V1.4

19 September 2023

This Privacy Policy applies to Centbee.com owned and operated by Centbee (Pty) Limited. This Privacy Statement describes how Centbee (Pty) Limited. (“Centbee”, “our”, “us” or “we”) collects, uses and discloses the personal information you provide. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information. If you have questions or complaints regarding our privacy policy or practices, please contact our appointed Information Officer at info@centbee.com.

A Special Note About Children

Children are not eligible to use our services and we ask that minors (under the age of 16) do not submit any personal information to us or use our services. We do not knowingly solicit data from, or market to, persons under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with information without his or her consent, he or she should contact us at info@centbee.com. We will delete such information from our files.

OVERVIEW

It is important for you to review this Privacy Policy as it applies to all Centbee Services. Centbee takes the protection of and privacy of your personal information very seriously and will collect, use and disclose your information only in accordance with the terms of this Privacy Policy or otherwise with your consent or in compliance with the law. In order to operate and provide the Centbee website, application and services (the “Centbee Services”) and to reduce the risk of fraud, we must ask you to provide us with information about yourself. This Privacy Policy describes the information we collect and how we use and disclose that information. We will not sell or rent your personal information to third parties for their marketing purposes. However, in order for us to offer our services to our users; enhance the quality of our service from time to time; and protect the interests of our users, we will in limited circumstances share some of your personal information with third parties under strict restrictions, as described in more detail in this Policy. By accepting the Privacy Policy on registration, you expressly consent to our collection, use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy.

If you disagree with the terms of this Privacy Policy, please do not register for or use the Centbee Services.

1. WHAT INFORMATION DO WE COLLECT?

Categories of Information

Centbee may gather and use information about you, including (but not limited to) information in the following categories:

• Identification data and contact information (e.g. name, address, telephone number, email address, date of birth);
• Profile information (the information provided by you which is displayed in your Centbee profile in the Centbee application);
• Electronic identification data (e.g. IP addresses, cookies);
• Banking and payment information (credit card information, account number) for accounts linked to your Centbee account;
• Survey results;
• Information about your usage of and interaction with the Centbee software, our products and websites including computer, platform, device and connection information, device capability, carrier network, bandwidth, statistics on page views, and traffic to and from our websites, operating system or browser type;
• BSV addresses used and transactions on those BSV addresses;
• Copies of government-issued identification, such as driver’s license, passport or other documents such as a recent utility bill;
• Information from third parties (as discussed below);
• Products or services ordered and delivered;
• Correspondence between you and Centbee, including email, telephone logs or recordings, or instant message content, or messages between or to your contacts or other Centbee users when sent using the Centbee system; and
• Centbee prepaid card details and usage.

2. REQUIRED INFORMATION

To open a Centbee account or use the Centbee Services, you must provide your mobile phone number. Using certain profile information, we utilize third parties to extract additional information to help verify the authenticity, and any background checks required on your account. In order to purchase BSV into your Centbee account, you must provide additional personal information (which may include a copy of government-issued photo identification, and supporting address documentation) necessary to validate your identity for legally-required “Know Your Client” purposes, and to comply with our legal obligations such as anti-money laundering and anti-terrorist financing laws and regulations. We may also require other commercial and/or identification information if you send or receive certain high-value transactions or high overall payment volumes through the Centbee Services in order for us to comply with our anti-money laundering or other legal obligations.

3. TRANSACTION INFORMATION

When a user downloads any of Centbee’s apps or otherwise envisages to use any of Centbee’s products or services, whether or not such products or services are actually used, the user shall agree to have entered into a business relationship with Centbee and shall therefore be classified as a customer for all intents and purposes of this Privacy Policy. When you use Centbee Services, we ask you to provide information related to that transaction, including such information as the amount of the transaction, the type of transaction and payment information. Also, when you send BSV to another Centbee user, you may be asked to provide personal details of that customer to complete the transaction and your details may also be passed on to us from that customer. We retain this information for each of your transactions through the Centbee Services and may add this information to your account profile to be used for future transactions that you may make with us. We also collect the Internet address (IP address) and other identifying information about the computer or device you use to create or access your Centbee account or use the Centbee Services, in order to help detect possible instances of unauthorised or fraudulent transactions. Furthermore, Centbee may transfer your data across national borders, including to jurisdictions where data protection and privacy laws may not exist.

4. INFORMATION ABOUT YOU FROM THIRD PARTIES

In order to protect our customers against potential fraud, we verify the information you provide with identity verification services, payment processors and/or credit reference and fraud agencies. In the course of such verification, we may receive personally identifiable information about you from such services. In particular, if you use a credit card or debit card with Centbee, we will use card authorization and fraud screening services to verify that your card information and address match the information you supplied to Centbee, and that the card has not been reported as lost or stolen. If you send or receive high overall payment volumes through the Centbee Services, in some circumstances we are required to conduct a background check on you by obtaining information about you from a credit reference or fraud agency. If you owe us money, we may conduct a credit check on you by obtaining additional information about you from a credit reference or fraud agency, to the extent permitted by law. Centbee, at its sole discretion, reserves the right to periodically retrieve and review a consumer credit report supplied by such credit reference or fraud agency for any account, and reserves the right to close an account based on information obtained during this credit review process.

5. ADDITIONAL VERIFICATION

If we cannot verify the information that you provide, we may ask you to send us additional information (such as your driving license, credit card statement and/or a recent utility bill, or other information linking you to the applicable address), or to answer additional questions online to help verify your information. If you want to change your details or you have recently moved, we will need additional documentation from you.

6. WEBSITE TRAFFIC INFORMATION

Because of the way Internet communication standards work, when you arrive at or leave the Centbee website, we automatically receive the web address of the site that you came from or are going to. We also collect information on which pages of our website you visit, IP addresses, the type of browser and operating system you use and the times you access our website. We use this information to try to understand our customers’ preferences better and to manage the load on our servers, so as to improve the Centbee Services.

Customer Service Correspondence: If you send us correspondence, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from Centbee to you. We retain these records in order to keep records of our relationship, to measure and improve our customer service, and to investigate potential fraud and violations of our Terms of Service. We retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. You may use our telephone number to contact us for support or assistance with our services. From time to time, we may contact you by telephone for support purposes. If we correspond by telephone, we will typically request certain personal information from you, such as your date of birth, address and email address, in order for us to confirm your identity.

7. NON-USER RECIPIENTS AND REQUEST

When a Centbee user either sends a payment to, or requests a payment from, an individual who is not a registered member of Centbee, we will retain the information that the member submits to us for the benefit of the member who is attempting to contact the non-member, so that the member can see a complete record of his or her transactions, including uncompleted transactions. Although this information is retained, we will not market to the non-member in any way at any time using this information.

8. PERSONAL DATA OF FRIENDS

You may be interested in inviting your friends or contacts to join Centbee. In the event you wish to use Centbee’s referral service, you will provide contact information about these friends or contacts. This information will only be used for the purposes of automatically generating a message to these potential Centbee users. By entering your friend’s contact details you are confirming that your friend has consented to the supply of their details and that you consent to Centbee identifying you as the person who has made the referral in the invitation sent to your friend and including your name and details in such invitation. You may request to remove this third-party information by emailing us at info@centbee.com.

9. HOW DO WE USE AND DISCLOSE YOUR INFORMATION AND FOR WHAT PURPOSES?

Our primary purpose in collecting information is to provide you with a safe, smooth, efficient, and customized experience.

Internal Uses: We collect, store and process your personal information on servers located in various jurisdictions where Centbee facilities are located. Centbee collects and uses, or has third party service providers acting on Centbee’s behalf collecting and using, personal data relating to you, as permitted or necessary for the following purposes:

• Provide the Centbee Services and members services you request including without limitation processing transactions and communicating with you about your transactions;
• Verify your identity and the information provided to us;
• Resolve disputes, collect fees, and troubleshoot problems;
• Inform you about service updates and faults;
• Investigate and prevent potentially prohibited or illegal activities, and enforce our Terms of Service;
• Customise, measure, and improve our services and the content and layout of our website;
• Deliver targeted marketing and advertising, service updates, and promotional offers based on the communications preferences you have defined for your Centbee account;
• To improve our search functionality and help you find contacts more easily;
• Compare information for accuracy, and verify it with third parties;
• For our internal purposes, to associate relationships amongst our users through such attributes as address, phone number or device information, for example where more than one Centbee account is set up under one household or last name;
• Protect your and Centbee’s interests, including in particular to enforce our Terms of Service and investigate, prevent and fight against fraud; and
• Comply with legal and regulatory requirements, Disclosure to Other Centbee Customers If you are a registered Centbee user, your name will be visible to other Centbee users who search for you.

Your payment card number, bank account and other financial information will never be revealed to or be visible to other Centbee users, including anyone who you have paid or who has paid you through the Centbee Services or third parties that use Centbee Services, except with your express permission or if we are required to do so pursuant to payment card rules, a court order or other legal process. By accepting this Privacy Policy, you expressly agree and consent that each time you use your Centbee account for transactional purposes, Centbee may transfer the aforementioned relevant data to such Centbee customer in order to process, execute or otherwise deal and provide information about the payment.

When registering with Centbee, we create a BSV address for you, and store that address on our servers. Such addresses and all transactions on them are intrinsically public-domain, and by processing BSV transactions on these addresses you consent to that information becoming public. Centbee will never disclose your cryptographic keys or PIN associated with those addresses.

Disclosure to Third Parties: Other Than Centbee Users Centbee will not sell or rent any of your personal information to third parties for their marketing purposes, and will only disclose this information in the limited circumstances and for the purposes described in this Policy. In certain situations, Centbee may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements. Specifically, you consent to and direct Centbee (and third party service providers acting strictly on Centbee’s behalf) to do any and all of the following:

Disclose information including, without limitation, transaction information, account information, personal information and the contents of communications to: the police; security forces; competent governmental, intergovernmental or supranational bodies; competent agencies (other than tax related authorities), departments, regulatory authorities, self-regulatory authorities or organizations; and other third parties that we in good faith believe it is appropriate for us to cooperate with in investigations of fraud or other illegal activity or potential illegal activity, or to conduct investigations of violations of our Terms of Service (including without limitation, your funding source or credit or debit card provider). If you provide false or inaccurate information and fraud is identified, we may pass details to fraud prevention agencies and law enforcement agencies may access and use that information. We and other organizations may also access and use this information (including information from other countries) to prevent fraud and money laundering. ;

• Disclose information in response to the requirements of the payment card associations or a civil or criminal legal process.
• Disclose necessary information to the payment processors, banks, payment card associations, or other service providers necessary to provide the Centbee Services you request (these third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information was shared).
• Disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian legally appointed for you).
• Disclose aggregated statistical data with our business partners. For example, we may disclose that a specific percentage of our users live in particular geographies. However, this aggregated information is not tied to personal information.
• As with any other business, it is possible that in the future Centbee could merge with, or be acquired by, another company. If such an acquisition occurs, you consent to the successor company having access to the information maintained by Centbee, including customer account information, and such successor company would continue to be bound by this Privacy Policy unless and until it is amended. You will be notified via email and/or a prominent notice on our website of any material change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

10. WHAT ARE COOKIES AND HOW DO WE USE THEM?

Centbee and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. We use analytics software to allow us to better understand the functionality of our software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile app. You are free to decline our cookies if your browser permits, but doing so may interfere with your use of our website. We may also collect information about your computer or other access device to mitigate risk and for fraud prevention purposes.

Centbee uses its own cookies for a variety of purposes, including to:

• Recognize you when you sign in and understand how you arrived at our website, so we can make sure that we provide you with relevant customer content and information;
• Recognize your time zone so that your transaction histories and other account information are accurately displayed;
• Present customized content, if, for example, your cookie was set a long time ago, we know you are not a new user and we will not show you content intended for new users, such as ‘how to use Centbee’ pages;
• Remember your chosen preferences, such as the language you choose to see our website in or default currencies;
• Fight against fraud;
• Inform Centbee about the version of the Centbee software client you are using so that we can provide you with new software updates and direct you to the relevant help sections;
• Enable you to access your account and account services through the Centbee software client;
• Provide internal and customer analytics and gain statistics and metrics about our websites, such as total number of visitors and page views;
• Monitor the effectiveness and performance of our advertising and marketing campaigns and carry out research in order to help us to improve our products and websites;
• Initiate security measures such as ‘time-out’ when you have not logged into your account service area for a period of time; and
• Populate your Centbee client with one of your Centbee contacts’ information, where this contact invited you to join Centbee.

11. HOW LONG IS YOUR INFORMATION RETAINED?

Centbee will retain your information (including geo-location data) for as long as is reasonably necessary to: (1) fulfil any of its intended purposes (as described in this Privacy Policy) or (2) comply with applicable legislation, regulatory requests and relevant orders from competent courts or our regulators.

12. HOW DOES CENTBEE PROTECT YOUR INFORMATION?

Centbee is committed to handling your customer information with high standards of information security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfil their job responsibilities. Centbee will take appropriate organizational and technical measures to protect the personal data and traffic data provided to it or collected by it with due observance of the applicable obligations and exceptions under the relevant legislation. We encrypt all transmission of information using secure socket layer technology (SSL). Your personal and traffic data can only be accessed by authorized employees of Centbee or its affiliates, subsidiaries or service providers who need to have access to this data in order to be able to fulfil their given duties. The security of your Centbee account also relies on your protection of your Centbee PIN. Do not share your Centbee PIN with anyone. Centbee representatives will never ask you for your PIN, so any email or other communication requesting your PIN should be treated as unauthorised and suspicious and forwarded to info@centbee.com. If you do share your Centbee PIN with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your PIN. If you believe someone else has obtained access to your PIN, please change it immediately by logging in to your account and changing your PIN and also contact us right away as described below.

13. ACCESSING OR CHANGING YOUR INFORMATION

You can review the personal information you provided us and make any desired changes or deletions to such information, or to the settings for your Centbee account, at any time by logging in to your account on the Centbee website and changing your preferences or by contacting our support help@Centbee.com. Upon request, Centbee will provide you with information about whether we hold any of your personal information. You have a right to ask for a copy of your information and to ask us to correct any inaccuracies in your personal information or delete your personal information. A fee may be charged depending on the work required to obtain and provide the requested access. We will respond to your request within a reasonable time frame. If you choose to close your Centbee account, you will need to contact Centbee to request this closure. We will mark your account in our database as “Closed,” but will keep your account information in our database for as long as reasonably necessary to comply with our legal and regulatory requirements. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required by law. If you wish to subscribe to our newsletter(s) or marketing communications we will use your name and email address to send communication to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at help@Centbee.com.

14. POLICY ACCOUNTABILITY

Centbee is responsible for ensuring that our day-to-day procedures comply with this Privacy Policy. If you want to exercise your right to access your information or have any questions about this policy, Centbee’s information practices, or your dealings with Centbee, you can contact us by emailing info@centbee.com.

15. THIRD PARTY SITES

Our site includes links to other websites whose privacy practices may differ from those of Centbee. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

16. POLICY UPDATES AND NOTIFICATIONS

All future changes to this Privacy Policy as already published on the Centbee website(s) and application at the time you register for the Services are incorporated by reference into this Privacy Policy. We may amend this Privacy Policy at any time by posting a revised version on our website. The revised version will be effective at the time we post it. If you disagree with the terms of this Privacy Policy, you may close your account at any time.

You can contact us by email: info@centbee.com.