API Gateway Privacy Policy

Telenor Microfinance Bank Limited (“Telenor Bank”, “we”, “our” or “us”) value and respect your privacy and any information provided by you to us. Therefore, we are committed to safeguarding the privacy of all those who use the API Gateway. This policy sets out how we collect and will treat your information. Please contact us at complaints@telenorbank.pk if you have any questions.

This policy reflects Telenor's group wide Privacy position and aims to provide you with adequate information in order for you to understand your privacy rights that you can make use of including but not limited to the right to withdraw your consent for us to use or share your information, unless that information is required to provide you with our services. By accepting the Privacy Policy and the Terms & Conditions during registration, you expressly consent to our collection handling, storage, use and disclosure of your personal information as described in this Privacy Policy. You can contact us at any point in time to discuss your privacy rights.

We will collect and process your information in accordance with all Applicable Laws including but not limited to all Data Protection laws which include but are not limited to privacy obligations in the Banking Companies Ordinance 1962,  the Microfinance Institutions Ordinance 2001 and  Branchless Banking Regulations, as well as any regulations promulgated By the State Bank of Pakistan from time to time.

Personal Information Collection

When you use the API Gateway, we collect and store your information as provided by you. Our primary goal isto provide you a safe, efficient, smooth and customized experience as well as to protect your rights and interests. This allows us to provide relevant products and improve our services that are most likely to meet your needs, and to customize the website to make your experience safer and easier. We only collect information about and related to you that we consider necessary for achieving this purpose.

Once you give us your information, you are not anonymous to us. If you choose to provide us with personal information, you consent to the transfer and storage of that information on our servers located anywhere inside Pakistan under the custody of Telenor Microfinance Bank or its authorized partners/vendor/supplier/service provider.

We may collect and store the following information:

  • Name, Address, Contact Numbers, Email id, Physical Contact Information, and sometimes Financial Information (depending on the service used) such as credit card, credit card or bank account numbers also if you register as a user, subscribe to any service, upload or submit any material on API Gateway, request any information, or enter into any competition or promotion we may sponsor;
  • in connection with an account sign-in facility, your log-in and password details;
  • demographic information (e.g., date of birth, gender, geographic area, and preferences)
  • Information on how you use API Gateway(such as the login device, date, time, location etc.), and any other information collected in relation to your use of the API Gateway.
  • If you send us personal correspondence such as emails or if other users or third parties send us correspondence about your activities or postings on the API Gateway, we may collect such information into a file specific to you;
  • communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the API Gateway or its content;
  •  Information from your interaction with our API Gateway, content and advertising, including computer and connection information, browsing history and length of visit, statistics on page views, traffic to and from the site, IP address and standard web log information;
  • Additional information we ask you to submit to authenticate yourself or if we believe you are violating policies (for example, we may ask you to verify your address, or to answer additional questions to help verify your identity or ownership);
  • Your official/work address, parents and spouse information etc.
  • Information from our partner companies, such as demographics and navigation data.

Personal Information does not include aggregated or anonymized information that may be derived by your use of the API Gateway. We may use and disclose aggregate information, and other non-personally identifiable information, for various purposes at our sole discretion and without notice or liability to you. Such de-identified and/or aggregated information will be deemed to be owned by us and we shall have unrestricted title, rights, and interest to the de-identified and/or aggregated information which may include, without limitation, the right to use, distribute, transmit, transfer, license, trade, rent, share, assign, and sell the de-identified and/or aggregated information.

Use of Personal Information:

We do not sell or rent your personal information to third parties for marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize our services, to better understand your interests and the interests of the development community as a whole.

Use:

Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customized experience. We may use your personal information to:

  • Administer the website
  • Administer your account with us
  • Provide the services and customer support you request
  • Resolve disputes or any troubleshoot problems;.
  • Customize your experience;
  • Prevent potentially prohibited or illegal activities, and enforce our Terms & Conditions;
  • Customize, measure and improve our services, content and use of the API Gateway;
  • Inform you about new and existing products, services, and updates;
  • Examine your personal information to identify users using multiple User IDs or aliases and delete/bar the unauthenticated User IDs.
  • Audit the downloading of data from the API Gateway

Our Disclosure of Your Information

We limit access to your personal information within Telenor Microfinance Bank to individuals with a need to know.

If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice if a security breach occurs

We may disclose personal information to respond to legal requirements, enforce our policies, respond to claims that a listing or other content violates the rights of others, or protect anyone's rights, property, or safety. Such information will be disclosed in accordance with applicable laws and regulations of the Country. We may also share your personal information with:

Relevant Members, Partners, Vendors, (like, our service providers managing the API Gateway, customer support, payment service providers), to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about products, services and communications.

Service providers under contract who help with our business operations ,data processors who process your data on our behalf as well as relevant third parties whom you consented service providers, dealers, agents or any other associate company for reasonable commercial purposes;

Other third parties to whom you explicitly provide information to while using our services (or about whom you are otherwise explicitly notified and consent to when using a specific service such as online payments).

Law enforcement or other governmental officials, in response to a verified request relating to a criminal investigation or alleged illegal activity. In such events, we will disclose information relevant to the investigation.

In accordance with applicable laws, regulations and court orders, with relevant authorities where we are required to cooperate for legal purposes.

Other business entities, should we plan to merge with or be acquired by that business entity. (Should such a combination occur, we shall require that the new combined entity follow this privacy policy with respect to your personal information).

Information You Share

Your feedback, ratings and associated comments may be displayed and shared with internal teams for the enhancement of the product or service and for the in-depth understanding of the teams with regards to consumer perspectives.

Account Protection

Your login information Client ID and Client Secret (“login information”) are the key to your Account. Use unique numbers, letters and special characters, and do not disclose your login information to anyone. If you do share your login information or your personal information with others, remember that YOU, yourself are responsible for all actions taken in the name of or by misusing your account. If you lose control of your login information, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf. Therefore, if your login information is compromised for any reason, you should immediately notify Telenor Microfinance Bank  at complaints@telenorbank.pk.

Your Decisions About Your Personal Information

At any time you can contact us to: stop receiving emails from us; review the personal information held by us in connection with your account; withdraw any consents you previously provided for our use and disclosure of your information; close your account; and amend your personal information.

Generally, you may withdraw at any time your previously-given consents for us to collect, use, and disclose your information in accordance with this Policy, subject to legal or contractual restrictions and reasonable notice. We may however continue to collect, use, and disclose your information as may be required to provide you access to the API Gateway, and to the extent that we are contractually obligated to do so or as necessary to enforce any contractual obligations you may have with us.

Security:

Your information is stored on our servers at a secure location of Telenor Microfinance Bank inside Pakistan. We treat data as an asset that must be protected using sophisticated tools (encryption, passwords, physical security, etc.) to protect your personal information against any kind of unauthorized access and disclosure.

We commit to reviewing and revising the privacy requirements as and when the need so arises.  If you have any concerns regarding the above please contact us at the e mail address provided above.

You should bear in mind that submission of information over the internet is never entirely secure. It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal information if you use a shared computer or a computer in a public place.