PRIVACY POLICY MODEL FOR MOBILE APPLICATIONS

This privacy policy governs your use of the software application 911 SMART RESPONSE APP (“Application”) for mobile devices that was created by Overflow Business Holdings The Application is a mobile panic application linked to a Control Room for Emergency Assist Services making use of Geo Location, Panic Alerts and Chat functionality.

 What information does the Application obtain and how is it used?

User Provided Information 

The Application obtains the information you provide when you download and register the Application. Registration with us is optional. However, please keep in mind that you may not be able to use some of the features offered by the Application unless you register with us. 

Your Account Information. You provide your mobile phone number to create an account. You provide us the phone numbers in your mobile address book on a regular basis, including those of both the users of our Services and your other contacts. You confirm you are authorized to provide us such numbers. You may also add other information to your account, such as a profile name, profile picture. Your mobile phone number is only provided o us on to keep your profile active. We do not share your number with any other parties outside of software environment.  

Usage and Log Information. We collect service-related, diagnostic, and performance information. This includes information about your activity (such as how you use our Services, how you interact with others using our Services, and the like), log files, and diagnostic, crash, website, and performance logs and reports. This information is only used for the advancement of our technology and operating systems. 

No Third-Party Banner Ads. We do not allow third-party banner ads. We have no intention to introduce them, but if we ever do, we will update this policy to advise you of the intetnion and you will still have access to provide permission for this. 

When you register with us and use the Application, you generally provide (a) your name, email address, age, user name, password and other registration information; (b) transaction-related information, such as when you make purchases, respond to any offers, or download or use applications from us; (c) information you provide us when you contact us for help; (d) credit card information for purchase and use of the Application, and; (e) information you enter into our system when using the Application, such as contact information and project management information.

We may also use the information you provided us to contact your from time to time to provide you with important information, required notices and marketing promotions.

Automatically Collected Information 

In addition, the Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application. 

Does the Application collect precise real time location information of the device?

When you visit the mobile application, we may use GPS technology (or other similar technology) to determine your current location in order to determine the city you are located within and display a location map with relevant advertisements. We will not share your current location with other users or partners.

If you do not want us to use your location for the purposes set forth above, you should turn off the location services for the mobile application located in your account settings or in your mobile phone settings and/or within the mobile application. 

Use of Personal Data

In order to pursue our business objectives and strategies we will use and process your Personal Data for the following lawful purposes: to facilitate the business relationships we have with you including contacting the data subject and attending to the data subject's enquirers and requests, providing the data subject from time to time information regarding our services and goods and other ad hoc business related information; to comply with our financial, regulatory and other legal obligations; to pursue our legitimate business interests including the performance of risk assessments, data analysis, testing, product development and product review purposes; for the purpose of performance of a contract as between Peach Payments and the merchant so as to complete payment transactions and to provide payment-related services to our merchants.

Disclosure of Personal Data

We share your Personal Data with trusted entities as outlined below: a) Other members of the Peach Payments corporate family (including https://mcgw.alipay.com) for internal administrative purposes; b) Our service providers that provide services on our behalf such as identity verification services, website hosting, data analysis, information technology and related infrastructure, customer service and auditing services; c) Third Party business partners when this is necessary to provide our services to you; d) Corporate transactions. In the event that we enter into a disposition that changes the structure of our business, such as a merger, acquisition, sale, assignment or change of control, we may share your personal data with third parties in connection with facilitating and evaluating the transaction and related due diligence procedures; and e) Otherwise with your consent.

We will be sharing your information to Peach Payments, the payment provider, in order to process your monthly payments. The information is encrypted in transit. We have taken all the reasonable steps in order to protect your information. Please note that only the information required in order to process your monthly payments are collected and shared with the payment provider.

WHAT PERSONAL INFORMATION DOES https://mcgw.alipay.com COLLECT ABOUT YOU?

We collect and use personal information about you, including when you interact with us, register for an Alipay account, use the Alipay Services to make purchases or otherwise conduct financial transactions, or otherwise visit or use our Alipay Services.

We may collect the following personal information about you:

• your basic personal details, including first and last name, date of birth, social security number and copies of your personal ID documents (e.g., passport);
• contact information, including your address, phone number, email, or other information that permits us to contact you;
• account information, such as details of the payment card used to complete a transaction with a merchant;
• company registration details, such as the basic personal details of the ultimate beneficiar(y)(ies) and account authentication details to complete “know your business” or “know your client” checks as required by local law;
• financial information and tax identification information;
• transaction details, such as the merchants you deal with, the amounts paid and the details of the products and/or services purchased;
• details of any marketing preferences you have given us (such as requests to receive or not receive certain types of marketing communication);
• copies of communications with or about you; and
• the following usage, device, and technical information:
  • information about the device you use to interact with us, and
  • information from your visits to our websites or mobile applications, collected automatically through tracking tools described in section 2 below. This information includes browser history, product engagement, length of visit/usage, page views, IP address or other unique identifiers, browser/platform type and version, internet service provider, operating system, referral source/exit pages, device operations, and other information regarding your interaction with our websites and our advertisements) session information, device ID, user agent, and IP address. We also embed tracking tools within the emails and other communications we send to you to help us understand how you interact with those messages, such as whether and when you opened a message or clicked on content within the message.

As noted above, we collect personal information which may be considered sensitive in certain jurisdictions. Specifically, if we collect your passport, your payment card information, or your financial information and tax identification information, you may have additional rights and protections with regard to such sensitive personal information under certain data protection laws.

Whenever personal information is collected (e.g. upon registration), we will indicate whether the provision of such information is mandatory (e.g. with an asterisk). If you do not provide such mandatory personal information to us, you may not be able to register for Alipay Services or, at least, you may not be able to participate in certain elements of the Alipay Services.

HOW https://mcgw.alipay.com OBTAINS YOUR PERSONAL INFORMATION

We collect the above personal information (including potentially sensitive personal information) in connection with Alipay Services from various sources, either directly from you or indirectly, as set out below.
We collect personal information directly from you when you provide it to us in connection with the Alipay Services. For example, we collect your personal information when you enquire about or register to use any of the Alipay Services, sign an Agreement with us, provide your personal information during the merchant on-boarding process, log into your Alipay account to use the Alipay Services on our site, or when you communicate with us via e-mail, phone, SMS, or any other electronic means.
We also collect personal information automatically from your devices. We use cookies and other tracking tools and technologies that automatically collect information like browser, usage, and device information any time you visit or interact with our websites, mobile apps, emails, and online content or ads on other websites and platforms. We may provide further information, depending on your location, via a cookie policy; please check the Alipay Services website or app you are using for more details.

We also receive personal information about you from the following sources:

• merchants and other third parties who support the ability to make payments and conduct transactions through Alipay Services or otherwise;
• Alipay Affiliates;
• suppliers providing services on our behalf (such as vendors that provide hosting services, assist in sending emails, provide technical assistance and security, perform research and analysis for us, or provide marketing and advertising services);
• banks and other payment institutions that we cooperate with to provide you with the Alipay Services; and
• publicly available sources, such as public registers and social media.

HOW https://mcgw.alipay.com USES YOUR PERSONAL INFORMATION

We use your personal information (including your sensitive personal information, if any) to provide you with Alipay Services. More specifically, we may use your personal information for the following purposes:

• verifying your identity, including during account creation and payment password reset processes;
• verifying your eligibility as a User of Alipay Services;
• processing, maintaining and managing your registration as a User;
• providing you with Alipay Services and related User services, including enabling and conducting transactions, customizing your user experience, enabling the receipt of balance top-ups, financing proceeds and third-party payments, facilitating the settlement of payment for goods and services and providing other fund settlement services, handling foreign exchange conversions, charge-backs, sending notices about transactions, and responding to your queries, feedback, claims or disputes;
• contacting you in relation to our provision of Alipay Services, contacting you in connection with any communication preferences or requests you have expressed, asking you for feedback about Alipay Services or other related products and services, collecting feedback from you and your staff about our products and services and using such feedback to improve our business and/or customize products and services;
• serving you advertising and sending you information about products and services, including for promotional and marketing purposes;
• assessing, detecting, investigating, preventing or remediating fraud, data breaches or other potentially prohibited or illegal activities and otherwise protecting the integrity of our platform and safety and security of our staff and that of our suppliers and counterparties;
• managing our risk, performing creditworthiness and solvency checks on Users, or detecting, investigating, preventing or remediating violations of your agreements with us or any of our applicable policies, industry standards, guidelines, laws and regulations;
• making disclosures as may be required by any rules, law or regulation, regulatory authorities, government officials, card association or other payment network. Such disclosures may also be made pursuant to any subpoena, court order or other legal process or requirement applicable to us or any Affiliates (including “know your customer”, anti-money laundering, counter-terrorist financing reporting, tax requirements or other commercial disputes);
• making disclosures to competent regulators to prevent any harm or financial loss, to report suspected illegal activity or to establish, exercise, or defend claims or potential claims on behalf of ourselves or our Affiliates;
• improving and optimizing the Alipay Services;
• managing our business including to protect Users, prevent harm, fraud or theft to ourselves or others, maintain the security of our products, and protect our rights or property and those of others;
• to comply with law, regulation, codes of conduct and other good practice and conduct requirements;
• and in any other ways for which we provide notice at the time of collection.

WITH WHOM DO https://mcgw.alipay.com SHARE YOUR PERSONAL INFORMATION?

We share your personal information (including your sensitive personal information, if any) for the purposes indicated under the section How we use your personal information above, with the following categories of recipients:

• our Affiliates;
• merchants that provide you with products, services and other offerings on or through Alipay Services;
• any agent, contractor, vendor, or service provider acting as subcontractor on behalf and upon our instruction to help us in providing Alipay Services. We set out a list of such agents, contractors, vendors, and service providers here. We engage the foregoing to help us with fraud prevention, anti-money laundering checks, credit checking, bill collection, data entry, database management, promotions, marketing, customer service, technology services, products and services alerts and payment extension services or to provide trade financing services;
• banks, card associations, payment networks or acquiring institutions;
• organisations involved in processing of payments and conducting transactions through Alipay Services;
• law enforcement agencies, insurers, government and regulatory authorities or any other organizations to which we, or any of our Affiliates or service providers, is under an obligation to make disclosure under the requirements of any applicable law, regulation, code of conduct or good practice or conduct requirement or commercial arrangement;
• individuals and entities involved in any merger, acquisition, corporate reorganization, financing, or similar transaction with us, including in the event of the sale of all or part of our assets; and
• our own and others’ professional advisors (e.g., lawyers, accountants, auditors, and trustees).

DOES https://mcgw.alipay.com STORE AND PROTECT YOUR PERSONAL INFORMATION?

We will keep your personal information (including your sensitive personal information, if any) in accordance with our policies and for as long as it is necessary to provide you with the Alipay Services or other purposes as set out in this Privacy Notice. In addition, we may retain your personal information (or sensitive personal information, if any) for a longer period (including after you are no longer a User) if it is necessary to comply with laws and regulations applicable to us. The criteria we use to determine the appropriate retention periods are:

• the various regulatory requirements that we are subject to;
• whether a legal claim could be brought against us for which your personal information may be relevant;
• the necessity of your personal information to provide the Alipay Services,
• the type, nature, and sensitivity of your personal information being processed; and
• the legal basis for processing your personal information – e.g., consent or legitimate interests or otherwise.

Do third parties see and/or have access to information obtained by the Application?

Yes. We will share your information with third parties only in the ways that are described in this privacy statement.

We may disclose User Provided and Automatically Collected Information:

• as required by law, such as to comply with a subpoena, or similar legal process;
• when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.
• if Oveflow Business Holdings (Pty) Ltd is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

What are my opt-out rights?

You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out via email, at optout@overflow.co.za

Data Retention Policy, Managing Your Information

We will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. We will retain Automatically Collected information for up to 24 months and thereafter may store it in aggregate. If you’d like us to delete User Provided Data that you have provided via the Application, please contact us at privacy@overflow.co.za and we will respond in a reasonable time. Please note that some or all of the User Provided Data may be required in order for the Application to function properly.

Children

We do not use the Application to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at privacy@overflow.co.za . We will delete such information from our files within a reasonable time.

Security

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application. Please be aware that, although we endeavor provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

Changes

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here and informing you via email or text message. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes. You can check the history of this policy by clicking here.

Your Consent

By using the Application, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing,” means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the United States. If you reside outside the United States your information will be transferred, processed and stored there under United States privacy standards. 

Contact us

If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at privacy@overflow.co.za