Privacy Policy

In this document (this “Privacy Policy”) we aim to present you with a succinct overview of our policies related to how we collect, use and disclose information. Whilst no one document can ever be completely comprehensive, we have striven to enclose many of the most salient matters requiring your attention in respect of how we manage any information we collect from you, or which you provide to us to enable us to maintain the requisite consistency of experience in our applications for your convenience.

 

To be allowed access to any of our platforms and applications, and to be allowed to use any of the features, information, data and functions available therein, you must first thoroughly read through this Privacy Policy and fully consent to it. Please do not proceed to use our systems or applications if you do not or cannot subscribe fully to all the terms and policies described in this Privacy Policy. If you do use our applications and systems, however, this Privacy Policy shall fully govern the ways in which we collect and receive data from you, handle and store that data, and process or harness it in order to deliver services, improve products, calibrate experiences, or comply with law, ethics, policy, regulations, standards or technology requirements.

 

Personal Information

Whilst the exact definitions of what qualifies as “Personal Information” may vary from jurisdiction to jurisdiction, they generally include information that identifies you as an individual or relates to an identifiable individual.  The following is a non-limiting set of examples of the types of information that we may classify as Personal Information in our servers: names, dates of birth, postal addresses (including billing and shipping addresses), telephone numbers, email addresses, citizenship, residence information, sexual status, sexual identity, legal residence status information, credit history, credit card and debit card numbers, profile pictures, shopping history, rating history, employment history, banking data, income data, social media account ID numbers etc.

 

Collection of Personal Information

We and our service providers need to collect Personal Information in order to provide the requested products or services to you.  If you do not provide the information requested, we may not be able to provide the products or services.  We and our service providers collect Personal Information in a variety of ways.  The following, among others, are some of the sources and channels through which your information may come into our possession.

 

  • Information supplied by yourself. You may provide us or our service providers with such information about yourself by completing forms or surveys via our web portals, through our native mobile applications (the “Apps”), by calling our call center, by visiting our stores or attending one of our trade shows, or in various other direct ways. The information may also come to us in the form of electronic correspondence via multiple media, such as email, messaging and chat apps, social media , direct phone calls to our representatives, text messages, in-person questionnaires, fax or in a physical medium such as courier, post or packages. The contexts may vary widely, and may include, but are not limited to, account registration, payments processing, quotes solicitation, invoice management, credit management, customer service, complaints investigations and management, and compliance formalities. In addition, the majority of our systems are automatically configured to try and optimize your experience whenever you visit any of our online platforms, or use the Apps, or interact with other services we provide. For example, your phone number may be automatically recorded when you dial into our call center, and the agent may take your name and residential address.
  • Third party data about or related to you. To improve our effectiveness in providing you with relevant experiences and information, we usually have to rely on other sources in order to learn about your preferences and access rights and the like. For example, we may depend on companies whose custom you patronize to access information for your eligibility for a certain offer or to even obtain contact information for you before we can send you the notifications about your eligibility. We may also obtain your Personal Information from other sources, e.g., publicly available databases and joint marketing partners, when they share the information with us.  [If you connect your social media account to our account on the same social media, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to our account on the same social media.] 

 

[If you disclose any Personal Information relating to other people to us or to our service providers in connection with our products or services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.]

 

Use of Personal Information

We and our service providers use Personal Information for legitimate business purposes including:

  • Providing the functionality of our products and services and fulfilling your requests.

o          To provide our products and services’ functionality to you, such as arranging access to your registered account, and providing you with related customer service.

o          To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our products or services.

o          To complete your transactions, and provide you with related customer service.

o          To send administrative information to you, such as changes to our terms, conditions and policies.

o          To allow you to send messages to another person if you choose to do so.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

  • Providing you with our newsletter and/or other marketing materials and facilitating social sharing.

o          To send you marketing related emails, with information about our services, new products and other news about our company.

o          To facilitate social sharing functionality that you choose to use.

We will engage in this activity with your consent or where we have a legitimate interest.

  • Analysis of Personal Information for business reporting and providing personalized services.

o          To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our products and services. 

o          To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.

o          To better understand your preferences so that we can deliver content via our products and/or services that we believe will be relevant and interesting to you.

We will provide personalized services either with your consent or because we have a legitimate interest.

  • Allowing you to participate in sweepstakes, contests or other promotions.

o          We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.

o          Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information.

We use this information to manage our contractual relationship with you.

  • Aggregating and/or anonymizing Personal Information.

o          We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.

  • Accomplishing our business purposes.

o          For data analysis, for example, to improve the efficiency of our services;

o          For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;

o          For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;

o          For developing new products and services;

o          For enhancing, improving, or modifying our current products and services;

o          For identifying usage trends, for example, understanding which parts of our products and services are of most interest to users;

o          For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and

o          For operating and expanding our business activities, for example, understanding which parts of our products and services are of most interest to our users so we can focus our energies on meeting our users’ interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

 

Disclosure of Personal Information

 

We disclose Personal Information:

 

  • To our third party service providers, to facilitate services they provide to us.

o          These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.

  • To third parties, to permit them to send you marketing communications, consistent with your choices.
  • To third-party sponsors of sweepstakes, contests, and similar promotions.
  • By using our products or services, you may elect to disclose Personal Information

o          On message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our social media pages).  Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

o          [Through your social sharing activity.  When you connect your social media account with our account on the same social media, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.]

 

We shall not willfully and unethically seek to trade in Personal Information in any way that can pose foreseeable harm to your interests.

 

Whenever we share Personal Information within units in our organization, with authorized affiliates, or with third parties we reasonably deem to be legitimate recipients, we would only be doing so cognizant of the fact that the parties with whom we are sharing Personal Information have consented to abide by the professional standards in the industry or sector within which they operate. We require all service providers, affiliates, allies, and authorised third party recipients of Personal Information to comply with professional confidentiality standards and to observe marketing ethics. Our contractors are explicitly forbidden from exploiting Personal Information for unethical, illegal and underhand purposes, and their continuing access to Personal Information we hold is dependent and contingent on their commitment to compliance.

 

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law and regulations.

o          These can include laws outside your country of residence.

  • To cooperate with public and government authorities.

o          To respond to a request or to provide information we believe is important.

o          These can include authorities outside your country of residence. 

  • To cooperate with law enforcement.

o          For example, when we respond to law enforcement requests and orders or provide information we believe is important.

o          We are generally required by law, policy, regulations and ethics to release Personal Information held on individuals and customers to assist law enforcement agencies and regulatory bodies for the purposes of public safety, the prevention of crime, and the abatement of fraud. Depending on the precise jurisdiction in which data handling, storage, transfer or management is being done, periodic disclosures may be warranted as a matter of course.

  • For other legal reasons.

o          To enforce our terms and conditions; and

o          To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

  • In connection with a sale or business transaction.

o          We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).  Such third parties may include, for example, an acquiring entity and its advisors.

 

Other Information

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, for example:

  • Browser and device information;
  • Apps usage data;
  • Information collected through cookies, pixel tags and other technologies;
  • Demographic information and other information provided by you that does not reveal your specific identity; and
  • Information that has been aggregated in a manner such that it no longer reveals your specific identity.

 

If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy.

 

Collection of Other Information

When you log into our single sign-on solution in order to access our products (website, mPedigree Goldkeys mobile apps, Goldkeys Hub web app)  across multiple devices or simultaneously, we may use cookies and similar tools and widgets to record your IP address, Internet bandwidth characteristics, navigational referents and page indices etc. For auditing purposes, and also to maintain security vigilance and optimize the product experience, we may keep track of the pages visited, search terms and queries raised, documents extracted, reports requested, multimedia content consumed and the time trail of activities.  These are but a few examples of how we may collect Other Information.  We and our service providers may collect Other Information in a variety of ways, including, without limitation: 

  • Through your browser or device:

o          Certain information is collected by most browsers or automatically through your device, such as your Media Access Control address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of our products or services (such as the Apps) you are using.  We use this information to ensure that our products and services function properly. 

  • Through your use of the Apps:

o          When you download and use the Apps, we and our service providers may track and collect Apps usage data, such as the date and time the Apps on your device access our servers and what information and files have been downloaded to the Apps based on your device number.

  • Using cookies:

o          Providing a consistent and stress-free user experience across platforms, applications and devices is one of our most important objectives. To do this, it is often crucial that our insights into customer preferences and interests are accurate, up to date, and comprehensive. Cookies and widgets embedded into websites, portals, native apps, and other applications improve our chances of attaining these objectives. These tiny files keep track of navigational referents and event sequences as well as a range of other ambient factors in order to help us render the most appropriate interfaces to you, whichever part of our service and product landscape you may be. In this Privacy Policy, we shall refer to the terms, “cookies” and “widgets”, interchangeably and sometimes together as a quick means of describing the various tools and techniques required to align the state of our products and services with your interests, preferences and anticipated preferences, especially in the digital realm.  Technically, cookies are pieces of information stored directly on the computer that you are using.  Cookies allow us to collect information such as browser type, time spent on our products or services, pages visited, language preferences, and other traffic data.  We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience.  We also gather statistical information about use of our products and services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.  [Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are using our products or services.  We may also use cookies or other technologies in online advertising to track responses to our ads.]    We do not currently respond to browser do-not-track signals.  If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website.  You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html.   If, however, you do not accept cookies, you may experience some inconvenience in your use of our products or services.  [You also may not receive advertising or other offers from us that are relevant to your interests and needs.]

  • Using pixel tags and other similar technologies

o          Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of our products and services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of our products and services and response rates. 

o          [Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of our products and services and report on activities and trends.  This service may also collect information regarding the use of other websites, apps and online resources.  You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.]  

  • Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies

o          We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of our products and services.  If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel.  You can also go to the Global Storage Settings Panel and follow the instructions (which may explain, for example, how to delete existing Flash LSOs (referred to as “information”), how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time).  Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications. 

  • IP Address

o          Your IP address is automatically assigned to your computer by your Internet Service Provider.  An IP address may be identified and logged automatically in our server log files whenever a user accesses our products or services, along with the time of the visit and the page(s) that were visited.  Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services.  We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering our products and services.  We may also derive your approximate location from your IP address.

[•         Physical Location 

o          We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals.  [We may use your device’s physical location to provide you with personalized location-based services and content.]  [We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns.]  [In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.]]

 

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  In some instances, we may combine Other Information with Personal Information.  If we do, we will treat the combined information as Personal Information as long as it is combined.

 

Storage & Handling

We observe all reasonable measures to ensure that our physical servers are maintained within reasonable bounds of security and integrity. We do have servers located within the European Union, where strict standards are in place regarding the safeguard limits considered appropriate. Our datacenter management contractors comply with local law on cybersecurity.

The cloud computing, server configuration, and datacenter management fields are in constant flux. New measures are promulgated constantly. We ensure that we only engage contractors capable of understanding emerging risks and the evolving nature of cyber threats and attack vectors. There is however no framework, protocols, systems or processes completely immune to compromise. We can therefore not guarantee that our measures can defy every attempt to breach or circumvent them. Consequently, whilst our systems have been designed to a reasonable level of robustness, in order to be able to resist conventional threats and attacks, we cannot anticipate all scenarios and can therefore not prepare for all risks in advance. We are thus unable to provide assurance that our systems and your data may not be compromised whilst in our possession; we can only assure you that we shall take reasonable care and take steps to reduce the likelihood of such incidents occurring.

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “For More Information” section below.

 

 

Fair Use of Your Information

We consider the following to constitute reasonable grounds for holding, handling, managing and storing your information:

To comply with law, regulations, equity, policy, ethics and professional standards;

 

To equip us to be able to deliver on our commercial obligations to you or to a third party reasonably deemed to be acting in your commercial interest or providing you with products and services;

To optimize the user interfaces of our platforms to ensure a consistent experience; To enhance the customer engagement and relationship process; and

To keep you abreast of information relevant to you based on your record of interactions with us, our products, services and affiliates.

 

Choices and Access

  • Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes.  You may opt-out from: 

o          Receiving electronic communications from us:  If you no longer want to receive marketing-related emails or mobile messages from us on a going-forward basis, you may opt-out by: [•].

o          Our sharing of your Personal Information with affiliates for their direct marketing purposes : If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt-out of this sharing by: [•].

o          Our sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes: If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may opt-out of this sharing by: [•].

We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

  • How you can access, change or delete your Personal Information

If you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us by:  [•].   We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information.  For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable. 

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).  

[If you are a resident of California, under 18 and a registered user of our products or services, you may ask us to remove content or information that you have posted to our services by writing to [•].   Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.]

 

Retention Period

There is no set period for preserving records of your information.  We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. 

The criteria used to determine our retention periods include: 

  • The length of time we have an ongoing relationship with you and provide the services to you (for example, for as long as you have an account with us or keep using our services). To the extent we retain any of your Personal Information after the termination of our relationship with you, rest assured however that even after the termination, we shall continue to take reasonable steps to prevent the unauthorized disclosure of such Personal Information to third parties in the absence of the appropriate procedures.
  • Whether there is a legal obligation to which we are subject: For example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them. In many instances our duty and obligation to law enforcement agencies require that we maintain information for as long as physically practicable, even after you or we have terminated the relationship and the services being offered by us to you.
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

 

Third Party Content, Services, Advertising, and Payment Service

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which our products or services link.  There are occasions when we have to link you to third party resources on the Internet and elsewhere in order to assist you obtain a complete picture of a particular issue, situation or event. We may do these through hyperlinks, references or even popups. Please note that any such referrals or redirections are not meant to serve as an endorsement, approval or promotion of the content, features or functionalities that you may encounter on these sites or in these resources. You are strongly advised to do your own assessment of the appropriateness of the content or resources before taking any actions or decisions. Under no circumstances can we accept liability for the outcomes or consequences of your use or reliance on such third-party content.

 

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our social media pages.

[We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use our products or services and other websites or online services.

  • You may receive advertisements based on information relating to your access to and use of our products or services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags).  They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.  If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/.    [You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.] ]

[We may use a third-party payment service to process payments made through our services. If you wish to make a payment through our services, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy.  We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Information.]

 

Use of Our Products and Services by Minors

Our products and services are not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under 13.  

 

Jurisdiction and Cross-Border Transfer

Standard operational requirements usually require that information stored on servers in a particular jurisdiction must routinely be transferred and conveyed to other jurisdictions for reasons too many to enumerate here. When this happens, appropriate safeguard standards covering transport and transfer are observed.  Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our products or services you understand that your information will be transferred to countries outside of your country of residence, including [•], which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

[ADDITIONAL INFORMATION REGARDING THE EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here [hyperlink to EU Commission’s adequacy list online:  https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en]. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as [standard contractual clauses adopted by the European Commission and binding corporate rules] to protect your Personal Information. You may obtain a copy of these measures by contacting [contact details] or by following this link: [link]. ]  

 

Sensitive Information

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through our services or otherwise to us.

 

 

For More Information

mPedigree [mPedigree Network], located at [2 Goldkeys Heights, Relax Court Bend, Dzorwulu, Accra, Ghana], is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.  Any feedback, questions, comments, queries, inquiries and request for clarifications should please be sent to the Global Customer Service team reachable via:  info@goldkeys.org or info@mpedigree.com.  Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.