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Privacy Policy

Privacy Policy

1. Introduction and Definitions 

 1.1. This Policy applies to Abreo (referred to as Abreo a Division of Webo (Pty) Ltd, Abreo, the company, we, us or our).
1.1  Abreo is a division of Webo (Pty) Ltd
1.2 Read more about Webo (Pty) Ltd at www.webo.co.za
1.3 Alan Mackenzie is the CEO of Webo (Pty) Ltd
1.4 Webo has been developing international SaaS products since 2004. 
 1.2. The Policy extends to and covers all operations and functions of Abreo. At Abreo, we are committed to ensuring the confidentiality and security of the personal information supplied to us by individuals. The South African POPIA binds Abreo. 
 1.3. The word "individual" refers to a customer, client, trustee or any other person with whom we come into contact. All contractors, sub-contractors, vendors, service providers, customers, agents or any other third parties that have access to personal information collected by Abreo must abide by this Privacy Policy. 
1.4. "Personal information" is information or an opinion relating to an individual, which can be used to identify that individual. "Sensitive information" is personal information that includes information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record. We do not collect sensitive information about you without your consent unless the collection is authorised by law. 
2. What types of personal information do we collect? 
2.1. Our ability to provide individuals with our services is sometimes dependent on us obtaining certain personal information about the individual. If an individual does not provide us with the information we request, we may not be able to provide them with the benefits of our services. 
2.2. Typically, the kind of personal information we collect includes name, date of birth, address, occupation, and contact details. 
2.3. We also collect information about the form of identification used in relation to an individual to send or receive a transaction (required by law in some instances) and information about a transaction, including details of the amounts paid in or out of an individual's account/s and delivery instructions. 
2.4. We may also collect information about: employment details, employment history, family commitments, etc.
2.4.2. the individual's current financial circumstances; 
2.4.3. the individual's foreign exchange preferences and tolerance to risk; and 
2.4.4. other matters that are relevant to the services we provide. 
3. How we collect personal information 
3.1. We collect personal information about individuals: 
3.1.1. directly from applications, questionnaires or forms completed by individuals who wish to use our services; 
3.1.2. from information disclosed to us by an individual on the phone or by sending us correspondence (by letter, fax or email); 
3.1.3. from information disclosed to us by an individual via our website and online trading platform; and 
3.1.4. from third party sources, including our business contacts, credit reporting bodies providing identity verification services, and financial institutions. 
3.2.In some circumstances, we may be provided with personal information about an individual from somebody else, for example, a referral from another person. We will take reasonable steps to ensure that the individual is made aware of the matters set out in this Privacy Policy. We may also occasionally receive unsolicited personal information about individuals. 
3.3.We do not give individuals the option of dealing with us anonymously or under a pseudonym. This is because it is impractical, and in some circumstances illegal, for us to deal with individuals who are not identified. 
4. Why do we collect personal information? 
4.1. Abreo collects personal information for the following purposes: 
4.1.1. to conduct our business of providing for the use of our SaaS and other services in relation to foreign currency arbitrage.
4.1.2. to provide individuals with information about our services and promotions; 
4.1.3. protect our business and other clients from fraudulent or unlawful activity, in accordance with our legal obligations and our legitimate interest; 
4.1.4. to assess applications by individuals in order to provide them with our services to comply with our legal obligations;
 4.1.5. to investigate and resolve any concerns or complaints an individual may have; 
4.1.6. to manage any legal actions involving Abreo; 
4.1.7. to collect and analyse statistical information regarding the number of visitors to our website and our online trading platform in accordance with our legitimate interest; 
4.1.8. to comply with our legal obligations, including our obligations to collect certain information under the relevant laws and regulations; and 4.1.9. to help us manage and enhance our services. 
5. About whom do we collect personal information? 
5.1. The type of information we may collect and hold includes (but is not limited to) personal information about: 
5.2. clients and potential clients; 
5.3.third parties such as service providers; 
5.4. prospective employees; and 
5.5. other people with whom we come into contact. 
6. How might we use and disclose personal information? 
6.1. We may use and disclose personal information for the purposes set out in section 4 above and for reasonably expected secondary purposes which are related to these purposes. We only use and disclose personal information in the circumstances authorised by laws and regulations. Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless the individual agrees otherwise, or otherwise authorised by law. 
6.2. We do not disclose personal information we collect to third parties for the purpose of allowing them to direct market their products and services. We do not use or disclose sensitive information for direct marketing purposes. 
6.3. We may engage third parties to perform services for us which involve the disclosure of personal information to that person. In these situations, we prohibit that person from using personal information about you except for the specific purpose for which we supply it. 
6.4. Where sensitive information is held by us about an individual, wherever possible we will attempt to de-identify the information. We also undertake to delete all personal information about an individual when it is no longer needed or required by law to be kept. We also destroy or de-identify all unsolicited personal information unless we are authorised by law to store it. 
6.5. We may disclose personal information to: 
6.5.1. a related company of Abreo; 
6.5.2. an individual's introducing broker; 
6.5.3. an agent, contractor or service provider we engage to carry out our functions and activities, such as our lawyers, accountants, or counterparties; 
6.5.4. organisations involved in a transfer or sale of all or part of our assets or business; 
6.5.5. organisations involved in managing our payments, payment merchants and other financial institutions such as banks; 
6.5.6. regulatory bodies, government agencies, law enforcement bodies and courts, and 
6.5.7. anyone else to whom the individual authorises us to disclose it, or as required by law. 
7. How do we communicate with you? 
7.1. We may, in accordance with our legitimate interest, send you information by SMS, push notification, email or in-app notification about our products, services and offers we think would be of interest to you. The information we send you will always be in relation to the services or products you have requested from us. 
7.2.If you receive email communications from us about the market or your activity on the Platform, and you don't want to receive them in the future, please use the unsubscribe link within the email, and we will stop sending you this information via email. Alternatively, when you are logged into your account, you can edit or delete your subscriptions, reviews or other information in whole or in part.
7.3. Please note that push notifications may be sent to every device you have logged into your account from. 
8. Sending information overseas 
8.1. We are likely to disclose personal information to related entities, server administrators, programmers and data storage service providers that are located outside South Africa. These recipients are located in the USA (Servers, Site Encryption, Firewalling) and in India (Software Programming & Software Programme maintenance). 
9. Management of personal information 
9.1. We take reasonable steps to protect personal information held from misuse, interference and loss and from unauthorised access, modification or disclosure. For example, by use of physical security and restricted access to electronic records. 
9.2. Personal information is generally held in client files. Information may also be held in a computer database. All paper files are stored in secure areas, and access is limited to authorised persons. Computer-based information is protected through the use of access passwords, and other data security measures. 
9.3. Any personal information collected will not be retained after the closure of an account.
10. Identifiers 
10.1. We will not use identifiers assigned by the Government, such as a tax file number, Medicare number or provider number, for our own file recording purposes. 
11. Direct Marketing 
11.1. We do not use personal information for direct marketing purposes, in accordance with our legitimate interest, unless: 
11.1.1. the personal information does not include sensitive information; 11.1.2. the individual would reasonably expect us to use the information for direct marketing; 
11.1.3. we provide a simple "opt-out" of receiving direct marketing material; and
 11.1.4. the individual has not asked to opt-out of receiving direct marketing material from us. 
11.2. If the individual would not reasonably expect us to use or disclose the information for the purpose of direct marketing, we may only use or disclose that information for direct marketing if the individual has consented. We will also only use sensitive information for direct marketing if the individual has consented. 
11.3. Individuals can request to opt-out of receiving marketing material from us or request that we provide them with the source of their information. We will respond to these requests free of charge within a reasonable time. 
12. Personal Data 
12.1 Obtaining a copy of your personal data and correcting mistakes. We respect your right to access and control your personal data. We will respond to requests for personal data and, where applicable, will correct, amend or delete your personal data. 
12.2. Access to personal data: We will give you access to your personal data (including a copy of the ability for us to send your personal data to another provider) on request unless any relevant legal requirements prevent us from doing so or other exemptions apply. Before providing access to you, we will ask you to prove your identity and give us sufficient information about your interaction with us so that we can locate any relevant data. 
12.3. Correction and deletion: You have the right to correct or amend your personal data if it is inaccurate or requires updating. You may also have the right to request us to delete your personal data. If you request that we delete your personal data this will result in the automatic closure of your account, and we will remove your personal data from active processing. However, we will be required to maintain your personal data to comply with our legal and regulatory requirements as well as in accordance with our internal compliance requirements in relation to maintaining records. 
12.4. Restrict processing: If you would like to control the use of your information for marketing, you should notify us of your requirements.
We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your personal data and any additional copies of the personal data you request from us. 
13. European and UK Representatives 
13.1. We do not have an UK nor a European Representative. 
14. Updates to this Policy 
14.1. This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. 
15. Responsibilities 
15.1. It is the responsibility of management to inform employees and other relevant parties that this Privacy Policy is maintained and enforced. Management must ensure that they periodically advise Abreo's employees and other relevant parties of any changes or any new Privacy Policies in a timely manner. It is the responsibility of all employees and other relevant parties to ensure that they understand and adhere to this Privacy Policy. Ignorance of the existence of the Privacy Policy will not be an acceptable excuse for non-compliance.
16. Privacy Training 
16.1. All new employees must be provided with timely and appropriate access to Abreo Privacy Policy. All employees are provided with opportunities to attend privacy training and must ensure that they understand the privacy-related issues that could adversely affect our clients and us if not properly adhered to. 
17. Non-compliance and disciplinary actions 
17.1 Any Abreo employee or relevant third party identifying, knowing about, or who suspects a Privacy breach must immediately report the matter to the Privacy Officer. Employees or other relevant parties that contravene or do not comply with Abreo's Privacy Policy may be subject to disciplinary action. 
18. Complaints Handling 
18.1. If you have any queries about the contents of this Policy, or wish to inform us of a change or correction to your personal data, would like a copy of the data we collect on you or would like to raise a complaint or comment, please get in touch with us. Suppose you are not satisfied with our response or believe we are not processing your personal data in accordance with the law. In that case, you can escalate your complaint to the Directors of Abreo.
19. Contractual arrangements with third parties 
19.1. We must ensure that all contractual arrangements with third parties adequately address privacy issues. 
19.2. Each third party is aware of and understands this Privacy Policy and has implemented policies in relation to the management of personal information in accordance with the relevant law. 
19.3. The third parties specifically agree only to use personal information for the purposes consented to by Abreo or by the individual concerned. 
20. Privacy Audits 
20.1. Abreo conducts periodic privacy audits in order to ensure that it is continuing to comply with its obligations. 
21. Website 
21.1. By accessing our website or submitting an application to use our SaaS or other products or services, you consent to Abreo collecting, maintaining, using, and disclosing personal information about you and provided by you. 
21.2. When an individual accesses our website, our website uses cookies which allow us to identify the individual's browser. Cookies do not identify the individual – they simply allow us to track usage patterns so that we can measure the level of interest in various Abreo areas of its site. All browsers allow individuals to be notified when they receive a cookie and elect whether to accept it. We use cookies on the Website and the Platform. 
21.3. We may use other identifiers on devices where cookies are not available (such as some mobile phones and tablets). These advertising identifiers do not constitute personal information. 
21.4. To support targeted advertising campaigns, we may collect your IP address. We also store IP addresses in server logs for Anti-Fraud and security reasons. 
21.5. We do not combine personal information with behavioural information. The purpose of collecting this information is to provide you with a more relevant and effective experience on our website(s), including presenting web pages according to your needs or preferences.
 21.6. Our website privacy policy can be accessed by clicking on the privacy button on our website. 
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