Privacy Policy
Effective Date: June 3, 2024
This Privacy Policy ("Policy") outlines the privacy practices of Omnea Pay (Pty) Ltd, a South African
company registered with number K2023893457 (referred to as the "Solution Provider,"
"we," or "us"). Our solution is enabled by Omnea (Pty) Ltd, a South African company with
registration number 2019/478958/07, that acts as an Operator as defined in the Protection of
Personal Information Act, 2013 (POPIA), and handles all personal information in accordance with
this privacy policy. We are dedicated to safeguarding the privacy of all visitors ("Visitors") to our
website, https://instapay.co.za/ (the "Website"), and mobile application, instaPay (the "App"), as
well as all individuals and merchants ("Users") who have subscribed to any of the services we offer
("Services").
If you have any questions or concerns about our privacy policy or practices, please contact us via
telephone at +27 (12) 470 4800 or email at support@instapay.co.za. By using our Website, downloading
our App, or subscribing to any of our Services, you agree to accept all the provisions outlined in this
Policy. If you do not agree with any part of this Policy, please refrain from using our Website,
App, or Services.
You must be at least 18 years old or possess the legal capacity to enter into binding contracts to
access the Website, App, or use the Services. We do not intend to collect or process any personal
information from individuals under 18 years of age.
By accepting this Policy, you acknowledge that you have read and agreed to all its provisions.
1. Changes to Privacy Policy
We reserve the right to amend this Policy at any time by posting a revised version on our Website
and App. The revised version will take effect for Visitors immediately upon posting. However, Users
will be given prior notice of any such revisions through the "Policy Updates" page on the Website
or by requiring Users to accept the new terms within the App. If a User is not satisfied with the
changes, they may terminate the subscribed Services.
2. General Information about Everyone
2.1 Types of Information We Collect
As a Visitor or User, you consent to the electronic collection, storage, and use of the following
categories of information for the purposes specified in section 2.3 below:
2.1.1 Usage Details: This category includes internet usage information, such as your Internet
Protocol address ("IP Address"), browsing habits, click patterns, unique user ID, software version,
system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences,
search engine keywords, JavaScript enablement, content and pages you access on the Website or
App, dates and times of your visits, paths taken, and time spent on sites and pages within the
Website or App.
2.1.2 Required Details: Information needed for the registration of our Services.
2.1.3 Optional Details: Additional information voluntarily provided, such as demographic details
or information related to your favourite social networking site, participation in competitions,
promotions, surveys, and other additional services.
2.1.4 Collected User Data: We collect the following data to comply with regulations, prevent
fraud, and enhance customer convenience:
2.1.4.1 Access to Camera and Gallery:
- Reason for Collection: To allow users to upload photos for profile pictures, document
verification, and other interactive features within the App.
- Information Collected: Images and videos from the user's device.
- Usage: Images are used for identity verification, personalized user profiles, and facilitating QR
code transactions.
2.1.4.2 Access to Contacts:
- Reason for Collection: To simplify user interactions and transactions by enabling features like
sending payments to contacts.
- Information Collected: Contact names and phone numbers.
- Usage: Contacts are used to streamline payments, send invites, and share promotional offers
with contacts.
2.1.4.3 Access to Location:
- Reason for Collection: To provide location-based services and enhance security.
- Information Collected: GPS coordinates and other location data.
- Usage: Location data is used to prevent fraud, offer location-specific promotions, and improve
service delivery.
2.1.4.4 Passport Number
- Reason for Collection: To comply with legal and regulatory requirements, particularly for
identity verification and anti-money laundering (AML) efforts.
- Information Collected: User’s passport number and issuing country.
- Usage: Passport information is used for identity verification, regulatory compliance, and fraud
prevention.
2.1.4.5 Gender
- Reason for Collection: To tailor services and communication, and for demographic analysis.
- Information Collected: User’s gender.
- Usage: Gender information is used to personalize user experience, improve targeted marketing
efforts, and analyse demographic trends.
2.1.4.6 Country
- Reason for Collection: To customize the user experience based on regional preferences and
comply with local regulations.
- Information Collected: User’s country of residence.
- Usage: Country information is used for service localization, regulatory compliance, and marketing
analysis.
2.1.4.7 Date of Birth
- Reason for Collection: To verify age eligibility, provide age-appropriate services, and for identity
verification.
- Information Collected: User’s date of birth.
- Usage: Date of birth is used to ensure compliance with age-related legal requirements,
personalize the user experience, and for security verification purposes.
2.2 How We Collect Such Information
2.2.1 Voluntarily Provided by You: Required and Optional Details can be submitted by you when
using our services, downloading/uploading content, participating in competitions, taking advantage
of promotions, responding to surveys, registering, subscribing to additional services, or using
optional features and functionality of the Website or App. Please note that the provision of Required
Details is essential for us to provide services to you.
2.2.2 Automatically Gathered via Various Technologies:
2.2.2.1 "Cookies" Information: When you access the Website or App, we may send cookies to
your device to collect certain Usage Details. These cookies may be session cookies (disappear after
closing your browser) or persistent cookies (remain after closing your browser but can be removed
manually).
2.2.2.2 Other Tracking Technology: We may automatically collect Usage Details through various
tracking technologies when you access the Website or App or open HTML emails or message links.
2.2.2.3 Web Beacons: Our Website may contain web beacons that count page views and access
cookies, helping us compile anonymous information about Website and Service usage. These web
beacons do not collect personally identifiable information.
2.3 The Purpose for Which We Collect This Information
2.3.1 We use Required Details to provide the services, verify identity, comply with legal obligations,
share with service providers and licensors to administer accounts, provide customer support, and
enforce legal rights.
2.3.2 We may use Optional Details for purposes as indicated at the time of your agreement to
provide such information.
2.3.3 Usage Details are used to provide the latest App version, remember your information for
convenient access, monitor Website usage metrics, and track your participation in promotions and
activities.
Please note that some third-party business partners may use their own cookies or widgets on our
Website, which are governed by their respective privacy policies.
3. Information About Users
3.1 Types of Information We Collect About Users
If you are a User, we may electronically collect, store, and use the following information:
3.1.1 Personal Details: Name, surname, identity number, student number, language, gender,
passport number, country, and date of birth.
3.1.2 Contact Details: Mobile number and email address.
3.1.3 Collected User Data: Additional information including access to camera and gallery,
contacts, and location.
3.2 How We Collect Information About Users
Personal and Contact Details are provided directly to us during User registration or through
subsequent updates to your User Account.
3.3 The Purposes for Which We Collect User Information
We use User-provided information to operate, enhance, and provide features of the Services.
Specifically:
3.3.1 Personal Details are used to identify Users, manage User Accounts, and administer service
usage.
3.3.2 Contact Details are used to verify identity, send service-related notifications, inform Users
about updates or content, address copyright infringement, and provide information about
competitions, promotions, and special offers.
3.3.3 Collected User Data is used for compliance with FICA and AML, fraud prevention, and
customer convenience in interacting with contacts and QR codes.
4. How We Protect & Store Personal Information
4.1 Personal information of Users and Visitors is stored and processed on cloud-based servers
protected by firewalls and data encryption, such as AWS (Amazon Web Services) and Azure. The
App does not store data on mobile devices and communicates with cloud servers through Secure
Socket Layers (SSL). Access to personal information is authorized only for employees with job
responsibilities requiring access.
4.2 Do not disclose your account password to anyone and be cautious of unsolicited requests for
your password or PIN. You are responsible for maintaining the confidentiality of your unique
password, account information, and linked bank account information.
4.3 If you are a legal entity and not an individual, we will liaise only with your named contact or
alternative contact provided by your named contact.
5. How We Share Personal Information With Others
5.1 We may share personal information with:
5.1.1 Other companies within our corporate group to provide joint content and services, detect
illegal acts, and guide product decisions. These companies use information only for marketing
communications if you request their services.
5.1.2 Service providers under contract for business operations (e.g., fraud prevention, marketing,
technology services) who use information for services provided to us.
5.1.3 Universities, retailers, service providers, and financial institutions with whom we partner to
create and offer products and services. These organizations may use information to market products
related to Omnea Pay (Pty) Ltd with your consent.
5.1.4 Companies we plan to merge with or be acquired by. In such cases, the new entity will be
required to adhere to this Policy regarding your personal information, and you will receive prior
notice.
5.1.5 Law enforcement, government officials, fraud detection agencies, or other third parties when
compelled by a subpoena, court order, legal procedure, or to comply with the law, prevent physical
harm or financial loss, report suspected illegal activity, or investigate violations of our User
Agreement.
5.1.6 Other third parties with your consent or direction.
5.2 We do not sell or rent your personal information to third parties for marketing purposes and
share your personal information with third parties only as described in this Policy.
6. Your Rights
6.1 Keep your personal information up to date by informing us of any changes.
6.2 Review and edit your personal information at any time by signing into your Account and
accessing the My Profile menu in the Application pages.
6.3 Request access to your personal information and obtain a description of the information we
hold about you, including third parties who have had access to it.
6.4 Request the correction of inaccurate personal information.
6.5 Restrict the processing of personal information in certain circumstances.
6.6 Object to automated decision making, including profiling, if it has a legal effect on you.
6.7 Request the deletion or erasure of personal information under certain circumstances.
6.7.1 Deactivate your account at any time, but please note that some information may remain
viewable to others as described in the Policy.
6.7.2 Retention of certain information for legal purposes.
6.7.3 Withdraw your consent subject to certain conditions.
6.8 Raise complaints related to personal information protection issues with the Information Officer
at inforeg@justice.gov.za.
6.9 If you wish to exercise any of these rights, please submit a request. Some rights may be limited
in certain situations, as required by law.
7. Non-Personal Information
The following information is not considered personal information for the purposes of this Policy:
7.1 Permanently de-identified information that cannot be traced back to you.
7.2 Non-personal statistical information collected and owned by us.
7.3 Information you provide voluntarily in open, public environments or forums, as it is no longer
confidential and not subject to protection under this Policy.
8. Your Consent to the Processing of Your Personal Information
By accepting this Policy, you consent to the collection, storage, processing, and disclosure of your
personal information as described in this Policy for as long as you are a registered User of our
Services. Upon termination of your registration and Account closure, we retain your information only
for record-keeping purposes in accordance with applicable law.
9. Changes to the Privacy Statement
This Policy may change over time, and the latest version is available on our Website. We will notify
you of any changes to this Policy by publishing them on our Website, and you can save or print the
Policy for your records.
10. How You Can Contact Us About Privacy-Related Questions
For questions or concerns regarding this Policy, to exercise your rights, or if you are aware that a
minor under the age of 18 has provided personal information, contact us at support@instapay.co.za.
