Privacy Statement
Mamoru South Africa (Pty) Ltd (“Company”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal information.
This Privacy Statement has been developed to enable you as our customer to understand how we collect and process your personal information and how we will look after your personal information when you access the website and/or use our Services (regardless of where you access it). It explains your privacy rights and how the law protects you.
We strive to create the most secure infrastructure to allow you to use our website and Services. It is our aim to prioritise our security safeguards to ensure that your personal information is protected in an appropriate manner and is used for a legitimate purpose. We will take appropriate and reasonable technical and organisational steps to protect your personal information in line with industry best practices.
Acceptance
You must accept all the terms of this Privacy Statement when you access the website and when using our Services. By accessing our website and using our Services, you are deemed to have read, understood, accepted, and agreed to be bound by all the terms incorporated in this Privacy policy.
You further confirm that you are 18 years or older at the time of accessing and using our Services. If you are younger than 18 years, you may not use our Services.
1. Who we are?
Mamoru South Africa (Pty) Ltd is a company registered in South Africa and provides crypto asset services and is licensed with the Financial Sector Conduct Authority as a licensed financial services provider.
This Privacy Statement aims to address the privacy issues. Mamoru is the company that will be responsible for collecting and/or processing your personal information when you use our trading platform through the website or when using our services. (hereinafter referred to as the Services). We will respect your privacy, and we are therefore committed to protecting your personal information when we collect, use, or access your information for purposes of rendering our Services to our customers.
We will take appropriate actions to implement advanced data protection measures to ensure that your information is safeguarded.
2. The sharing of your personal information
We will not disclose your personal information to third parties without your written consent unless the disclosure of your personal information is required in terms of the law (i.e., a court order) or requested by any regulatory authority or such disclosure is in the public interest or for a legitimate purpose. We may also disclose your personal information in order to protect our legitimate interests in exercising our rights or the protection of our reputation and property.
Your information will only be processed by our employees, but we may need to disclose personal information to our employees or independent contractors who require it for performing their roles.
3. Personal information usage
We may only collect, process, use, store and transfer different kinds of information about you at the start of, and for the duration of your relationship with us with your consent, for legitimate purposes or in situations where it is in our legitimate interest, and which will not cause you undue prejudice.
Personal information refers to any information that identifies you as our customer and shall not be limited to:
| Item | Description |
|---|---|
| Identification information | First and last names, identity number or passport number. |
| Contact information | Postal or physical address, email address and telephone numbers. |
| Financial Data | Cryptocurrency asset addresses or any other related address. |
| Transaction Data | Details of transactions performed by you, details about payments, withdrawals, exchanges, trading history, profit, balance, deposits and withdrawals amount methods or any other details relating to the Services rendered through the website. |
| Technical Data | Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in-type and versions, operating system and platform and other technologies on the devices you use to access the website and use of “cookies” stored on your device(s). Please see our Cookies Policy for more information. |
| Profile Data | Your account details, username and passwords, transactions made by you, your interests, preferences, feedback and/or information received through your interaction with us within the course of providing our Services and survey responses. |
| Usage Data | Information about how you use the website, products and Services, registration date, account category, trading cluster, number of complaints, number of requests filed and IP history. |
| Marketing and communication Data | Your preferences in receiving marketing from us and your communication preferences. |
| Special categories of data or sensitive Data | Criminal convictions and offences. |
| Conformity Data | Details about your education, employment status, trading experience, self-assessment test. |
| Banking Data | Details of number of payment wallets and/or information of your bank card, including information of the issuing bank, card number, cardholder name, card expiration date, payment system, card validation code (CVV2/CVC2), and photos of both sides of the bank card. |
| Know your customer Data | Identity document information, including your recent utility bills, identity book or card, passport. |
| Economic profile Data | Details on your income, source wealth, source of income, source of funds, net profit, expected annual amount of investment. |
| Location Data | Details of your actual location when we interact with you on the website (for example, a set of parameters that determines regional settings of your interface, namely residency country, time zone and the interface language). |
| Audio Data | Full voice recordings of calls that you receive from us or make to us. |
4. Accuracy of your personal information
We will try to ensure that the information we collect from you is accurate, complete, and up to date. From time to time, we may request that you update your personal information on the website or by contacting us directly. You may also review your information and update it from time to time. Please note that it is your responsibility to ensure that your personal information is accurate and up to date.
5. Storage of your personal information
We will retain your personal information for as long as:
- you are a customer of the Company;
- to comply with the retention requirements imposed by any law;
- a contract between you and the Company requires us to keep it;
- you have consented to the Company keeping it;
- the company requires it for statistical or research purposes.
TAKE NOTE: The Company may keep your personal information even if you no longer have a relationship with the Company if the law permits or requires.
6. Your rights
6.1 Right to notification: You have the right to be notified that personal information about you is being collected or that it has been accessed or acquired by an authorised person.
6.2 Right to access: You have the right to request access to the personal information we have about you by contacting us. This includes requesting: confirmation that we hold your personal information or description of the record containing your personal information and the identity or categories of third parties who have had access to your personal information.
6.3 Right to correction, deletion or destruction: You have the right to request us to correct, delete or destroy the personal information we have about you if it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully, or if we are no longer authorised to keep it. We will take reasonable steps to determine if the personal information is correct and make any correction needed. It may take a reasonable time for the change to reflect on our website or platform/systems. If the law requires us to keep your personal information, it will not be deleted or destroyed upon your request. The deletion or destruction of certain personal information may lead to the termination of a business relationship with us. Please refer to our PAIA Manual for further information in this regard, such as the process you should follow to give effect to this right. It may take up to 15 business days for the change to reflect on our systems. We may request documents from you to verify the change in personal information.
6.4 Right to objection: You may object on reasonable grounds to the processing of your personal information where the processing is in your legitimate interest, our legitimate interest or in the legitimate interest of another party. We will not be able to give effect to your objection if the processing of your personal information was and is permitted by law, you have provided consent to the processing and our processing was conducted in line with your consent; or the processing is necessary to provide our Services to you. We will also not be able to give effect to your objection if the objection is not based upon reasonable grounds and substantiated with appropriate evidence. You must inform us of any objection in writing. Please refer to our PAIA Manual for further information in this regard, such as the process you should follow to give effect to this right.
6.5 Right to withdraw consent: Where you have provided your consent for the processing of your personal information, you may withdraw your consent. If you withdraw your consent, we will explain the consequences of such withdrawal. If you withdraw your consent, we may not be able to provide our Services to you. We may proceed to process your personal information, even if you have withdrawn your consent, if the law permits or requires it. It may take up to 15 business days for the change to reflect on our systems. During this time, we may still process your personal information.
6.6 Right to complain: You have the right to file a complaint with us or any regulator with jurisdiction (in South Africa, you can contact the Information Regulator) about an alleged contravention of the protection of your personal information. We will address your complaint as far as possible.
7. Your duties
You must provide proof of identity when enforcing the rights above.
You must inform us when your personal information changes.
Please refer to the Company’s Promotion of Access to Information Act 2 of 2000 Manual (PAIA Manual) for further information on how you can give effect to the rights listed above. The PAIA Manual is located on the Company’s website.
8. Processing of personal information about persons related to juristic persons
If our customer is a juristic or legal person, we may collect and use personal information relating to the juristic or legal person’s directors, officers, employees, beneficial owners, partners, shareholders, members, authorised signatories, representatives, agents and other persons related to the juristic or legal person. These are related persons. If personal information of a related person is provided to us, you warrant that the related person is aware that they are sharing their personal information with us, and that the related person has consented thereto. We will process the personal information of related persons as stated in this privacy policy, thus references to “customer/s” in this privacy policy will include related persons with the necessary amendments.
9. Transferring of your information to other countries?
Where applicable, the Company will only transfer your personal information to third parties in another country in any one or more of the following circumstances:
- where your personal information will be adequately protected under the other country’s laws or an agreement with the third-party recipient;
- where the transfer is necessary to enter into, or perform, under a contract with you or a contract with a third party that is in your interest;
- where you have consented to the transfer; and/or
- where it is not reasonably practical to obtain your consent, the transfer is in your interest.
This transfer will happen within the requirements and safeguards of the law. Where possible, the party processing your personal information in the other country will agree to apply the same level of protection as available by law in your country, or if the other country’s laws provide better protection, the other country’s laws would be agreed to and applied.