Privacy policy
Version 2.0, 10 May 2012
22seven is committed to the privacy of your Personal Information. Your information is yours - always. We will always collect the minimum amount of Personal Information necessary to provide the Service to you. Our staff and Authorised Service Providers are bound by confidentiality and privacy obligations that align directly with this Privacy Policy. They are given access only to the information they require to fulfil their responsibilities.
This Privacy Policy describes and explains what Personal Information we collect, how we use it and how we protect it. "Personal Information" means any information that is recognised as such under South African Law and includes any information which identifies you (our customer) or which, when linked to other information, can personally identify you.
What Personal Information does 22seven collect and how is it used?
We only collect Personal Information that is reasonably necessary for us to provide the Service to you.
Registration information: Name, email address and password you provide when you register to use the Service so that we know who you are, can authenticate your use of the Service and are able to contact you about Service related matters.
Security Credentials: Your User ID, PIN, Password and any other required authentication information to automatically collect your Account Information from the secure websites and systems of your nominated Product/Service Providers on your behalf. From the time you submit this information to us it is always transferred and stored in encrypted form. It is stored only by Yodlee (our Authorised Aggregation Service Provider) and is only ever used to collect your account information from your nominated Product/Service Providers on your behalf to be used in the Service. Your Security Credentials are never disclosed to any other third party and at no time can employees of 22seven or Yodlee access them.
Account Information: Balances, transactions and other account-specific details that Yodlee's automated aggregation service collects from your Product/Service Providers on your behalf or that you provide directly to the 22seven Service via the Website or Mobile Applications. You will have full access to this information via the Service. You will also have access to the information and insights our automated algorithms derive from your Account Information. We only store the last four-digits of account and credit card numbers when received as Account Information.
Billing information: Bank account, credit card or other payment details you provide when you subscribe to 22seven in order for us to collect your monthly subscription fee. This information is handled separately from your Account Information and is disclosed to our authorised billing service providers during the collection process and is only used for this purpose.
Correspondence information: Information we collect when we receive correspondence from you via email, social media, mobile text messages and phone calls. This includes your sender information, the content of the message and the metadata pertaining to the message. We use this information to communicate with you and to improve the Service.
Public forum/message board information: Your name (as provided at registration) as well as the messages you post on our public forum/message board. This information is visible to all users and will remain as such even if you terminate your use of the Service.
Website and Mobile Application connection information: Your IP address, type, version and language of Internet browser, operating system and version, type of device, screen resolution, referring and exit web pages. We use your IP address to understand the geographic makeup of our customer base and to assist with the identification of potential unauthorised access. We use the rest of this information to optimise the usability of the Service on your access device. We may also compile aggregate information to analyse usage patterns and make improvements to our Service.
Additional verification information: Copies of your identify documents or utility bills in order for us to verify your identity should you be unable to unlock your account through our standard online verification process.
Does 22seven ever disclose my Personal Information to third parties?
We disclose your Personal Information only to our Authorised Service Providers with whom we contract to assist us in providing the Service to you. We make use of Authorised Service Providers to automatically aggregate your Account Information, host and run our servers, send emails, manage support requests, collect subscription fees and enrich information. They process your Personal Information strictly in accordance with our instructions and for the purpose for which such Personal Information has been disclosed to them. They will always be under obligation to protect your Personal Information on terms that provide the same or equivalent protection as set out in this Privacy Policy.
In addition, we may disclose your Personal Information to law enforcement, other government officials, or other third parties as may be necessary in connection with an investigation of fraud, intellectual property infringements, cyber crime or other activity that is illegal or may expose us or our Authorised Service Providers to legal liability.
Does 22seven use my information for any purpose other than providing the Service to me?
We may aggregate and analyse your 'de-identified' information (i.e. stripped of all uniquely identifiable attributes and that cannot subsequently be re-identified) with that of other customers and information received from other sources. We will do this to develop market insights, troubleshoot problems, detect and protect against error, fraud and other criminal activity, identify behaviour/usage patterns and improve our Service generally. We may publish or share the insights we develop through this process.
Will 22seven ever sell my Personal Information?
No. We collect and use your Personal Information only to provide the Service to you and as set out in this Policy. Your Personal Information remains exactly that - yours.
How does 22seven protect my information?
We use a combination of technical, procedural and operational measures to keep your information safe and secure. Please read more about our security.
Does 22seven use Cookies on its website?
Unless you have disabled Cookies in your Internet browser, we will store Cookies on your computer/device when you visit our website. These Cookies (small text files containing a string of characters) enable us to recognise you as a returning visitor, track your usage behaviour, as well as store your user preferences and other information. We do this to remember information so that you will not have to re-enter it during your visit or the next time you visit the Website. Cookies also allow us to provide custom, personalised content and information, monitor the effectiveness of our marketing campaigns, monitor aggregate metrics such as total number of visitors and pages viewed.
What Personal Information can 22seven staff see?
22seven staff are bound by comprehensive confidentiality obligations. Our staff are given access only to information they are required to see in order for them to fulfil their responsibilities. In all cases we provide access to the minimum amount of information. Given their role, our customer support team has access to the most amount of Personal Information - to enable them to answer your support questions. In addition to Service usage information, our internal systems provide them with secure access to:
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What happens if I dispute the validity of the information?
If any information collected by us about you is disputed by you and is found to be inaccurate, incomplete, or cannot be verified, we will promptly delete or modify such item of information, as appropriate, based on the results of the investigation.
Can 22seven refuse me access to my Personal Information?
We may, in compliance with applicable laws or if we are unable to verify your identity, refuse you access to your Personal Information and in such circumstances we will tell you why access has been denied.
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How long does 22seven keep my Personal Information?
We will keep your information for as long as you are an active customer of the Service. We delete your information when you terminate your use of the Service but will retain some Personal Information for so long as we are obliged to do so under South African law. Such information will always be maintained under the same security and privacy controls that are in place for other customers of the Service.
What happens if I wish to opt out of any disclosure of my Personal Information?
You may opt out of disclosure of your Personal Information. Should you choose to do this and should the opt out be in respect of Personal Information necessary to provide the Service, we may not be able to continue to provide the Services to you and in such circumstances, we will notify you of this. Should you still wish to opt out after such notification you will be entitled to terminate your use of the Service, which will result in the deletion of your Personal Information.
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