Privacy Notice
Introduction
This Privacy Notice sets out the basis on which any Personal Information
Network collects, uses, shares and otherwise processes. Please read the following carefully
to understand Network’s views and practices regarding Personal Information and how Network
will treat it. By accessing and using Network Services, including Network’s interactions
with you via our websites (including but not limited to www.network.ae), mobile sites and
applications (“Sites”), you agree to the transfer, storing and processing of Personal
Information as set out in this Privacy Notice.
Definitions
“Card” When Network uses the word ‘card’ in this notice, it applies to all
payment methods and types and not simply those involving a physical card; and use of the
term ‘cardholder’ applies to any shopper or individual whose payment transactions may be
processed.
“Network” means Network International Holdings Plc., Network International LLC any of its
subsidiaries or affiliates.
“Network Services” means the products and services which are being offered by Network.
"Personal Information or Personal Data" for purposes of this Policy means to any information
relating to an identified or identifiable individual.
You are important
At Network our most important asset is you and your trust. In this Privacy
Policy we will cover what and how we collect, use, disclose, transfer, and store your
information.
We want to assure you that Network is committed to maintaining the confidentiality,
integrity and security of any Personal Information about our users. This Privacy Policy will
explain to you what and how we collect, use, disclose, transfer, and store your non-personal
and Personal Information shared through our Sites or in connection with our Services.
It is not mandatory for you to provide the Personal Information that we have requested, but,
if you choose not to do so, unfortunately, we will not be able to provide you with our
Services or respond to any queries you may have.
Principles of Data Processing
Network shall apply the following principles when processing your Personal
Information:
1. Lawfulness, fairness and transparency: All Personal Information will processed fairly,
transparently and in compliance with applicable laws.
2. Purpose: Any Personal Information collected will be used for a stated purpose.
3. Data Minimization: Network will collect only the Personal Information that is adequate
and relevant to the purposes for which it is collected.
4. Accuracy: Network will keep the Personal Information accurate and, where necessary, kept
up to date information.
5. Storage Limitation: Personal Information will be stored with Network for a defined period
as per its policy or applicable law.
6. Integrity and Confidentiality: Network will implement appropriate technical,
organizational and physical security measures to protect Personal Information.
7. Accountability: Network will maintain applicable records, logs when dealing with Personal
Information.
What kind of Personal Information do we collect?
Network collects Personal Information relating to cardholders, merchants or other customers, suppliers and other business partners in order to carry out its business activities. Network may collect Personal Information from various sources, including:
- Information you voluntarily provide, either directly or via our customers;
- Information automatically collected when you use our Sites and Services, including in our role as a payment processor;
- Information collected by cookies and other tracking technologies when you use our Sites;
This Personal Information may include:
Contact information, Demographic information, Identification information, Payment
transaction information, Financial and credit card information, Technical information,
Social media posts, Applications (including job applications)
Non-Personal Information.
We also collect information in a form that does not, on its own, permit direct association
with any specific individual such as occupation, language, zip/area code, location, time
zone, etc. We may collect, use, transfer, and disclose non-personal information for any
purpose. This information is aggregated and used to help us provide more useful information
to our customers and to understand which portions of Services are of most interest. This
aggregated data is considered non personal information for the purposes of this Privacy
Notice.
How do we use your Personal Information?
Network uses Personal Information internally in relation to:
1. Conduct its Operations, Risk Management, Transaction Processing, Marketing, development
of existing and new Products and for Legal, compliance, regulatory or law enforcement
purposes.
2. Online Session Information and Use is Collected to Improve Your Experience
We may also collect technical and navigational related Personal Information, such as computer
browser type, Internet protocol address, pages visited, and average time spent on our Site.
This Personal Information may be used, for example, to alert you to software compatibility
issues, or it may be analyzed to improve our design and functionality of the Network Sites
and the Services.
We Use Cookies and other technologies to improve your Experience
We may use cookies and similar technologies to help us better understand user behavior, tell
us which parts of Network Sites people have visited, and facilitate and measure the
effectiveness of offer and Services and improve them.
We treat the information received from cookies and other technologies as non-personal
information.
You will have the option to disable cookies. If you choose to do so, unfortunately, certain
features of the Network website and the Services will not be available once cookies are
disabled.
Some web browsers may send out ‘do not track’ signals. There is no industry standard
currently in place as to what websites and other online services should do upon receipt of
such signals. Should such a standard be developed, Network will re-visit its notice, but
currently takes no action upon receipt of such signals.
Network may offer certain features that are only available through the use of tracking
technologies. Temporary cookies are used to enable you to navigate our site and use its
features. These are deleted when you close your browser. IP addresses are used in
conjunction with cookies for the purpose of “remembering” computers or other devices used to
access our Sites.
Analytical or performance cookies collect anonymous information about how visitors use our
websites. They allow us to analyse information such as the count of visitors to our
websites, what search terms our visitors are using, what pages are viewed, and the last page
visited. This information is based on the visitor’s IP address, and we cannot view
individual activity tied to a single person.
To the extent that Internet Protocol (IP) addresses (or similar identifiers) are clearly
defined to be Personal Information under any local law and where such local law is
applicable to Network Services, Network will manage such identifiers as Personal
Information.
Network Sites may also contain links to and from third party websites, including those of
partner networks, advertisers and affiliates. Please note that these websites may have their
own privacy notices and cookies policies, and Network does not accept any responsibility or
liability for these third party websites. The inclusion of links to third party websites in
no way constitutes an endorsement by us of such websites’ content, actions, or policies.
How We Use Anonymized Data: Peer Comparisons, Research & Development
Network may make anonymous or aggregate Personal Information and disclose such data only in a non-personally identifiable manner to:
(i) advertising, measurement or analytics partners approved by Network that conduct research
into consumer spending;
(ii) deliver products and services to other clients; and
(iii) Users of the Service for purposes of comparison of their financial situation relative
to the broader community.
With whom does Network share Personal Information and for what purposes?
Before we share Personal Information, we ensure there are adequate safeguards in place to protect the processing of that data. Network does not disclose information that could identify you personally to anyone, except as described in this notice, including, but not limited to:
- Any Network group company;
- Any group company (such as advisers, share plan, payroll and other third party administrators, agents or contractors working on behalf of Network);
- Financial institution clients;
- Service providers and other third parties under contract who help with our business operations (including, but not limited to, fraud investigations, site analytics and operations);
- Regulatory, legal and judicial authorities;
- Social media sites integrated into web services that we offer;
- Governmental or quasi-governmental organizations; and
- Potential purchasers of Network.
Network may disclose Personal Information to third parties for the following purposes:
- Legal or regulatory purposes
- Business purposes
- Suppliers who assist Network with the provision of its Services
Information on cross-border data transfers
Network International Holdings Plc., has its headquarters in London, United Kingdom. Network
International LLC, a subsidiary of Network International Holdings Plc., has it registered
office in Dubai, UAE. Network has offices and operations in other countries including Egypt,
South Africa, Jordan, Saudi Arabia, and Nigeria. The data Network collects from you may be
transferred, stored and processed in a country different from where the data was
collected.
By using our Network Sites and Services, you are permitting Network (or its authorized
service providers) to process, store and transfer Personal Information to a country which is
different from where the data was collected. The transfer of information will often be in
furtherance of a contract to which you or your bank/merchant are a party. In other cases,
the transfer of information will be consistent with the legitimate interests of conducting
Network Services.
Individual’s Privacy Rights (data subject rights)
Certain laws and regulations give individual data subject rights in relation to their Personal Information (for example, the right to access that data, to rectify inaccurate data, or to erase Personal Information). In certain circumstances, data subjects may have such rights in respect of the Personal Information processed by Network. In such circumstances, where a request to exercise such a right is received by Network, it must be forwarded to privacy@network.global so that it can be handled in accordance with applicable laws and statutory timeframes.
How do we keep your Personal Information safe and secure?
We are bound by our Group Policies
Our employees are committed to maintain the highest data protection standards by complying
with this Privacy Notice and our other policies including our Code of Conduct and Group Data
Protection Policy. The Board Audit and Technology Committee has the overall responsibility
to review the adequacy and effectiveness of the Group Data Protection Policy, ensure
compliance with the same, and review and approve changes to the said Policy wherever
considered appropriate.
All our employees receive trainings on these important requirements at least annually.
We Are Committed To Keeping Your Personal Information Secure
The security of your Personal Information is important to us. As discussed below, we utilize
physical, electronic and procedural security measures to protect against loss, misuse, and
alteration of Personal Information under our control. We adhere to industry standard
practices and security measures and our practices are independently validated annually
enabling us to comply with ISO 27001 and PCI-DSS standards to safeguard and secure the
information we collect.
No method of transmission over the Internet, or method of electronic storage, is completely
secure. Therefore, we cannot guarantee its absolute security. Any transmission is at your
own risk.
We use a combination of firewall barriers, encryption techniques and authentication
procedures, among others, to maintain the security of your online in-app session and to
protect Network accounts and systems from unauthorized access. Our servers are in a secure
facility. Access requires multiple levels of authentication. Security personnel monitor the
system 7 days a week, 24 hours a day.
We Enforce Physical Access Controls to Our Facilities
No employee may put any Personal Information or account Personal Information on any insecure
machine (i.e., nothing can be taken from the database and put on an insecure laptop). In
addition, Network frequently tests the Service for any failure points that would allow
hacking.
However, it is important to understand that these precautions apply only to our Service and
systems. We exercise no control over how your Personal Information is stored, maintained or
displayed by third parties or on third-party sites.
Our Service Ensures Secure Communications with Encryption
From the time you submit your login ID and password so that communications between your
device and Network are encrypted. This enables client and server applications to communicate
in a way that is designed to prevent eavesdropping, tampering and message forgery.
You are responsible for keeping your login ID, password, mobile device, and email account
safe and confidential.
You also agree that you control and limit access to the email account and mobile device. If
your email address or your mobile device changes, you are responsible for informing us of
that change.
We are not responsible if someone else accesses your account through Registration
Information they have obtained from you or through a violation by you of this Privacy Notice
or the Terms of Use.
Restrictions and Monitoring of Our Partners and third parties
Any partners we work with have been selected in accordance with our security and risk
management policies and practices and are bound by contractual obligations which includes
compliance with Network policies and requirements relating to confidentiality, privacy and
security. They may be subject to discipline, including termination and criminal prosecution,
if they fail to meet these obligations.
We may also use third party vendors or service providers to help us provide the Service to
you, such as sending e-mail messages on our behalf or hosting and operating a particular
feature or functionality of the Service. We require such third parties to maintain the
confidentiality of the Personal Information we provide to them.
How long does Network store and retain Personal Information?
Network will store Personal Information only for the greater of as long as necessary to
achieve the purposes for which it was collected and applicable law. Retention periods for
transaction and other data categories may vary, depending on our obligations. For example,
legal and regulatory compliance with anti-money laundering (AML) and KYC requirements,
operational demands, business requirements or dates we assigned based on contracts will also
need to be taken into account, and may require retention for a period of up to 7 years after
the data was collected or after the merchant or other customer relationship has ended.
What happens in case of a data breach?
In case Network is faced with a breach of Personal Information, Network shall inform the
relevant authorities and the data subjects where required by applicable law and shall take
necessary steps to mitigate the impact of such breach.
Changes and updates to the privacy notice
Network may, from time to time, make changes to this Privacy Notice. If any material changes
are made as to how Network treat Personal Information, you will be notified through this
notice on Network’s Sites.
The date the Privacy Notice was last modified is at the bottom of the page. You are
responsible for ensuring you periodically visit our Sites to check for any changes. By
continuing to use Network Services or the Sites, you agree to the changes in this Privacy
Notice.
This notice is global in scope, but is not intended to override any legal rights in any
territory where such rights prevail. In such event, the rights and obligations set out in
this Privacy Policy will apply, subject only to amendment under any applicable local law
having precedence.
Questions
We have appointed Amit Khandelwal as the Group Data Protection Officer (DPO). If you have questions, comments, concerns or feedback regarding this Privacy Notice or any other privacy concern, contact DPO at privacy@network.global or call us at +971 4075863.
Last modified: 25 September 2024