thawani to employ certain security measures and meet certain security standards, but Thawani cannot and does not warrant that merchants will do so. We cannot guarantee the security of our databases, nor can we guarantee that information you supply won’t be intercepted while being transmitted to us over the internet or wireless communication, and any information you transmit to Thawani you do at your own risk. We recommend that you not disclose your password to anyone.
9. CONTACT US