1 WHAT THIS POLICY REGULATES
1.2 This Policy describes the ways in which Tencent International Service Pte. Ltd. (“WeChat”, “we”, “our” and “us”) collect, store, use and protect the additional Personal Information acquired through your use of the Wallet specifically. Throughout this Policy, we use the term “Personal Information” to describe information that can be associated with a specific person and can be used to identify that person, as opposed to information that has been made anonymous so that it does not identify a specific user.
2 CHANGES TO THIS POLICY
We may amend this Policy at any time by posting a revised version within the Wallet. We will provide Wallet users with reasonable prior written notice of any such revision within the Wallet, and if you are not happy with the revisions made, you are entitled to terminate your use of the Wallet. Your continued use of the Wallet following any revision to this Policy shall constitute your acceptance of the revised Policy.
3 WHAT PERSONAL INFORMATION WE COLLECT & WHY
3.1 Mobile Number & Device ID
3.1.1 During the Wallet registration process, you provide us with your mobile number (“Mobile Number”) and we also uniquely identify your mobile device, creating a unique device identifier therefor (“Device ID”).
3.1.2 We use your Mobile Number and Device ID to verify that it is you wanting to perform a transaction via the Wallet. We also use your mobile number to occasionally inform you of facts and other information relating to your use of the Wallet (eg. notifications regarding major updates, customer service notifications, and to address copyright infringement or defamation issues) as well as to inform you, subject to obtaining your prior consent, of competitions, promotions and special offers from us and/or our partners and/or affiliates.
3.2 Personal Details
3.2.1 Either during the Wallet registration process and/or thereafter (prior to you wanting to transfer cash to another Wallet user), we may collect your South African identity number and use this to confirm your nationality and deduce your birth date and gender. It may also be used in conjunction with your Mobile Number in order to verify your identity against the RICA database to determine your name and surname. Note that our Authorised Third Party, Standard Bank, would perform such verification process, and pass your name and surname on to us.
3.2.2 We use the aforesaid Personal Information to greet you when you access your Wallet, to manage and administer your use of the Services and fulfil our contractual obligations.
3.3 Card Details
3.3.1 If you choose to make use of our Card Storage Service (as described in the Wallet Agreement) and in so doing enter any credit card or dual purpose debit card details in the Wallet, we collect the relevant card number, cardholder name and expiration date (“Card Details”). However, we use the services of a licensed payment service provider, compliant with Payment Card Industry Data Security Standards (PCI DSS) (“our PSP”) to do so, our PSP currently being Ecentric Payment Solutions (Pty) Ltd (reg no 2001/029509/07). Our PSP stores your Card Details in its PCI DSS compliant environment, encrypting and tokenizing such details, returning only the encrypted token to us. We do not see or otherwise store your unencrypted Card Details.
3.3.2 Your Card Details are used to enable you to easily perform card-based transactions via the Wallet. More specifically, whenever you want to perform a transaction using your card, our PSP will provide the Card Details to the relevant merchant’s acquiring bank (ie Standard Bank).
3.3.3 Although we enable you to enter your card’s CVV, neither we nor our PSP nor any Authorized Third Party collects or stores such CVV in any way. The CVV is instead stored on your own Mobile Device in an encrypted format via a cookie to enable your Mobile Device to automatically send the relevant CVV each time you want to make a payment with your card.
3.4 Transaction Details
We automatically collect and store information related to the transactions you perform using the Wallet (including what payment methods you used, how much you paid and to which merchant and/or other user etc) (“Transaction Details”). We use these Transaction Details in order to provide you with transaction records for your use of the Wallet, and to monitor aggregate Wallet and/or specific Service usage metrics.
3.5 General Wallet usage information
3.5.2 We may use your aforesaid Usage Details to: (a) automatically provide you with the latest version of the Wallet on your device; (b) remember your information so that you will not have to re-enter it during your visit or the next time you access the Wallet; (c) monitor aggregate Wallet usage metrics such as total number of visitors and pages/Services accessed; and (d) track your entries, submissions, and status in any purchases or other activities in connection with your usage of the Wallet.
3.6 Optional Details
You may voluntarily provide additional information to us from time to time, such as demographic information or information related to your favourite social networking site, or your participation in competitions, promotions, surveys, and/or additional services (“Optional Details”). You may do this if you decide to upload or download certain content from/to the Wallet, enter competitions, take advantage of promotions, respond to surveys, register and subscribe for certain additional services, or otherwise use the optional features and functionality of the Wallet. You may also provide such information during your discussions with our call centre. We may use the Optional Details provided by you for such purposes as indicated to you at the time you agree to provide such Optional Details
3.7 Your PIN
Note that the 4-digit PIN you choose in order to access the Services available via the Wallet is collected by Standard Bank, not us. Standard Bank uses such PIN to verify your PIN entries when you make use of its ‘Instant Money’ Service (ie when you use the cash balance in your Wallet). However, we receive an encrypted version thereof from Standard Bank in order for us to verify your PIN entries when making use of the other Services available via the Wallet.
4 HOW WE STORE & PROTECT PERSONAL INFORMATION
4.1 Your Wallet-related Personal Information is stored on servers within South Africa as well as on Google cloud servers in the Europe 1C region and all information travelling between our servers and/or your mobile device is secure-socket-layer (“SSL”) encrypted in line with industry standards (i.e. SSL TLS).
4.2 As explained in 3.3.1 above, your Card Details specifically, are not stored on our servers, but are stored in South Africa on the PCI-compliant servers of our PSP, being a licensed payment service provider.
4.3 In accordance with the Wallet Agreement, you should not divulge your Wallet-related PIN to anyone. We will never ask you for such PIN in an unsolicited telephone call or e-mail and although our call centre agents will be able to reset that PIN for you, they will not be able to see it. YOU ARE RESPONSIBLE FOR MAINTAINING THE SECRECY OF SUCH PIN AND ACCOUNT INFORMATION AT ALL TIMES.
5 How we share personal information with others
5.1 For reasons explained in 1.3 above, we may share some of the Personal Information we have collected directly from you with such Authorised Third Parties that you also register with, including Standard Bank. Similarly, some of the Personal Information they collect directly from you may be shared with us. This is done in order to streamline registration processes and/or avoid multiple requests for the same Personal Information from you. For example, we collect your Mobile Number and create your Device ID, and send both to Standard Bank, so as to enable verification of your identity when transacting.
5.2 As mentioned in 3.3.1 above, your Card Details are stored by our PSP and then shared, as and when you instruct for purposes of making a payment, with the relevant Merchant’s acquiring bank.
5.3 We work with the Authorised Third Parties and indirectly, the Merchants, to enable them to accept payments from you via the Wallet. In doing so, an Authorised Third Party may share information about you with us (e.g. transaction confirmations) when you attempt to make a payment.
5.4 We may also share certain of your Personal Information with the following entities/persons:
5.4.1 Our holding company, Tencent Holdings Ltd, and other divisions or companies within the Tencent Holdings Ltd group of companies so as to provide joint content and services like registration, transactions and customer support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about their products, services and communications. Members of our corporate family will only use this information to send you marketing communications if you have requested their services.
5.4.2 Our service providers under contract, like our PSP, who help with parts of our business operations (fraud prevention, marketing, technology services). Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
5.4.3 Companies that we plan to merge with or be acquired by, provided that should this occur, the new combined entity will be obliged to adhere to this Policy with respect to your Personal Information.
5.4.4 Law enforcement, government officials, fraud detection agencies or other third parties when (a) we are compelled to do so by a subpoena, court order or similar legal procedure; or (b) we need to do so to comply with any law; or (c) we believe in good faith that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our User Agreement and/or Merchant Agreement.
5.4.5 Other third parties, but only with your consent or direction to do so.
5.5 We will not sell or rent any of your Personal Information to third parties for their marketing purposes and only share your Personal Information with third parties as described in this Policy.
5.6 Please note that the Authorised Third Parties (including Standard Bank) and the Merchants you transact with, have their own privacy policies, and we will not be held responsible or liable for their operations, including, but not limited to their information practices.
6 How you can access or change your personal information
Should you wish to review and/or edit any of your Personal Information, you can do so by contacting our call centre at 0860466639.
7 Non-personal information
Notwithstanding anything contained in this Policy regarding your information, the following information is not regarded as Personal Information for purposes of this Policy:
7.1 permanently anonymised information that does not relate and/or cannot be traced back to you specifically (which information we may compile, use, share and otherwise process as we deem fit);
7.2 non-personal statistical information collected and compiled by us (which we own and retain all rights in); and
7.3 information which you have provided voluntarily in an open, public environment or forum (because once disclosed in a public forum, the information is no longer confidential and does not constitute Personal Information subject to protection under this Policy).
8 You consent to the processing of your personal information
By accepting this Policy, you consent to our collection, storage, processing and disclosure of your Personal Information as described in this Policy. Should you terminate your registration with us for the Wallet, you consent to our retention of the information we have already collected from you for record-keeping purposes only.
9 How you can contact us about privacy questions
If you have questions or concerns regarding this Policy, you should contact our call centre at 0860466639.