5. Our Privacy Principles
Patricia focuses on the following core principles:
5.1 To Empower the individual: Patricia wants You to be in charge of Your Personal Information and to make Your own voluntary choices about Your Personal Information;
5.2 To keep and secure Personal Information: Patricia does not take Your trusting us with Your information for granted. We take responsibility to ensure that appropriate security measures are put in place and Your Personal Information is protected;
5.3 To be transparent and to educate Users: For You to know what Personal Information is, how we collect Personal Information, the purpose for collecting Personal Information and how we secure Personal Information;
5.4 To abide by privacy laws in the Territory: Patricia is committed to complying with privacy laws in the Territory; and
5.5 To collect and store Personal Information on the “need to collect” basis: Patricia collects Personal Information to perform its services for You. We implement measures to prevent collecting and storing Personal Information beyond what we need.
6. Personal Information We May Collect About You
We may collect, record and use information about You in physical and electronic form and will hold, use and otherwise process this data in accordance with the Data Protection Legislation and as set out in this Policy.
The Personal Information we collect and use may include, amongst other things:
6.1. Identity Data: Information such as, Your full name(s), Your government-issued identity number, and Your date of birth. This data is to enable us to verify Your identity in order to offer our Services to You;
6.2. Contact Data: This is data that we use to contact You, such as Your name, residential address, email address, telephone number, details of the device You use and billing details;
6.3. Identification documents: (such as Your passport or any Government-issued identity card), a photograph (if applicable), bank statement, affidavit, utility bill or other bill and any other registration information You may provide to prove You are eligible to use our Services and in compliance with regulatory requirements on Know Your Customer (KYC);
6.4. Usage Data: When You access the Services, our servers automatically record information about how You our Services including links You have clicked on, length of visit on certain pages, unique device identifier, log-in information, location and other device details;
6.5 Financial Data: Information, such as Bank Verification Number, personal account number or bank account information, the date and the total amount of transaction, and other information provided by financial institutions or merchants when we act on their behalf;
6.6. Information from other sources: We may also receive Personal Information about You from other sources such as our affiliate, in the event you maintain an account with the Affiliate, Your financial institution, to confirm the basic Personal Information about You or our identity verification partners, in line with the fulfilment of our Anti Money Laundering and Combating the Financing of Terrorism (AML/CFT) obligations;
6.7. Transactional Data: This is information containing details of the transactions You carry out when using our Services, including geographic information;
6.8 Marketing and Communications Data: This includes both a record of Your decision to subscribe or to withdraw from receiving marketing materials from us or from our third parties;
6.9. Records of Your discussions with us if we contact You and if You contact us; and
6.10. Information about Your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.
As a principle, we do not collect any Special Categories of Personal Information. If we do collect Special Categories of Personal Information, we will ensure compliance with Applicable Laws.
It is important that the Personal Information we hold about You is accurate and current. Please keep us informed if Your Personal Information changes during Your relationship with us.
7. How We Collect Your Personal Information and Why We Have It
The Personal Information we have about You is directly made available to us when You:
7.1. Sign up for an Account;
7.2. Use the Services;
7.3. Contact our customer support team;
7.4. Fill our online forms;
7.5. Enter a Patricia sponsored or affiliated promotion;
7.6. Contact Us;
7.7. Other Sources: we may receive information about You from other sources, including publicly available databases and combine this data with information we already have about You, This helps us to update, expand and analyse our records and provide services that may be of interest to You.
8. Our Legal Basis for Processing Your Personal Information
We only use Your Personal Information for a specific purpose; and before we do so, we must have a legal reason. For example, when it is necessary for us to perform a contract with You for our Services, for our legitimate interest, or where You have given us Your consent, or to fulfil our legal obligations. These are all known as the “legal or lawful basis for processing”.
The legal or lawful basis we rely on for processing Your Personal Information by using our Services:
8.1 Your consent: Where You agree to us collecting Your Personal Information by using our Services.
- 8.1.1 With your consent, we may send marketing and promotional communications by email, SMS and push notifications (depending on your choice of contact). For more information please see the Marketing section of this policy;
- 8.1.2 We may send targeted marketing about our services on third-party online services such as Google, Instagram and Facebook if we believe that you are likely to be interested in using our services based on Your profile. Your consent to receive targeted adverts would have been obtained by these third parties on our behalf;
- 8.1.3 Surveys: engaging with You for the purposes of obtaining Your views on our Apps or Services.
8.2 We have a contractual obligation: Without Your Personal Information, we cannot provide our Services to You.
8.3 We have a legal obligation: To ensure we are fully compliant with all applicable Data Protection Legislation, Financial legislations such as Anti-Money Laundering and Counter Terrorist Financing Laws, we must collect and store Your Personal Information. We protect against fraud by checking Your identity with Your Personal Information.
8.4 We have a legitimate interest: We may also collect Your Personal Information where we have a legitimate interest to do so, provided that Your rights do not override such interests.
9. How We May Use Your Personal Information
We may Use Your Personal Information we collect to:
9.1. Create and manage any accounts You may have with us, verify Your identity, provide our Services, and respond to Your inquiries;
9.2. Provide the Services to you;
9.3. Process Your transactions to buy or sell cryptocurrencies and make or receive cryptocurrency payments through our Services;
9.4. Protect against and prevent fraud, unauthorized transactions, claims and other liabilities;
9.5. Provide, administer and communicate with You about products, services, offers, programs and promotions of Patricia, financial institutions and partners;
9.6. Evaluate and improve our business, including developing new products and services;
9.7. To target advertisements, newsletter and service updates;
9.8. As necessary to establish, exercise and defend legal rights;
9.9. As may be required by applicable laws and regulations, including for compliance with Know Your Customers and risk assessment, Anti-Money Laundering, anti-corruption and sanctions screening requirements, or as requested by any judicial process, law enforcement or governmental agency having or claiming jurisdiction over Patricia or Patricia’s affiliates;
9.10. To use data analytics to improve our Services, user experiences and to optimize service delivery;
9.11. For other purposes for which we provide specific notice at the time of collection;
9.12. To comply with Data Protection Legislation and any other applicable laws.
We will only use Your Personal Information for the stated purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purpose. If You wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use Your Personal Information for an unrelated purpose, we will notify You and we will explain the legal basis which allows us to do so.
Please note that we may process Your Personal Information without Your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
10. Data Security and Retention
10.1. The security of Your Personal Information is important to Patricia. We are committed to protecting the information we collect. We maintain administrative, technical and physical controls designed to protect the Personal Information You provide, or we collect against loss or theft, as well as against any unauthorized access, risk of loss, disclosure, copying, misuse or modification.
10.2. Other security measures include but not limited to, secure servers, firewall, data encryption and granting access only to employees in order to fulfil their job responsibilities.
10.3. Where You use a password for Your Account, please ensure You do not share this with anyone, and the password is kept confidential at all times. Patricia shall not be responsible for any loss that arises in relation to Your Account as a result of the disclosure of Your password to any third party.
10.5. We will only retain Personal Information on our servers for as long as is reasonably necessary as long as we are providing Services to You. Where You close Your Account, Your information is stored on our servers to the extent necessary to comply with regulatory obligations and for the purpose of fraud monitoring, detection and prevention.
10.6. To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of Your Personal Information, the purposes for which we process Your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Where we retain Your Personal Information, we do so in compliance with limitation periods under the applicable law.
11. Disclosing Your Personal Information
We may disclose or share Your Personal Information with third parties which include our affiliates, employees, officers, service providers, agents, suppliers, subcontractors as may be reasonably necessary for the purposes set out in this policy.
Patricia only shares Personal Information with external third parties in the following limited circumstances:
11.3. We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to
- 11.3.1. satisfy any applicable law, regulation, legal process or enforceable governmental request;
- 11.3.2. enforce applicable terms of service, including investigation of potential violations thereof;
- 11.3.3. detect, prevent, or otherwise address fraud, security or technical issues;
- 11.3.4. assess financial and insurance risks; or
- 11.3.5. protect against imminent harm to the rights, property or safety of Patricia, its users or the public as required or permitted by law.
We may process Your Personal Information in order to contact You or send You marketing content and communication about our products, services or surveys. You may exercise Your right to object to such contact from us or opt out from the marketing content. Please note however that if You opt-out of marketing content, we may still send You messages relating to transactions and our Services related to our ongoing business relationship.
We may ask You for permission to send notifications to You. Our Services will still work if You do not grant us consent to send You notifications.
13. Your Data Protection Rights and Choices
Based on Your location and applicable laws, below are the rights You have as a user in relation to Your Personal Information:
13.1. Right to be informed;
13.2. Right to request access or copies to Your Personal Information by signing into Your Account or contacting us;
13.3. Right to request that Patricia erase Your Personal Information. You have the right to ask us to erase Your Personal Information. Please note that this is a limited right which applies where the data is no longer required in relation to the purpose for which the data was collected and processed by us, or the processing has no legal justification. The exceptions to this right include where the applicable law requires Patricia to retain a historical archive for public interest or such other related purposes, for the establishment, exercise or defence of legal claims or where we retain a core set of Your Personal Information to ensure we do not inadvertently contact You in future where You object to Your data being used for marketing purposes;
13.4. Right to correct or rectify any Personal Information that You provide which may be incorrect, out of date or inaccurate. You also have the right to ask us to complete information You think is incomplete;
13.5. Right to object to the processing of Your Personal Information for marketing purposes. You have a right to ask us not to contact You for marketing purposes by adjusting Your notification preference on the settings page or by opting out via the unsubscribe link in marketing emails we send You;
13.6. Right to object to processing: You have the right to object to the processing of Your Personal Information in certain circumstances. Please note that where You object to us processing Your Personal Information, we might be unable to provide the services to You.
The basis of us processing Your Personal Information is Your consent. You also have the choice at any time to withdraw consent which You have provided.
You also have a choice to deactivate Your Account at any time. You may contact us should You wish to de-activate Your Account at any time via the Contact Us segment below or send us an email to [email protected].
If You wish to exercise any of the rights set above, please contact us using the contact information provided in the Contact Us segment below. Where we are unsure of Your identity, we might ask You for proof of Your identity for security reasons before dealing with Your request.
Patricia’s websites and applications are not directed at persons under the age of eighteen (18) and we do not collect any Personal Information knowingly or directly from minors.
Where You have any belief that Patricia has mistakenly or unknowingly collected information from a minor, please contact us using the information provided under the Contact Us section to enable investigate and restrict such data.
16. International Data Transfers
By submitting Your Personal Information to us, You agree to this transfer, storing and processing. We note that Your Personal Information may be transferred to countries which may not have the same data protection laws as the country You initially provided Your Personal Information, but whenever we transfer or transmit Your Personal Information internationally, we will ensure or take reasonable steps to ensure Your Personal Information is handled securely in line with the applicable data protection laws and standard contractual clauses.
17. Dispute Resolutions and Filing a Complaint
We may request additional details from You regarding Your complaints and keep records of Your requests and resolution.
18. Advertising and Sponsorship
Part of the Site may contain advertising and sponsorship. Advertisers and sponsors are responsible for ensuring that material submitted for inclusion on the Site complies with relevant laws and codes. We will not be responsible to you for any error or inaccuracy in advertising and sponsorship material.
This Policy was updated on the 11th of August 2022