This Privacy Policy contractually regulates our right to collect and use certain information of yours and your rights in this regard. Please read this policy carefully before using our Website or any other service that forms part of the Thumbzup Platform.

Thumbzup is committed to taking steps to protect your privacy when you use our Website or the Thumbzup Platform and implementing business practices that comply with all relevant legislation, including the Protection of Personal Information Act 4 of 2013 (“POPI”). In this policy, we explain how we will use and protect your personal information.

1. Definitions:

In this policy, unless a contrary intention clearly appears, the following terms shall bear the meanings assigned to them and similar expressions shall have corresponding meanings:

1.1       “Thumbzup” means Thumbzup Innovations (Pty) Ltd, a company duly registered and incorporated with limited liability under the company laws of the Republic of South Africa under registration number 2011/100818/07 and having its principal place of business at Building A, Trentbridge Office Park, cnr Leonie str & Von Willich Ave, Doringkloof, Centurion 0157, Republic of South Africa;

1.2. “Thumbzup Payment Devices” means all models of the Payment Blade, Payment Pebble^® card reader or SUNMI range of payment devices made available by Thumbzup;

1.3. “Thumbzup Platform” means any or all of the following:

• • A Thumbzup payment device as defined in 1.2,
  • The Thumbzup Merchant Portal or Retail Portal
  • The Thumbzup mobile application suite including the Launcher, Updater and/or Thumbzup Pay app;
  • The Thumbzup Companion API
  • All related Thumbzup backend servers

1.4       “Thumbzup Transaction” means a sale, refund or authentication transaction initiated by a Registered Merchant, or a Registered Merchant’s customer on the Thumbzup Platform and processed via the Thumbzup Platform.

1.5       “Registered Merchant” means a company that has signed a Master Service Agreement with Thumbzup to process transactions on the Thumbzup platform

1.6       “Website” means the website at www.thumbzup.com, including all associated subdomains owned and operated by Thumbzup;

1.7       “You” means any person who browses the Website and also means any Registered Merchant.

2. What information do we collect from you?

Thumbzup will collect certain personal information about you, including both identifiable and non-identifiable personal data. Identifiable personal and business data is collected when you apply to become a Registered Merchant, while you are a Registered Merchant when performing any transaction on the Thumbzup Platform, when performing any other transaction with Thumbzup or when you communicate with Thumbzup. This may include information such as company registration information, bank account details, tax information, identity documents, and so on.

Non-identifiable information is gathered automatically when you visit or use the Website. This may include the type of device you used to access the Website, your operating system, your IP address, your browser type and the pages you view on the Website. Thumbzup may also combine the information we collect from you with information we obtain about you from our business associates and other third-party partners.

In some instances, we collect and store information about your location. We convert your IP address or mobile GPS data into a rough geo-location. We may use location information to improve and personalise our services for you. We also record where you are when you accept payments using our services.

3. What information do we collect from your customers?

Thumbzup will collect certain personal information from Registered Merchant’s customers when they are performing a Thumbzup Transaction on the Thumbzup Platform. This includes data manually entered such as their email address or mobile number and their cardholder PIN, as well as card data automatically obtained when the customer presents their card. This information is afforded the same protections as our card processing facilities.

The Thumbzup Platform is certified at PCI DSS Level 1, and the Thumbzup payment devices are PCI P2PE and PCI PTS certified. These certifications cover both logical and physical security to protect the cardholder PIN and sensitive information such as the card PAN. The platform undergoes regular security compliance audits to maintain these certification statuses. A multitude of technical and organisational measures based on best practice and compliance frameworks are in place to ensure personal information is protected from loss, theft, misuse and unauthorized access.

Thumbzup will only store your customer’s personal information as long as it is necessary to provide our services and to comply with applicable laws and regulations. When it is no longer necessary to retain personal information it is erased.

4. Why do we collect information?

Thumbzup collects you and your customer’s information so that we can provide our services to you and so that we have the necessary information to be able to process payments in an efficient, secure, correct and legal manner, meeting regulatory requirements.

In addition, we collect information so that our Support team can respond to merchant inquiries and help diagnose service problems. Some information is also used for research purposes to develop and improve the Thumbzup Platform in the form of new features, performance enhancements and usability improvements.

Information is also collected to protect the security and safety of the Thumbzup Platform, our Registered Merchants and the security of your customers, in the form of fraud detection.

In some cases, we are required by law to collect personal information about our Registered Merchants. Except where the law requires otherwise, we will protect the confidentiality of such data.

5. How will we use your information?

Thumbzup respects your privacy. We will protect the confidentiality of your personal information supplied in the course of contracting with Thumbzup. Thumbzup will not sell your personal information to third parties for commercial or marketing purposes.

Thumbzup may log your visits to and use of the Website and collect IP addresses and information about your operating system and the type of browser you use for the purposes of network/system administration and to audit the use of the Website.  This data will not be used to identify individual users.

Any information which Thumbzup collects from you through our communications will be used to address the matters referred to in those communications.  If this requires referring such communications to a third-party business partner to ensure customer service, your personal information will only be disclosed to the point necessary to address your query or concerns, and will otherwise be kept confidential.

6. What happens to information disclosed on Thumbzup’s social media?

Any information that you disclose in a public space on Thumbzup’s social media platforms is available to anyone else who visits that space. Thumbzup cannot safeguard any information you disclose there.

7. What happens to my information when I visit third party links?

The Website contains links to sites that belong to third parties unrelated to Thumbzup. These links are provided for convenience only and Thumbzup does not endorse these sites or the third parties.  Thumbzup has no control over and takes no responsibility for your use of or for any information you submit to or over these third party sites.  You access and use third party sites at your own risk. Thumbzup cannot be held responsible for any use of your personal information arising from you disclosing personal information on third party sites.

8. Thumbzup reservation of rights

Thumbzup reserves the right to:

• Disclose information about you where required in good faith, to do so by law or to exercise Thumbzup’s legal rights or defend Thumbzup against legal claims;
• Share your information with law enforcement to investigate or prevent illegal activities being committed over Thumbzup’s network;
• Disclose your information where you have given us explicit consent to do so;
• Monitor user and network traffic for site security purposes and prevent any unauthorized attempts to tamper with the website or to cause damage to the Thumbzup platform.
• Change the terms of this policy from time to time in line with any changes that the law or our internal business operations require, without prior notice. The current version of this policy that applies at the time you visit our Website and/or use the Thumbzup Platform will regulate our relationship. It is your responsibility to consider the policy each time you use the Thumbzup Platform.