Introduction

At SPENN, we are deeply committed to respecting the privacy of our customers. We ensure that your data is safe by using sophisticated security measures. In this document, we set out what data we may collect from you and explain how we use it in the provision of our services to you.

By creating an account in the SPENN Application or Platform (“SPENN App” or “SPENN Platform”) and accepting the Terms & Conditions, you consent to SPENN collecting and storing your data necessary to provide you with the services of your choice. This Privacy Policy (the “Policy”) governs the collection, storage, and processing of your data.

This Policy applies to your use of all our services and products. Your personal information is kept in our business records only for as long as it is needed to provide you with our services, and afterwards, only as it is required for tax or other legal obligations.

We reserve the right to update this Policy from time to time. In case our Privacy Policy is updated, we will notify you.

Scope

The Policy applies to all SPENN Platform Users and SPENN Customers; it covers all matters related to how we collect, use, share, and protect your data. All partners with whom we share your information must meet the requirements set out in this Policy. We explain how we share data in further sections of this document.

Collecting Information

To deliver our services, we may collect your personal information, such as your name, address, personal number, telephone number, and email address that you provide to us while creating your SPENN Account. We also collect your IP address, information about the device you use the SPENN Platform on, your location, and other data to indicate your user behavior. For identity verification purposes, you may be asked to take a photograph of your face (selfie); however, this data is processed entirely locally, and any spatial orientation/facial expression data is not collected externally by us, nor is it submitted to any partner or third parties.

Most of the information listed above and any other information that you provide us with can be accessed via your SPENN Account by clicking the “Me” tab.

We collect this information when you download the SPENN App, during the registration process, when you subscribe to our newsletter, or from public sources. To comply with local laws, we may need to access some of your personal data from public sources, such as National Identification Authorities or Credit Reference Bureaus, depending on your country of residence. By using the SPENN App or Platform and its associated services, you expressly agree to such access.

The Controller of your data, that is, the entity that decides how your data is used, is:

SPENN AS, a Norwegian registered limited company, with company number 915 912 028, registered office address: Andoyfaret 15, 4623 Kristiansand, Norway. SPENN AS is the owner of the source code and all intellectual property rights of the SPENN App that you download to your mobile phone.

If you have any questions regarding this Privacy Policy or our processing of personal data, please contact [email protected].

Why We Collect This Information

The reason we collect this information is to enable you to use our services and improve your user experience. Thanks to this data, we can comply with all the relevant legal requirements that govern our relationship with you, as well as customize our services to match your needs, respond to your questions, and ensure the safety of all our customers and the integrity of our products.

We collect and process your data to:

• Provide you with the online services of your choice, including sending and receiving funds.
• Ensure that transactions are performed smoothly and provide troubleshooting services.
• Process transactions and maintain records of sales (for SPENN Merchants and Business users).
• Respond to your questions and requests or contact you regarding the services that we provide.

Additionally, we are required to collect and store your data, including your transaction data, for security reasons, in accordance with the Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) laws in force in Zambia.

We also process your transaction data under our legitimate interest, especially to:

• Ensure the security of our services, adhere to our internal procedures, and prevent fraud.
• Analyze the functionality of our services and the SPENN App and/or Platform and tailor them to your needs.
• Resolve customer queries, particularly those sent to our Customer Service Teams (CS Team).
• Perform statistical analyses.
• Ensure compliance with local and global laws and regulations.
• Store data for archiving and auditing purposes.

With your consent, we may retrieve information from cookies and other tracking technologies to assist with user navigation, analyze your use of our products and services, assist with our promotional and marketing efforts, and provide content from third parties.

Your Rights Regarding Your Data

You have the right to:

• Access and correct your data.
• Withdraw your consent to data processing, which may limit your ability to use the SPENN App and Platform.
• Request data portability or deletion where applicable.
• Object to automated decision-making.
• Restrict further data processing.
• File a complaint with the Norwegian Data Protection Authority (Datatilsynet) if you believe your data rights have been violated.

Sharing Information

We do not sell your personal information. We share your information only with companies that assist us in performing services for you, such as consulting and auditing, and we require full compliance with our Privacy Policy. Some of these companies may be located outside your jurisdiction, and local authorities may have access to your data.

We may also release your personal information if required to comply with legal requirements, court orders, or to defend our or others’ legal rights.

Anonymous, non-personally identifiable information may be shared with third parties for marketing or advertising purposes, but only if we receive your consent.

Your personal information may also be shared due to an acquisition, merger, receivership, insolvency, or bankruptcy proceedings we may undergo as a company.

Your name will be visible to other customers who enter your phone number as a recipient of a transfer/request for transfer. This ensures that our customers send funds to the correct person, as our transactions are non-reversible.

Safety of Information

We have implemented internal security policies and technical measures to protect your data against loss, unauthorized disclosure, or access.

The history of your transactions is secured by blockchain technology, providing an indelible and transparent record of transactions.

We store your data as required by Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Know Your Customer (KYC) laws for a minimum of 10 years from the end of the relationship or transaction date.

Links to Other Websites

We may include links to third-party websites that are not covered by this Privacy Policy. Please review their privacy policies separately.

Phishing Warning

Phishing is an illegal practice of creating fake websites that imitate legitimate ones to steal sensitive information. If you suspect a phishing attempt, please contact our Customer Service team.

Communication

We may send you electronic information about your transactions, our products, and agreements between us. You agree to receive such communications electronically. We may also contact you via SMS or phone calls for service-related matters but will not send marketing messages without your prior consent.

You can withdraw your consent to receive marketing communications at any time by contacting us.

Contact Information:
SPENN AS
Andoyfaret 33D,
4623 Kristiansand, Norway
Email: [email protected]