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Privacy Policy


THIS PRIVACY POLICY GOVERNS YOUR USE OF PRODUCTS, SERVICES, CONTENT, FEATURES, TECHNOLOGIES OR FUNCTIONS OFFERED BY THE ECCB AND ALL RELATED SITES, APPLICATIONS AND SERVICES ON THE DCASH PILOT PROJECT (COLLECTIVELY REFERRED TO HEREIN AS THE “PILOT SERVICES”) INCLUDING, WITHOUT LIMITATION, WHEN YOU PROVIDE ANY INFORMATION IN RELATION TO YOUR USE OF PILOT SERVICES.

BY VOLUNTARILY PROVIDING THE ECCB WITH PERSONAL AND OTHER INFORMATION, SIGNING UP FOR, ACCESSING, OR USING THE PILOT SERVICES, YOU ACCEPT AND CONSENT TO THIS PRIVACY POLICY. THEREBY, ACKNOWLEDGING AND AGREEING THAT SUCH INFORMATION MAY BE TRANSFERRED FROM YOUR CURRENT LOCATION TO THE OFFICES AND SERVERS OF THE ECCB AUTHORISED THIRD PARTIES. FOR THE AVOIDANCE OF ALL DOUBT, BY ACCEPTING AND CONSENTING TO THIS PRIVACY POLICY, YOU EXPRESSLY CONSENT TO THE ECCB’S COLLECTION, USE, DISCLOSURE AND PROTECTION OF YOUR PERSONAL INFORMATION AND HEREBY DIRECT THE ECCB TO COLLECT, USE, DISCLOSE AND/OR PROTECT SUCH DATA IN A MANNER CONSISTENT WITH THIS PRIVACY POLICY.

Overview

The ECCB has adopted this Privacy Policy to govern the use of the Pilot Services by all users (hereinafter referred to as “you”), which includes, without limitation, pilot participants who use the Pilot Services for personal purposes (the “Customers”) and those who use the Pilot Services in the course of their trade or business (the “Merchants”).

For the avoidance of doubt, this Privacy Policy applies to all users, unless otherwise expressly excluded by written agreement. By consenting to, and agreeing to the terms of this Privacy Policy, you expressly consent and agree to us processing the data that you submit and/or generate in the manner set out herein. The ECCB takes its access to such information seriously and will use it only in accordance with the terms of this Privacy Policy, which describes the information we collect and how we use, share and protect that information.

For the purposes of this Privacy Policy, the term “information” means any confidential and/or personally identifiable information or other information related to users of Pilot Services, including but not limited to Customers and Merchants.

Collection And Use Of Data

Data Submitted

In collaboration with financial institutions and agencies, we collect and may use information such as:

∙ personal data including your account information (the “Account Information”), which includes without limitation: name, address, phone number(s), email address, username, photograph, account number(s), government-issued identification number(s), date of birth and physical address,

∙ communications between you and us for customer service and/or other purposes (e.g., by email, fax, phone call, tweet, etc.);

∙ the emails and phone numbers of your contacts, if you choose to invite them to use one or more of the Pilot Services as part of a referral programme (unless your contact opts to unsubscribe from our commercial mailing list(s));

∙ financial data generated by or about transactions you complete using the Pilot Services, including information related to the value, volume, nature and other details of a transaction;

∙ mobile data including the unique identification number associated with your mobile device used to access any of our mobile applications. For iOS users, we also collect the Apple-recommended CFUUID (the Core Foundation Universally Unique Identifier); and

∙ other commercial and/or identification information required in order to comply with anti-money laundering obligations under applicable law.

Data Generated And Other Data

We also automatically collect and may use the following data:

∙ Analytics: When you visit our website or use our platforms, we use third party analysis tools to collect data about your computer and internet connection. That information includes the IP address of your computer and/or internet service provider, the time you accessed our website, the internet address of websites from which you link to our website and from which you came before landing on our website, the browser that you are using, and your navigation and preferences on our website. All of this information is used internally for the purpose of understanding how our website is being used and improving our website. We also use third party analysis tools to collect data about your use of our mobile applications. The information collected identifies the nature and timing of the actions you take within our mobile applications, including installation, registration, uploading, and certain types of navigation. All of this information is used internally for the purpose of understanding how our mobile applications are being used and to facilitate the improvement of said mobile applications.

∙ Site Management: We aggregate data that we collect about the use of our website and/or other platforms for administration purposes, to protect and improve our website and our systems, to better understand the preferences of our website visitors and optimize the content that we serve, to identify server problems, to compile aggregated statistics about our website and/or the platforms’ usage, and to improve our marketing and research.

∙ Do Not Track: Pilot Services do not currently respond to “Do Not Track” signals and operates as described in this Privacy Policy whether or not a Do Not Track signal is received.

Data Protection And Security

Data Protection

The ECCB is committed to observing high standards of information security. We use computer safeguards such as firewalls and data encryption, enforce physical access controls to our buildings and files, secure cloud configuration and authorise access to personal information only for those employees and/or third party service providers who require it to fulfil their job responsibilities.

We require all third parties to respect the security of your data and to treat it in accordance with the law.

While we use reasonable physical, electronic and procedural safeguards to protect your personal information from loss, misuse, unauthorised access or disclosure, alteration and destruction, please be advised that we do not accept responsibility for the security of any data transmitted over the internet or information stored, posted or provided directly to a third party website, which is governed by that third party’s policies.

Password Protection

Your ability to securely use the Pilot Services also depends on your protection of your login credentials such as your product password. We strongly recommend that you do not share your password(s) with anyone. An authorised ECCB representative will never ask you for your password. Therefore, any email or other communication requesting your password or any similar information should be treated as unauthorised and suspicious. In the event that you receive such a communication, please promptly contact your financial institution or Agency or you may contact the ECCB by clicking on the ‘Email Us’ tab on the DCashec.com website or sending an email directly to DCashec@eccb-centralbank.org.

If you do share your password(s) with a third party for any reason, the third party will have access to your account and your personal information, and you will be solely responsible for any and all actions taken using your password. If you believe that someone else has obtained access to your password, please change it immediately. We also strongly recommend that you also contact your financial institution or Agency and you may contact the ECCB by clicking on the ‘Email Us’ tab on the DCashec.com website or sending an email directly to DCashec@eccb-centralbank.org.

Data Retention

The ECCB may retain information about you in our databases for as long as you are a pilot participant or as needed to provide the Pilot Services to you. Additionally, our retention and use of your information will be in accordance with applicable law, including our legal obligations, interest in resolving any disputes, and the enforcement of all relevant agreements. It is important to note that the retention period may extend beyond the end of your relationship with us, as required by law or as deemed necessary in our absolute discretion.

Data Sharing And Disclosure

The ECCB may also share your information for the purposes of fraud prevention, risk management, customer service, legal compliance and particularly in circumstances where:

∙ you have consented or otherwise given us permission to share said information;

∙ we have aggregated or anonymized the information, so that it cannot reasonably be used to identify you;

∙ it is necessary to perform pilot services;

∙ it is, or we reasonably believe it to be, required by applicable law or legal process; and

∙ it becomes necessary in order to protect the rights, property and safety of the ECCB and the public, including, for example, in connection with court proceedings, or to detect or prevent criminal activity, fraud, material misrepresentation, or to establish our rights or defend against legal claims.

Notifications Of Changes

This Privacy Policy may be revised at any time. Any revised policies will be posted on our website and/or other platforms. Unless we have reasonable cause to do otherwise, we will provide you with at least 14 days' prior notice of the effective date of the revised privacy policy. As of the effective date of the revised privacy policy, you will be considered to have consented to all changes if you continue to use the Pilot Services.