This Privacy Notice describes how CurrenC collects and processes your Personal Information through the CurrenC Site, Portal and any applications that are referred to herein. For purposes of this Privacy Notice, Personal Information will be understood in accordance with the definition provided in the Protection of Personal Information Act 4 of 2013 and can broadly be understood as the non-public information that personally relates to or identifies you as an individual or as a legal entity.
1. How Personal Information is obtained
In order to utilise CurrenC Services', you will be required to create an account on the Portal and provide certain Personal Information that will be used to verify you or a legal entity's identity. Additional Personal Information may be requested throughout your business relationship with CurrenC in order utilise the Services, carry out your instructions or for CurrenC to remain compliant with certain laws and regulations. Failure to provide certain Personal Information may result in CurrenC's refusal to offer you our Services. To the extent permitted under the applicable law, we may collect certain types of information automatically, for example when you interact with us or use the Site, Portal or Services. Furthermore, our Site may incorporate social media features and widgets provided by third parties. These features may collect your IP address, track the page you are visiting, and utilise cookies to ensure their proper functionality. Interactions with these features and widgets are governed by the Privacy Notice of the respective company providing them.
2. Purpose of Collecting, Using and Storing Personal Information
CurrenC is required to collect, use, process and store Personal Information in order to remain compliant with certain legal and regulatory requirements. In addition, CurrenC will use this Personal Information in order to transact and communicate with you or your business.
3. Sharing of Personal Information
To protect your privacy and Personal Information, CurrenC undertakes to limit the sharing of your Personal Information outside of CurrenC. Accordingly, CurrenC will take all reasonable steps to prevent unauthorised access to or disclosure of your Personal Information, however CurrenC cannot provide a complete guarantee in this regard.
CurrenC may share your Personal Information to authorised and reputable third parties or CurrenC's affiliates. CurrenC will share your Personal Information only when it is necessary and required to provide you with the Services. The third party shall only have access to the Personal Information required to perform their functions and may not be used for any other purposes.
In the event that CurrenC is involved in a merger, sale, dissolution or similar event, Personal Information may form part of the transferred assets.
CurrenC reserves the right to disclose your Personal Information when it is required to do so by law to regulatory, law enforcement or other government authorities, including during routine regulatory examinations and to necessary credit reporting or collection agencies, or when necessary to protect our rights or title in property.
4. How Personal Information is Protected
CurrenC will limit access to those employees who need access to the Personal Information in order to provide you with the required Services with CurrenC. In keeping with industry standards and practices, CurrenC will maintain appropriate physical, electronic and procedural safeguards and controls designed to protect your Personal Information, including your financial and transaction information. While no security technology is impenetrable, CurrenC is constantly reviewing, refining and upgrading the security technology as and when new tools and upgrades become available.
5. Reviewing and Updating Personal Information
You are responsible for ensuring that all Personal Information submitted is accurate, complete and updated. All Personal Information should be reviewed on a regular basis and in the event that your Personal Information needs to be updated. CurrenC is entitled to request updated Personal Information from you at any time. In the event that you fail to comply with such a request, CurrenC reserves the right to suspend or terminate your CurrenC Account and any CurrenC Services.
6. Election to not disclose Personal Information
CurrenC, at its discretion, may refuse to engage in business with you if you fail to or elect not to disclose Personal Information to CurrenC or its employees. This refusal is based on CurrenC's obligation to comply with various laws and regulations that apply to it.
In the event that CurrenC is provided with inaccurate or fraudulent Personal Information during the business relationship, CurrenC has the duty to report you or the legal entity to the relevant authorities.
7. Storing of Personal Information
CurrenC will retain your Personal Information to enable your continued use of CurrenC Services and shall retain your Personal Information for a period of 5 (five) years.
CurrenC only processes your Personal Information in compliance with this Notice and in accordance with the laws governing data protection and processing. If, however, you wish to raise a complaint regarding the processing of your Personal Information or are unsatisfied with how CurrenC handled your Personal Information, you may contact CurrenC at info@CurrenC.co.za, alternatively you may refer the complaint to the relevant ombudsman.
In adopting this Policy, CurrenC wishes to balance its legitimate business interests and your reasonable expectation of privacy. CurrenC is committed to protecting the privacy and the Personal Information of all former and current clients. If you choose to become an inactive client, your Personal Information will continue to be protected by this Policy and any governing laws. In the event that you close your account, CurrenC will retain your Personal Information for regulatory compliance, internal record-keeping and other legal purposes.
8. Travel Rule
At CurrenC, we take privacy and security seriously. To comply with the Travel Rule, CurrenC will securely collect, transmit and retain required information such as the originator and beneficiary information and wallet details using industry standard protocols. This data will only be shared with verified and compliant crypto asset service providers, counterparties or trusted third party service providers in accordance with applicable Travel Rule obligations and this Privacy Notice. In addition, CurrenC may utilise third party compliance software to facilitate the collection, transmission and retention of the required information.
CurrenC may also retain records relating to Travel Rule information for a period of 5 (five) years after termination of your relationship with CurrenC or as required under the applicable and regulatory laws.