Privacy Policy (updated August 2023)

 

The Amanacard service and SecureAid system are provided to you by Huozhi Ltd, a social impact enterprise registered in the United Kingdom. For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR"), the company responsible for your personal data is Huozhi of 21-23 Mossop St, London SW3 2LY, United Kingdom ("Huozhi", "us" or "we").

 

This Privacy Policy explains what we do with your personal data. It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

 

Huozhi partners with international organisations ("Organisations") to facilitate and track the delivery of aid in the form of goods, services and cash to unbanked vulnerable households, paid workers and/or local businesses (“Recipients”) in crisis zones. Our strategy is to help organisations minimise the cash footprint created by their cash-based programming whilst simultaneously ensuring the delivery of critical cash payments via vetted networks of “Merchants” that operate a verifiable end-to-end money transfer service.

 

When an individual is onboarded to the SecureAid platform, they become an "Amanacard Member", which enables them to use a physical or virtual Amanacard that interfaces with various Amanacard mobile applications. As part of this process, we need to collect and process personal data in accordance with the Terms & Conditions (local versions available in Arabic; Dari; Pashtu).

 

This Privacy Policy applies to subscribers who are Recipients and Merchants, and specifically operators of the Amanacard "Cash App" (“Cash App User”) and users of "My Amana" app.

 

WHAT

What is the nature of the data that Huozhi will be collecting about you via SecureAid?

 

We will collect the following information from you:

• Gender

• Full name (in local language)

• Date of birth

• Copy of an ID

• Mobile number

• Business / Entity name and address

 

• We will also collect information about the cash pay-outs or non-cash purchases you facilitate using the Cash App, and convert this to anonymised statistical data for reporting purposes and settlement of the debt owing to you.

 

What information does Huozhi receive about you from third parties?

We will receive information about you that you have already provided when being contracted by an organisation to deliver services in the aid programme that will now make use of the Amanacard service.  This includes: your gender, your full name, your date of birth, you ID, your mobile number and your business or entity name and address.

 

How long will Huozhi hold this data for?

We hold data for the minimum duration necessary to fulfil the stated requirements of your contract. We delete all personal data at the close of your use of Amanacard, and will only retain a copy of the data for the following reasons:

• compliance with Applicable Laws or Applicable Policies

• continuing right to store or use such data pursuant to another agreement with you or third parties – for example, you may wish to retain a record of your financial activity and thus build a transaction history

 

HOW

How will Huozhi collect the data?

We will receive information directly from you (in person or remotely), and in the case where you are already contracted by a partner organisation, we may receive information securely from them.

 

How will Huozhi use the data itself and if it discloses it to third parties, what is the basis on which it would do so?

We will collect and store your information so that we can provide you with an Amanacard Member profile, and any necessary related services.  We believe that it is within our legitimate interests to do so.

 

We share personal data with partner Organisations where this is necessary in relation to the purpose for which the data was obtained, and covered by a data sharing agreement.

 

Prior to sharing data with third parties, we will anonymise any personal data in accordance with the United Kingdom’s Information Commissioner Office (ICO)’s anonymisation code of practice, withholding any detailed information that could allow individuals to be identified: https://ico.org.uk/.

 

WHERE

Where will Huozhi hold this data and, consequently, where will it be accessible from?

Huozhi will hold this data on servers hosted in the European Union.  It will only be accessible by authorised personnel in the United Kingdom, and a minimum level of information (full name, ID number, date of birth) is accessible temporarily when we meet you in person to issue your Personal Identification Number (“PIN”) or Household Identification Number (“HIN”).

 

RIGHTS

How can you exercise your rights under the legislation?

You have the right to know what information we hold about you and process on your behalf, and you also have the right to ask for it to be rectified, or for it to be erased (except in cases listed in paragraph 3 of Art. 17 GDPR).  If you have an Amanacard Member profile and would like to contact us about your information, please contact us at: service@amanacard.com.  We will respond within 30 calendar days of receiving your enquiry. 

 

You also have the right to lodge a complaint with your local supervisory authority. The supervisory authority in the United Kingdom is the Information Commissioner's Office at: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (Tel: +44 303 123 1113; Email: casework@ico.org.uk).

 

By providing us with your mobile number, we can make you aware of any changes to this policy and contact information.

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