Privacy Policy

Introduction

Optiswift Technologies Limited (“Optiswift”, the “Company”, or “we” or “us”) values the personal data of the individuals (“Users”, “you”, “your”) who use our website or mobile application (the “Platform”). We have made it our obligation to ensure that your personal data is protected whenever you use our Platform. We have, therefore, set out to describe how we treat your personal data and the rights you have in respect to your data as a user of our Platform. Please read this Privacy Notice (the “Notice”) to understand how we collect, use, share, process, and store your personal data.
Please note that the application of this Notice does not extend to services that are not owned or controlled by Optiswift, including third-party websites and the services of other Optiswift’s partners. Optiswift ensures to handle personal data provided to us by our Users in strict compliance with applicable data privacy and protection laws.

The Information we Collect

To access the Optiswift Services and for optimal use of the Platform, we collect personal data from you.

Personal data refers to the personally identifiable information which you submit, when you use the services offered on our Platform. They include the following:

Sign-Up Data: This includes your full name, date of birth, nationality, residential address, country of tax residence, marital status, email address, phone number, and occupation. This information is necessary for us to carry out our know-your-customer checks (KYC) on you when you register to use our services.
Employment Related Data: This may be categorised into:
1. As a prospective employee: During your recruitment process, information we collect may include your full name, phone number, email address, information related to your previous employment, and other personal information as you may disclose in your curriculum vitae. Depending on the level you get to in our recruitment process, we may share your data with background verification platforms for screening checks. You have the right to object to this processing. However, objecting means we may be unable to proceed with your recruitment exercise with us.
2. As an employee: in addition to the information above, we may collect and process your tax information, bank account information, marital status, information from your previous employers and/or referees, evidence of your home address, and such other information as we may require to ensure a healthy employment relationship with us.
Sales/Marketing Data: This includes data
1. we collect when you sign up for our newsletter,
2. you provide to our sales or marketing team at a physical outreach or event,
3. you provide during a social media campaign,
4. you provide when you commence the process of onboarding on our Platform without completing it.
Complaint Resolution Data: collect and process your name, contact email and phone number, including other information you voluntarily provide in relation to an issue you need us to resolve, or a feedback you provide, when you reach out to us on media such as our social media platforms, or the contact page on our website. This information is used solely for the purpose of resolving the issues you raise.
Other Information:
1. - Analytics - we analyse our relationship and transactional information to derive unique data. For example, we may generate propensities, attributes and/or scores for marketing, security or fraud purposes.
2. - Information derived from your use of our website and other technical products – this includes information regarding your interactions with our websites, applications or advertisements, including IP address, device identifiers, settings, characteristics, advertising ID, browsing history, web server logs, server log records, activity log records, keystroke timing and other information collected using cookies and similar technologies. We may also use such data to improve features, website content and analyse data to develop products and services.
3. - Audio and Visual Information – this includes audio, electronic, visual or similar information relating to your interactions with us, including photographs, video images, CCTV recordings, call centre recordings, call monitoring records and voicemails.
Government-Issued Identification Numbers: whether as an employee or a shareholder or director of any of our merchants, we may request a government issued ID to carry our verification of your identity. We may use third party services for this verification We may also collect information about your device including
Cookies: We use cookies on our website. You may check out our cookies policy here.
Minors: We do not collect the information of minors. If you are under the age of 18, you are not eligible to use our service. Kindly refer to our Terms.

Use of Information:

We use your personally identifiable information to:

provide you with our services and customer support, including processing your transaction requests;
process your requests, resolve disputes and troubleshoot problems;
prevent potentially prohibited or illegal activities and enforce our Terms and any other agreement which you may sign with us;
customise, measure and improve our services;
customise and improve the layout of our website and platform generally;
compare information for accuracy and verify with third parties;
update our databases and provide user support;
provide you with information about other services we offer which you may not have signed up for or may not be available at the time of your onboarding;
Authenticate your access to a user account;
Communicate with you about your account;
Manage risk, fraud and abuse of our services and protect you from fraud by verifying your identity;
Comply with our obligations and to enforce the terms of our sites and services, including to comply with all applicable laws and regulations;
Trail information breach and remediate such identified breaches;
Communicate with you about your account;
Resolve disputes and troubleshoot problems.

By continuing the use of our platform, you understand that we may:

Market Optiswift and/or our partner’s products and services to you.
Use cookies to provide a targeted display, feature, service or offer to you.

Where you do not intend to, or you no longer want to receive targeted display, feature or any of our service, please send an email to [email protected]

Marketing

We may use your personal data for the purpose of providing targeted marketing services about our services or any of our partners’ services to you.
We may send marketing communications to you by SMS or email. You have the right to opt out of any of these channels at any time, if you do not want to receive them.

What Constitutes your Consent?

Consent has to be expressly given and so given through a positive action. We obtain your consent when you either click on a consent icon shown to you on our platform, or you sign or imprint your name or initial on a consent request form.
We do not always rely on consent as the lawful basis for our processing of your personal data. However, where processing of your personal data is based on consent, we will obtain the requisite consent at the time of collection of the personal data by expressly asking that you consent to the processing of your personal data when you access our Platforms, or use the services we provide on them. You can withdraw your consent at any time. But, when you do, your withdrawal will not affect the processing of your personal data which we already carried out based on your consent before your withdrawal.
We may retrieve personal data about you from third parties including financial and security institutions.

Sharing of Information

We assure you that your personal data will only be used for the purpose for which we obtained it. However, we may share your personal data with our partners subject to appropriate data security and protection measures.
We will comply with applicable data protection laws when transferring your data out of the jurisdiction where it is primarily used.
In the event that our platform contains third-party links or links to other websites, we advise that you check the privacy notices and safeguards in place on such websites as we are not responsible for the privacy practices or safeguards of these sites and will not be responsible for your use of such websites. Optiswift will not accept any responsibility for any loss or damage in whatever manner resulting from your disclosure of your personal information to such third parties.
We may share your Personal Data or other information about you with others for the following reasons:
- With our partners: These include for the purpose o
  1. security checks,
  2. KYC verifications, transaction monitoring, fraud prevention,
  3. regulatory compliance,
  4. customer support services, and
  5. marketing services
- With other third parties for our business purposes or as permitted or required by law: This may include:
  1. To comply with a law, guidelines or regulations;
  2. To law enforcement authorities or other government officials, or other third parties pursuant to a court order or other legal process or requirement applicable to Optiswift’s or Optiswift’s corporate family;
  3. If we have reasonable cause to believe that the disclosure of your personal data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
  4. To protect the vital interests of a person.
  5. To investigate violations of or enforce our term or other legal terms applicable to any service;
  6. To protect our property, services and legal rights;
  7. To facilitate a purchase or sale of all or part of our business;
  8. To companies that we plan to merge with or be acquired by; and
  9. To support our audit, compliance, and corporate governance functions
In each of the instances listed above, we will only share such personal information as are relevant and necessary to comply with the particular process concerned.
We may also share your Personal Data and other information with your consent or direction.

Your Rights

You can exercise the following rights with respect to your personal data with Optiswift:
- request and access your personal data which we collected and stored;
- withdraw your consent at any time. For example, you can withdraw your consent to receive our marketing or promotional materials or unsubscribe to our newsletters;
- object to automated decision making;
- request rectification and modification of your personal data;
- request for deletion of your personal data;
- be informed of and entitled to provide consent prior to the processing of personal data for purposes other than that for which the personal data were collected;
- request that we restrict processing of your personal data; and
- request for information regarding any specific processing of your personal data.
You may exercise any of these rights by sending an email to [email protected] where your requests will be treated promptly.

Lawful Basis for Processing Personal Data
We will only use your Personal Data if we have a lawful reason to do so. Our various lawful basis for using your Personal Data may include:

Purpose of Collecting and Processing	Lawful Basis
KYC Verification and Onboarding	- Your Consent - Lawful purpose - we are required by our regulators to collect this information - To fulfil the terms of the contract which you sign with us at the point of onboarding Legitimate interests (ours and those of others) such as to protect you, us, or others from threats (such as security threats or fraud); to enable or administer our business, such as for quality control, compliance, consolidated reporting and customer service; to manage corporate transactions, such as mergers or acquisitions; and to understand and improve our business or customer relationships generally
Transaction Processing and Monitoring	- Lawful purpose - we are required by our regulators to collect this information - To fulfil the terms of the contract which you sign with us at the point of onboarding - Legitimate interests (ours and those of others).
Issues Resolution	- To fulfil the terms of the contract which you sign with us at the point of onboarding
Sales and marketing	- Your consent
Recruitment/Employment	- Your consent; - our legitimate interests or those of others; - fulfil the terms of your employment contract; - comply with labour laws applicable to us.
Generating de-personalized information for product development and improvement	- For our legitimate interests or those of others
Fraud Monitoring, Chargebacks and Dispute Resolution	- For our legitimate interests or those of others; - To fulfil the terms of your employment contract; - To comply with labour laws applicable to us.

Disclosure of Personal Data

We may disclose any information we collect about current and former customers, including Personal Data, to affiliates and non-affiliated third parties as follows:
1. With law enforcement officers, customer onboarding partners, transaction monitoring tools, and transaction partners. Disclosure will only be on an absolute-necessity basis.
2. With another user, when you sign up for Optiswift’s services via a referral link. The user that referred you may receive information indicating that you have enrolled with Optiswift. You may avoid this sharing by not using a referral link to enrol.
In connection with our everyday business purposes, we may also share personal data about you as follows:
1. In response to a request for personal data, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process.
2. With relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud.
3. If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Optiswift or others.
4. In connection with, or during negotiations of, any merger, sale of Optiswift’s assets, financing or acquisition of all or a portion of our business to another company; and
5. With your consent or at your direction, including if we notify you that the personal data you provide will be shared in a particular manner and you provide such personal data.
We may also share aggregated or de-identified personal data, which cannot reasonably be used to identify you. For example, we may share transaction zip codes with third parties to improve our accuracy in geo-locating transactions and to improve the clarity of transaction descriptions.
We will usually not share your personal data with other third parties without your consent, or where, via a legal contract, you have authorised us to do so. Where we need to transfer your personal data to another country, we shall ensure that such country to which the data is being transferred shall have adequate data protection law. We will seek your consent where we need to send your data to a country without an adequate data protection law.

Account Monitoring

You accept that Optiswift shall have the right to monitor your account usage and if required, will disclose personal information to local enforcement or investigative agencies or any competent regulatory or governmental agencies to assist in the prevention, detection or prosecution of fraud or criminal activities.

Optiswift Employee Obligation

Optiswift employees who handle personal information are under an obligation to treat it confidentially and may not disclose it to third parties. Optiswift employees are also responsible for the internal security of the information. Employees who violate Optiswift's privacy policies are subject to the company’s disciplinary procedures.

Submitting Information Through Optiswift

Any person submitting information to Optiswift through our platform may be granted access rights to that information. Optiswift has developed systems that enable users to access and correct their personal information submitted to it. Optiswift is committed to ensuring that personal data processed by the company is accurate and up to date in line with the provisions of the applicable data protection law. In order to ensure that your personal data with the company is current, complete and accurate, please update us if there are changes to your personal information by informing the company’s DPO via the stated contact details. We shall take it that your records with the company are current, complete and accurate if we do not receive any update from you.

Privacy Notice Updates

12.1. Optiswift may at any time amend, delete, or add to its Privacy Notice by giving notice of such changes or posting a revised version of our Privacy Notice on our website. Any change will be made unilaterally by us and you will have been deemed to be informed of these changes by your continuous use of our services after the revised Privacy Notice is uploaded. Where there is a fresh processing requirement which is not envisaged at the time of your onboarding with us and is not covered by the existing lawful basis we have (consent or otherwise), we will request your consent or rely on any other lawful basis in accordance with applicable laws. We will make efforts to display a notice of any change to our Privacy Notice on our website. Notwithstanding this, you further agree that it is your sole responsibility to check for updates of the Privacy Notice.
12.2. If you do not accept any change, you will be required to close your Optiswift user account, otherwise you will be deemed to be on notice and comfortable with the new terms. Any closure of the account still renders you liable to Optiswift for any liability incurred by you prior to closure.

Correspondence

Should you send us correspondence including chats, calls, emails and letters, we will retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from Optiswift to you. The rationale for this retention is to keep records of our relationship, measure and improve customer service and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.

Security

14.1. Optiswift is committed to managing customer information with the highest standards of information security. We protect your personal information using physical, technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. To prevent unauthorised access or disclosure of Information we have physical, electronic and managerial procedures in place to keep your information safe. Once logged into your Optiswift account, all internet communication is secured using Transport Layer Security (TLS) technology and the connection is encrypted and authenticated using AES 128bit encryption key and uses Elliptic Curve Diffie-hellman key exchange (ECDHE) RSA as a key exchange mechanism and only authorised access to personal information is granted only to employees who require it to fulfil their job responsibilities.
14.2. The security of your Optiswift user account also rests on the protection of your PIN. You should not share your PIN with anyone and no employee of Optiswift will ever ask you for either of these so any email or correspondence requesting for such information should be treated as unauthorised and suspicious and forwarded to [email protected] We will endeavour to respond to such emails as soon as possible.
14.3. Should you share your PIN with any third parties, such third parties will have access to your account and your personal information, and you may be responsible for any actions taken using this information. Optiswift shall not be liable or responsible for any breach or loss arising from the disclosure of your PIN or other private information to any third parties. In the event you suspect a third party has gained access to your PIN, please log into your Optiswift profile, change it and notify us straightaway.
14.4. Although we make good faith efforts to store Information in a secure operating environment that is not open to the public, you should understand that there is no such thing as complete security, and we do not guarantee that there will be no unintended disclosures of your Information. If we become aware that your Information has been disclosed in a manner not in accordance with this Privacy Notice, we will use reasonable efforts to notify you of the nature and extent of the disclosure (to the extent we know that information) as soon as reasonably possible and as permitted by law.

Phishing

Optiswift takes appropriate measures to ensure that your Personal Data is only processed and retained for a period in line with the purposes set out in this Notice, as is stated under our data retention policy, or as required by applicable laws. We will also determine what action is to be carried out after the period stated in policies expired.

Inquiries

Optiswift is responsible for ensuring that our day-to-day procedures are aligned with this Privacy Notice. Should you have any questions about this Privacy Notice, Optiswift's information services or your transactions on Optiswift, you can contact us via our customer helplines or by email to [email protected].