MSACCO - The Multi-Channel Payment Gateway

PRIVACY POLICY

Developed December 2022

1.0 INTRODUCTION:

Early December 2021, Futurelink Technologies Ltd (FLT) acquired a National Payment System Operator License from Bank of Uganda, defining its new found purpose as to enhance the financial resilience of Africa’s low and middle income earners. FLT consequently set out to democratise Africa’s financial services though an efficient community-driven marketplace.

In order to pursue this big dream, FLT developed MSACCO app to facilitate attainment of the the mission. We therefore propose and request the approval of the following changes to the identity and strategy of FLT for the next 5 years;

All users of MSACCO App, consent to the use of the Application directly through the App on their smartphones.

In light of all the aforementioned users of the MSACCO App, FLT is mindful of all the data we collect, process, store, and share. FLT is committed to maintaining the authenticity and sanctity of all information and data in their possession and is committed to protecting the privacy and security of all FLT customers and user’s data.

This privacy policy (together with FLT Terms of Use, and FLT Disclaimer (and any other documents referred to herein) explains its views and practices regarding the collection, processing, use, disclosure and transfer of customer information by Us (the Privacy Policy). This Privacy Policy incorporates the terms of the Terms of Use, and FLT Disclaimer, and by using, visiting or browsing MSACCO Application (use of MSACCO Application including, amongst others, accessing MSACCO Application and/or registering to use and using the Services and/or the Content), The customer accepts and agrees to FLT information practices described below and this Privacy Policy, FLT Disclaimer, and FLT Terms of Use.

2. INFORMATION WE MAY COLLECT FROM THE CUSTOMER

We receive and store information, including personal information, about the customer and customer use of MSACCO Application and the Services. This information is gathered in a number of ways, as further set out below. In this Privacy Policy, We use the term personal information to mean information that can be used to uniquely identify or contact the customer. Any other information (non-personal information) is information that does not permit direct association with the customer. We may collect, process, use, disclose and transfer non-personal information for any purpose. The customer can choose not to provide personal information that FLT may request of the customer, but, in general, most of the personal information FLT requests what is required in order to provide the customer with access to MSACCO Application and the Services, and the lack of such personal information may prevent FLT from doing so. We may collect and process the following personal information about the customer:

  1. Information that the customer provide on or through MSACCO Application or the Services. This includes information provided at the time of registering to use MSACCO Application, receive payment, making payments or applying for a loan. We may also ask the customer for information when the customer reports a problem with MSACCO Application or the Services;

  2. Details of customer visits to and use of MSACCO Application including, but not limited to, traffic data, location data, weblogs, service provider page viewing statistics and other communication data, whether this is required for FLT own billing purposes or otherwise and the resources that the customer access;

  3. Information related to the customer and customer use of MSACCO Application, including but not limited to: customer activity on the Application, correspondence, internet protocol addresses, device and software data (such as type, configuration and unique identifiers);

  4. A record of correspondence if the customer contact FLT;

  5. Obtained from surveys that FLT may ask the customer to voluntarily complete from time to time, which FLT uses for research purposes;

  6. Information posted by the customer on MSACCO Application and through any use of the Services;

  7. Any other information that may be necessary:

(i) to carry out actions for the conclusion or performance of the Agreement or any contract to which the customer are a party;

(ii) to comply with an obligation imposed on FLT by law;

(iii) to protect customer legitimate interest;

(iv) to pursue a legitimate interest of FLTs, the Customer or of a third party to whom the information is supplied; and

  1. Any content of a personal nature that is uploaded by the customer or any other Registered User in respect of the customer.

3. INTERNET PROTOCOL ADDRESSES

FLTWe may collect information about customer device, including where available customer internet protocol address, operating system and browser type, for system administration and to report aggregate information to FLT advertisers and/or service providers. This is statistical information about customer browsing actions and patterns, and does not identify The customer.

4. COOKIES

  1. FLT and our service providers use cookies and other technologies (such as web beacons) for various reasons. For example, We may use cookies and other technologies to make it easy to access MSACCO Application and the Services by remembering the customer when the customer return to MSACCO Application and use the Services, to provide and analyze FLT services, to learn more about the customer and customer likely interests, to improve MSACCO Application and the Services.

  2. A cookie is a small data file which is stored on customer computer or other device when The customer browse and use websites and online services. If the customer return to a website or application, the cookie shows that it is a repeat visit. The cookie contains no personal information. The cookie cannot be used to identify the customer on the websites of third parties, including the website of the analysis provider. Cookies can additionally be used to store customer preferred settings, e.g. language and country settings, so that they will be immediately available on customer next visit. We do not use the internet protocol addresses or cookies to identify the customer personally. We use the web analysis system in order to raise the efficiency of MSACCO Application and the Services.

  3. Cookies are not the only types of technology that enable this functionality. FLT also use other, similar types of technologies including but not limited to browser storage and plugins (e.g., HTML5, IndexedDB, WebSQL and Silverlight storage).

5. WHERE WE STORE CUSTOMER PERSONAL INFORMATION

The information that FLT collects from the customer may be transferred to, and stored in Uganda. It may also be processed and backed up outside Uganda or for one of FLT service providers (including but not limited to, cloud service or other IT providers, and other companies that provide services to Us).

Such staff members may be engaged in, among other things, the provision of the service or the provision of maintenance and support services. By submitting customer personal information, The customer agree to this transfer, storing or processing. FLT will take all steps reasonably necessary to ensure that customer information is treated securely and in accordance with this Privacy Policy and in accordance with the terms of the Data Protection and Privacy Act, 2019 , as amended from time to time.

6.SECURITY

  1. FLT takes information security seriously and uses reasonable administrative, technical, physical and managerial measures to protect customer personal information from unauthorized access. For example, We utilise an industry-standard protocol for certain of customer transmissions to FLT, in order to encrypt certain personal information that the customer send to FLT through the registration and sign up process.

  2. Unfortunately, no security system can be guaranteed to be completely secure. Accordingly, although We will do MSACCO best to protect customer personal information, FLT cannot guarantee the security of customer information transmitted to, on or through MSACCO Application or the Services, and any transmission is at customer own risk. By using MSACCO Application or providing information to FLT through any means, the customer agree that We can communicate with the customer electronically regarding security, privacy, and administrative issues relating to customer use of MSACCO Application.

  3. In order to provide the customer with ease of access to customer account and to help administer MSACCO Application and the Services, FLT implements technology that enables Us to recognize the customer as the account holder and provide the customer with direct access to customer account without requiring the customer to retype any password or other username identification when The customer log in to MSACCO Application and the Services. The customer can choose not to take advantage of this feature on customer computer, smartphone or other device by checking or unchecking the relevant box when the customer login on or on customer settings through the Application. To remove access to customer account from customer computer or other devices:

(i) email FLT administrator at for deactivation (note, deactivation may not occur immediately) or

(ii) delete customer settings from customer computer or other (steps vary by device and the option is not available on all devices the customer are responsible for maintaining the confidentiality of customer account access information and for restricting access to customer computer or device through which the customer access customer account.

If the customer do not maintain the security of customer password or device, or fail to log out or deactivate customer device, subsequent users may be able to access customer account, including customer personal information.

7.USES MADE OF THE INFORMATION

  1. FLT uses information and personal information held about the customer in the following ways:

  1. to ensure that Content on MSACCO Application and the Services is presented in the most effective manner for the customer and for customer computer or other device;

  2. to process customer registration on MSACCO Application as a Registered User, customer use of the Services and Content, and to communicate with The customer in respect of this;

  3. to provide the customer, or allow FLT service providers to provide the customer, with information, products or services that the customer request from FLT or which We feel may interest The customer (such as newsletters, messages about new features, special offers, promotional announcements, consumer surveys and other marketing concerning MSACCO Application and the Services), where The customer have expressly consented to be contacted for such purposes;

  4. to determine customer general geographic location, in order to enforce the terms of this Privacy Policy, FLT Terms of Use, Disclaimer and Acceptable Use Policy; personalize MSACCO Application and the Services and FLT marketing to better reflect particular interests; help Us to quickly and efficiently respond to inquiries and requests; and otherwise analyze, enhance, administer or promote the service offering for The customer and other Users;

  5. to carry out FLT obligations arising from the Agreement and any contracts entered into between The customer and Us, if any;

  6. to help the customer access financial services, offers on products and services that We may have from time to time;

  7. to allow the customer to participate in interactive features of MSACCO Application and the Services, when The customer choose to do so; and

  8. to notify The customer about changes to MSACCO Application and the Services.

  1. We do not disclose information about Users to FLT advertisers (if any) without customer prior written consent, but FLT may provide them with aggregate information or information in an otherwise anonymous form about MSACCO Users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, individuals in a specific territory). We may make use of the personal information FLT has collected from the customer to enable Us to advertise or displaying information for target audience.

  2. In addition FLT may use other companies, agents or contractors to perform services on FLT behalf or to assist Us with the provision of access to MSACCO Application and the Services to the customer. For example, FLT may engage service providers to provide marketing, communications, infrastructure and IT services, personalize and optimize MSACCO Application and the Services, process credit card transactions, provide customer service, collect debts, analyze and enhance data, including Users’ interaction with FLT service, and process consumer surveys. In the course of providing such services, these service providers may have access to customer personal information. We do not authorize these service providers to use or disclose customer personal information except in connection with providing the services We request of them.

8. DISCLOSURE OF CUSTOMER INFORMATION

In addition to the other provisions of this Privacy Policy, We may disclose customer personal information if We reasonably believe that access, use, preservation or disclosure of such information is reasonably necessary to:

  1. Satisfy any applicable law, regulation, legal process,or governmental request;

  2. Enforce applicable terms of use, including investigation of potential violations thereof;

  3. Detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues; or

  4. Protect against harm to the rights, property or safety of Us, MSACCO Users or the public as required or permitted by law. This includes exchanging information with other companies and organizations for the purposes of fraud protection, anti money laundering and credit risk reduction.

We will not sale customer personal information to any third party.

9.CUSTOMER RIGHTS

The customer has the right to ask FLTUs not to process customer personal information for marketing purposes. We will usually inform the customer (before collecting customer information) if We intend to use customer information for such purposes or if We intend to disclose customer information to any third party for such purposes.

The customer can exercise customer right to prevent such processing by checking certain boxes on the form on which FLT collects customer information or by responding to the emails FLT sends the customer in this regard.

The customer can also exercise this right at a later time by contacting Us at info@fltug.com.

10. CHANGES TO FLT PRIVACY POLICY

We may, from time to time, make changes to this Privacy Policy. Any changes We may make to FLT Privacy Policy in the future will be posted on this page and shall be effective immediately.

We may also, at FLT discretion, notify the customer of such changes, but We are under no obligation to do so and it is customer responsibility to check this page on a regular basis to ensure that the customer are made aware of the terms of this Privacy Policy as updated from time to time.

11.CONFIDENTIALITY CLAUSE

  1. By accepting the terms of this Policy, the customer undertake to exercise utmost confidentiality of all data the customer access by vitue of being a user of MSACCO Applications. The customer undertake not to divulge, share, manipulate, sale or use information collected or accessed in a manner of inconsistent with this Policy and the interests of FLT.

  2. All users undertake to use the information for the benefit of MSACCO and all its stakeholders only to the extent that it is necessary for conducting the business of FLT. The customer hereby bind him/herself to confidentiality and non-disclosure the breach of which will attract all lawful and equitable remedies in contract and statute.

12. LIMITATION OF LIABILITY

  1. FLT shall not be liable for any damages arising out of third party actions where any user of the services of FLT and such third party shall bear personal or corporate liability for any contractual or statutory breach of this Policy.

  2. The customer confirm that the information supplied is accurate, true, and reliable. We shall not be liable for damages caused as a result of false, inaccurate and unreliable data. We shall hold The customer liable for any damages that will arise from the data supplied.

13. CONTACT

  1. customer personal information is controlled by Us (address below), and We provide The customer with access to MSACCO Application and the Services and We are the responsible party (where applicable).

  2. If the customer have questions concerning customer account, please contact msacco@fltug.com .com at If the customer has questions concerning this Privacy Policy, including the treatment of customer personal information and/or FLT use of cookies and other technologies, please contact Us via email at info@fltug.com.