This Privacy Policy (“Policy”) applies to Faciangola Prestadora de Servico de Pagamentos, Lda, and to all of its products and services. Faciangola Prestadora de Servico de Pagamentos Lda is a legal entity, commercially represented under Angolan law as a limited liability company, which acts as a Fintech to design and implement products and services for the financial sector with fully technology-based processes.
Our products and services are intended for use by natural and legal persons. They are made available to users, hereinafter clients, by means of a registration on Faciangola's technological payments platform.
The Client is the data controller of its own personal data and, in case of doubt, should contact Faciangola with questions or requests regarding their personal data. Faciangola is not responsible for the privacy or security practices of our Clients, which may differ from this Policy.
As used in this Policy, “personal data” means any information relating to, describing, or that may be used to identify an individual, whether directly or indirectly. Capitalized terms not defined in this document (such as site, services, Client, agent, agents' contact information and other terms) have the meaning given in our Terms of Use.
Applicability
This Data Privacy Policy applies to personal data for which Faciangola is the controller, which may include:
1. data collected through the site faci-x.co.ao, the Faciangola mobile applications, our social media pages, brand pages and other sites we operate (collectively, our “Digital Properties”);
2. Data collected in a manner where we post a direct link to this Policy, such as those in connection with digital communications, printed forms, in-person interactions (which may include marketing and outreach activities, such as surveys, promotions, sweepstakes, conferences, webinars and events);
3. Agents' Contact Information;
4. Data collected about individuals who visit our offices or conduct business transactions with us.
This Policy does not apply to the following information:
Personal data about Faciangola employees and candidates and certain contractors and agents who act in similar roles.
Personal data that Faciangola processes on behalf of our Clients.
Changes
We may update this Data Privacy Policy from time to time to reflect changes in legal, regulatory, operational requirements, our practices and other factors. Please check this Policy periodically for updates.
If any of the changes are unacceptable, the Client should stop interacting with us. Where required by applicable law, we will notify the Client of any changes to this Policy by posting an update on our site (and updating the “Last Update” date at the beginning of this Policy) or in another appropriate manner.
We collect information about the Client and how they interact with us in various ways, including:
Information you provide to us directly. We collect the information the Client provides to us directly. This includes cases where you register and communicate with us directly through our Digital Properties, when you visit our offices, by email exchange, when you participate in our events or when you take part in our marketing and outreach activities (including surveys, promotions, sweepstakes, conferences, webinars and events).
Information collected from your employer, co-workers or friends. We may collect and process personal data relating to representatives (for example, employees) of our current, past and potential clients, suppliers, investors and business partners of those companies or other employees of those companies. We may also receive your name, address, phone number and company name from a friend as part of a referral. In the case of a referral, it is presumed that the referred person has been notified by the referrer about our policies and privacy.
Information collected or automatically inferred from your interactions with us. We automatically collect technical information about your interactions with our Digital Properties (such as IP address, browsing preferences, purchase history, shopping cart and so on). More information is available in our Cookie Policy.
Information from public sources. We may collect information from government entities from which public records are obtained and information that Clients submit in public forums, including information made publicly available on social networks.
Information from third parties. We receive information about Clients from third parties, such as third-party content and service providers, entities with which we partner to sell or promote products and services, telephone and fax companies, authentication service providers, data brokers and social media (including widgets related to those networks, such as the “Facebook Like” button). Your interactions with these social media features are governed by the privacy statement of the companies that provide them.
We may combine information that we receive from various sources described in this Notice, including third-party sources and public sources, and use or disclose it for the purposes identified below.
4. Types of personal data we collect
The types of personal data we collect include:
Identifiers, such as your name, address, unique personal identifier, online identifiers (such as various advertising identifiers), instant messaging ID, internet protocol (IP) address, email address, account or user name, mobile phone number, social media identifiers (for example, Twitter handle, Instagram name, etc.), or other similar identifiers.
Commercial information and preferences, including credit records, products or services purchased, obtained or considered for purchase or acquisition, or other purchasing or consumption histories or tendencies.
Internet activity or other electronic network activity and device information, such as your browsing history, search history, information about your device, operating system, mobile carrier, location and other information about your interactions with our digital properties or products and services, emails, mobile applications or advertisements. Some of this information may be collected using cookies and other tracking technologies, as described in our Cookie Policy.
Geolocation information, such as the latitude and longitude of your IP address or mobile device location, province, municipality, district and commune by means of a web form.
Audio, electronic, visual and other sensory information, such as video/photo or audio recordings of our facilities (for example, if you participate in an event or visit our offices). Recordings of your interactions with our sales, advocacy and support teams (for example, for quality assurance, training and analysis purposes in accordance with applicable laws) or records of customer support instant messages.
Professional or employment-related information, such as your company or employer, company website, your job title and role, training and certification activity, company information or business address.
Inferences drawn from any information we collect to create a profile about the Client so as to reflect their preferences, characteristics and behavior.
5. How we use your personal data
We may use each category of your information described above in the following ways:
To enable interactions and provide our products and services to the client: We may use your personal data to create, maintain, personalize, administer and protect your account; allow you to access and use the site and the services; to enter into, manage and perform our contract with you or your employer; provide, operate, maintain, improve and promote the products and services site; process and complete your contact and support requests and send related information, including purchase confirmations and invoices; inform you about additional features and other services offered by us; diagnose, repair and track service and quality problems; facilitate an order, download, expiration or termination; send transactional messages, provide security alerts and updates and communicate with you about our data practices; manage and promote registrations for conferences, webinars and events; manage and promote surveys, contests, promotions and sweepstakes; personalize and improve our digital properties and your Services experience; provide content information relevant to your interests; install and configure changes and updates of programs and technologies related to interactions with us; authenticate whoever interacts with us; to respond to your requests, complaints and inquiries.
To fulfill a referral request: If you choose to use our referral product or service to tell a friend about our products and services, we will use the name and email address you provide us to contact your friend. You should only provide your friend's name and email address if you have a reasonable belief that they will not object to our contacting them.
For our own business purposes: We may use your personal data to evaluate or audit the use and performance of programs and technologies related to interactions with us; evaluate and improve the quality of your interactions with us, our products and services, site, applications, programs and technologies related to interactions with us; design new products and services; process and catalog your responses to surveys or questionnaires (for example, customer satisfaction evaluations); record phone calls and/or videoconferences for quality assurance, training and analysis purposes in accordance with applicable laws (including obtaining consent or an opportunity to object, if required by law); conduct internal research for technological development and demonstration; conduct analysis and data testing; payments, balance, credits, accounting and other similar business functions; maintain appropriate business records and other relevant records.
For legal and security reasons: We may use your personal data to comply with legal requirements, such as export controls; establish, exercise or defend ourselves against legal actions that we may have against the Client/prosecute together with you, whether in judicial proceedings or in administrative or extrajudicial proceedings; protect the security, protection and integrity of our property (such as our digital properties (site, application, etc.), products and services, databases and other technology assets) and rights of those who interact with us or with other people; analyze compliance with the applicable terms of use, investigate fraudulent transactions, unauthorized access to our digital properties and services, violations of content and conduct policy, illegal activities (in compliance with legal obligations under applicable laws); and otherwise detect, prevent and respond to security incidents or other malicious, deceptive, fraudulent or illegal activities. These security purposes may also involve the collection and processing of special categories of personal data (namely, health data), for office visits and events when necessary for reasons of interest of public health or required by applicable law.
For marketing: We may use your personal data to market our products and/or services, as well as those of third parties, with regard to our business partners. This may include sending marketing communications, product recommendations and other non-transactional communications (via email, mobile phone or other online and offline communications) about our Services or third-party services, promotions, news and events. We may use your personal data when you participate in marketing research, questionnaires, promotions, testimonials, online comments, product feedback, events, sweepstakes or other contests. We may audit some details of our ad impressions. We may use your personal data for contextual ad personalization. You may unsubscribe from marketing communications by accessing the address https://FaciPay.ao and by providing your email address(es), mobile phone number or by clicking the unsubscribe link at the bottom of our marketing communications. You may also manage your email preferences. Please note that some of our marketing materials and information may use tracking technologies and analytics tools to help us understand your preferences. For additional information, please consult the Cookie Policy.
Corporate transactions: We may use your personal data in connection with corporate transactions, sales, mergers, acquisitions, reorganizations, bankruptcies and other corporate events. For example, we may use your personal data to fulfill requests from a potential or actual buyer interested in our companies and other assets, or in connection with an actual or potential purchase of companies or assets by us.
Consent: We may use your personal data for any other purposes to which you give your consent.
In a de-identified, anonymous or aggregated format. Depending on applicable law, when converted to a de-identified, anonymous or aggregated format, the data may cease to constitute personal data and we may use that information for any purpose not prohibited by law.
6. To whom we disclose your personal data
We may share your personal data with the categories of recipients described below:
Affiliates and subsidiaries: We may share your personal data within our Faciangola ecosystem, which includes parent companies and our holdings, affiliates, subsidiaries, business units and other companies that we may acquire in the future after they become part of Faciangola, which will use them for the purposes described in this Privacy and Data Protection Policy.
Service providers: We may share your personal data with service providers that work on behalf of Faciangola, such as hosting service providers; IT, operating systems and platforms; Internet services, data analytics and marketing companies. We may also engage companies to provide certain services, such as identity verification, email distribution, market research and promotion management. We provide these companies only with the information necessary to perform their services and we work with them to ensure that your privacy is respected and protected. These companies are contractually prohibited from using this information for their own marketing purposes or from sharing this information with anyone other than us, unless under our direction as part of providing the service or with your agreement.
With third parties under your direction or that are necessary to complete transactions: We may disclose your personal data to entities that assist us in fulfilling your orders and requests, such as credit card processors and partners that may provide part of your order. We may also disclose your personal data to third parties that you may direct (such as if you choose to participate in events, offers or promotions that are offered jointly with third parties).
Business partners. We may also provide your personal data to business partners for their own purposes, such as:
To event sponsors, in which case your information will be subject to the sponsors' privacy statement(s). If required by applicable law, we will obtain your consent before sharing data with the event sponsors.
To our Clients, such as by sharing information about Agents of a Client's account.
To channel partners (third-party organizations or individuals that market and sell products and services for us), with the purpose of allowing our channel partners to notify the Client about our products and services. We require channel partners to offer an opt-out option in the communications they establish with the Client. By opting out, you will stop receiving future communications from our channel partners.
To third-party networks and sites for marketing and advertising on third-party platforms and sites.
Professional advisors. We may share your personal data with various professional advisors, such as lawyers, accountants and auditors.
For legal, security and protection purposes: We may share your personal data to respond to legal requests from law enforcement or other governmental authorities, in accordance with the Government Data Request.
Duly identified and verified law enforcement agents, or government officials, may use the email atendimento@FaciPay.ao to securely submit legal processes for user data, preservation requests, emergency requests or hold access requests;
Through this same channel they may also use it to check the status of a request, track multiple requests and download the response to a request;
The request may be submitted if you are a sworn law enforcement agent or another government official authorized to issue a legal process related to an official investigation.
Requirements for all jurisdictions:
Requests must:
be in Portuguese;
be in *.pdf format, except in some emergency situations;
be addressed to Faciangola Prestadora de Servico de Pagamentos Lda, Edificio Bengo, Sala 109, Condominio Belas Business Park Talatona - Luanda – Angola. For requests regarding meetings or phone calls, at the same address;
come from an official government email address;
contain:
the name of the requesting agent;
the name of the requesting body or institution;
the badge/identification number of the requesting agent;
the email address issued by the government, body or institution of the requesting agent;
the phone number (including the extension) of the requesting agent;
the postal address (a P.O. box is not permitted) of the requesting agent;
a date and the signature of the official who is authorizing it;
a date by which the legal process requests a response
Content of the requests
Requests must be legally valid, appropriately scoped and sufficiently detailed. This means that they must:
Have a valid legal basis and have been issued in accordance with the laws and rules in force in the jurisdiction of the agency making the request, be signed and have been sent by someone with authority to make such a request.
Be clear and not be excessively broad.
Include specific identifiers in the requests, such as the meeting number, date and time in UTC (Coordinated Universal Time), the email address used to set up the meeting and the username(s) of the targeted user(s), if the request concerns a meeting, and specify reasonable date ranges, if applicable.
We contest excessive or unlawful requests
We always contest requests that:
Are broad or vague;
Do not have a legal basis in the Angolan jurisdiction;
Are not genuine or related to crime prevention;
Request information that is not subject to the requester's jurisdiction;
Come from an entity without authority to make the request;
Have confidentiality requests without end dates;
Are inadequately fulfilled or are invalid in other ways.
Our policies for notifying users
It is our policy to notify our users/Clients when we must disclose their information to a government, body or institution, except when we receive a valid order for delayed notification or when the matter involves child endangerment, a life-threatening emergency or a threat to the services, rights or property of Faciangola.
We evaluate each delayed notification request we receive to ensure that it is legally valid. When necessary, we take all reasonable legal steps to contest legally invalid delayed notification orders.
When a delayed notification order expires, we notify the affected user.
We may also share this information if we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations that involve possible threats to the physical safety of any person; to enforce or apply our Agreement and Policy with natural persons and to protect our rights, property or safety of our users or third parties; or otherwise establish, exercise and defend ourselves against legal actions (including sharing data with opposing parties or other parties related to the process and their professional advisors) and as required by law.
In connection with a corporate transaction: If we sell/acquire some or all of our assets, merge or are acquired by another entity (including through a sale or in connection with a bankruptcy) or engage in other similar forms of corporate change, we will share your personal data with that entity.
The public: There may be opportunities to make public comments about us or our products and services. If you provide testimonials, we may publish your name together with the testimonial, with your consent. If you provide feedback, we may publish your name together with the feedback with your consent. We may publish anonymous testimonials and content feedback without your consent. The site may offer publicly accessible blogs, community forums, comment sections, discussion forums or other interactive features (“Interactive Areas”). Please note that any information posted in an Interactive Area may be read, collected and used by other people who access it.
Consent: We may disclose your information to third parties with your consent. We may also de-identify, anonymize or aggregate personal data to share with third parties for any purpose, if permitted by law.
7. Cookies and Tracking Technologies
Cookies, Pixels and other similar tracking technologies used: We and our authorized partners also collect information through cookies, web beacons, pixels, tags, embedded scripts, session replay tools, SDKs, local storage, such as HTML5 and local shared objects (Local Shared Objects, “LSOs”, also known as Flash cookies), or other data retrieval and tracking technologies (“Tracking Technologies”), such as your Internet service provider and IP address, device identifier, browser type, operating system, WiFi MAC address of your device or Bluetooth MAC address, the date and time at which you access our Digital Properties, the pages you accessed when visiting our Digital Properties and the Internet address from which you accessed our Digital Properties. Cookies are a type of technology that installs a small amount of information on the computer or other device of a user when they visit a site or application. Cookies allow a site, for example, to recognize future visits using that computer or device. Some cookies exist only during a single session and some are continuous across multiple sessions over time. We and our partners use these Tracking Technologies to ensure the basic functionality of our Digital Properties; to remember user preferences (including their preferences regarding tracking technologies); maximize the performance of our Digital Properties and Services; provide you with offers that may be of interest to you; measure the effectiveness of our Digital Properties, marketing campaigns and email communications; and to personalize online content. These Tracking Technologies may be used to track you over time and across devices, sites and Services.
In addition, we may employ, directly or through third parties, tracking pixels. Tracking pixels are tiny, transparent graphics with a unique identifier, of a function similar to cookies, and are used to provide analytical information about the user experience, as well as to support marketing activities personalized for users of our Digital Properties. Unlike cookies, which are stored on the hard drive of the user's computer, tracking pixels are embedded invisibly in web pages. Our Digital Properties may use tracking pixels to help us best manage content, such as improving the user interface, or improve our marketing programs, or the marketing of our affiliates, business partners and other third parties (including for interest-based advertising, as described below). The Digital Properties may use information to create aggregate reports of tracking information about user demographics, traffic patterns and purchases. We may also link tracking information to personal data.
Third-party Companies: To provide you with a more relevant and interesting experience, we may work with third-party companies to display ads or personalize content on our Digital Properties or through other communication channels. These companies may use Tracking Technologies as described in this Data Privacy Policy to collect information about you, which may include your exact location, your visits to the Digital Properties and your visits to other places on the Internet. These companies may also use this information to provide more relevant advertising, known as interest-based advertising, which may include sending an ad on another online service after you have left our Digital Properties (that is, retargeting).
Your choices: You may choose to receive some interest-based advertising. If you are located in the European Economic Area, Switzerland or the United Kingdom, essential cookies always need to be used to provide the Services requested. However, you may choose whether you agree with the use and further processing of data collected through non-essential cookies (that is, functional cookies, analytical cookies, targeting cookies and social media cookies) at the time you first visit the Faciangola site. You can update your decision (including withdrawing any consent given previously with effect in the future) at any time, by clicking the “Cookie Settings” link in the footer of each web page. Clicking this link will also provide more information about the various types of cookies used and the specific third parties that use them.
If you are located in the European Economic Area, you may also opt for the use of cookies more generally at this link.
The Digital Advertising Alliance ("DAA") and the Network Advertising Initiative ("NAI") also provide mechanisms for you to disable interest-based advertising carried out by participating members at:
You may also visit http://www.aboutads.info/appchoices to obtain information about the DAA opt-out program specifically for mobile applications (including the use of exact location for third-party ads).
Disabling interest-based advertising will not exclude you from all advertising, but only from interest-based advertising from us or from our agents or representatives. In addition, opt-outs based on cookies need to be performed on each device and browser you wish to disable. For example, if you disabled your computer's browser, that disabling will not necessarily be effective on your mobile device.
DAA/NAI browser-based opt-outs will not work or may no longer be effective if your browsers are configured to reject cookies, if you subsequently delete your cookies or if you use a different device or web browser. We are not responsible for the effectiveness of these options or opt-out programs of third parties or of any others.
Do Not Track: Some browsers have incorporated Do Not Track (Do Not Track, “DNT”) preferences. The majority of these features, when activated, send signals to the site you are visiting that you do not want information about your online search and browsing activities to be collected and used.
As there is not yet a common agreement on how to interpret DNT signals, we do not honor DNT signals from site browsers at this time. However, you may reject or delete cookies. If you reject or delete cookies, some of our site's functionalities may be impaired or part of the advertising served to you may no longer be relevant to you. If you change computers, devices or browsers, or use multiple computers, devices or browsers and delete your cookies, you may need to repeat this process for each computer, device or browser.
Consult the “help” instructions of your browser to learn more about how to manage cookies and the use of other tracking technologies. You can also find more information about how to manage cookies at All About Cookies – Manage Cookies.
For detailed information about the use of cookies on our site and how to manage your cookie settings, read and review our Cookie Policy.
8. Security and retention
We maintain reasonable security procedures and technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, disclosure, alteration or use.
When Faciangola is the controller of personal data, your personal data will generally be retained for as long as necessary to fulfill the purposes described in this Data Privacy Policy. This includes retaining your data to provide the requested products and services, interact with you, enable your participation in an event, maintain a business relationship with you/your company; improve our business over time; to ensure the ongoing legality, security and protection of our services and relationships or in accordance with our internal retention procedures.
Once the natural or legal person has terminated the contractual relationship with Faciangola, we may retain your personal data in our systems and records to: ensure appropriate compliance with the clauses that continue in force in contracts that have been terminated or for other legitimate business purposes, such as to evidence our commercial practices and contractual obligations, to provide you information about our products and services or to comply with applicable legal, tax or accounting requirements. Likewise, your personal data will be retained during the applicable period provided by law for the establishment, exercise or defense of possible legal actions.
When we do not have an ongoing legitimate business need nor a legal basis to process your personal data, these will be deleted, anonymized or aggregated or, if this is not possible (e.g., because your personal data has been stored in backup files), we will securely store your personal data and keep it isolated from any further processing until deletion is possible. If you want to know more about the retention periods applicable to your specific circumstance, please contact us.
9. Privacy of minors
Our site, products and services are not directed at minors under 18 years of age and we do not intentionally collect personal data online directly from minors. If you are a parent or guardian of a minor and believe that the minor has disclosed personal data to us online, please contact us at the email address atendimento@FaciPay.ao
10. External links
When interacting with us, you may find links to external sites or other online services, including those embedded in third-party advertisements. We do not control and are not responsible for the privacy and data collection policies of these third-party sites, products and services. You should consult these third parties and their respective privacy notices for more information or if you have any doubts about their practices.
11. Terms of use
The Master Subscription Agreement, End User License and other applicable terms for interactions with us can be found in our Terms of Use.
12. Contact information
In case of doubts or complaints regarding this Policy or about the privacy practices of Faciangola, please contact us via email:
atendimento@FaciPay.ao or at the following address:
Faciangola Prestadora de Servico de Pagamentos Lda.
Edificio Bengo, Sala 109
Belas Business Park.
Talatona – Luanda – Angola.
Should you have any doubt about the use of data or privacy that has not yet been adequately resolved, please contact us.
13. Your data protection rights
We guarantee the security of Clients' data, and we grant individuals rights relating to personal data, such as those listed below:
Access: You may have the right to obtain our confirmation of whether your personal data is being processed and related information; and the right to obtain a copy of your personal data during processing.
Rectification: You may exercise the right to request the rectification of inaccurate personal data and to complete incomplete data.
Objection: You may exercise the right to object to the processing of your personal data for compelling and legitimate reasons related to your specific situation, except in cases where the legal provisions expressly provide for such processing. You also have the right to object to/exclude the processing of your personal data for direct marketing purposes by clicking the unsubscribe link at the bottom of the marketing communication received by email or by sending an email to atendimento@FaciPay.ao .
Portability: You may have the right to receive your personal data that you provided to us, in a structured, commonly used and machine-readable format, and have the right to transmit it to other data controllers without hindrance. This right only exists if the processing is based on your consent or on a contract and the processing is carried out by automated means.
Restriction: You may exercise the right to request the restriction of the processing of your personal data in certain cases.
Erasure: You may request the erasure of your personal data if:
(i) they are no longer necessary for the purposes for which we collected them;
(ii) you have withdrawn consent and there is no other legal basis for the processing;
(iii) you object and there are no legitimate grounds for the processing;
(iv) the processing is unlawful or the erasure is necessary to comply with a legal obligation.
Right to lodge complaints: You may also exercise the right to lodge a complaint with a supervisory authority in the country where you reside. The contact details of the data protection authorities are available for public consultation on search sites, for example, Google. The authorities of the EEA, Switzerland and the United Kingdom, the APD in Angola and other countries may be consulted through these channels.
Right to refuse or withdraw consent. Should we request your consent for the processing, you are free to refuse to give consent and may withdraw consent at any time, without any adverse negative consequences, by contacting us and using the contact information provided above. The legality of any processing of your personal data that occurred before the withdrawal of your consent will not be affected.
Automated decision-making. We inform you that the types of automated decision-making do not occur on our site, application, products or in our Services. If there is any change, we will inform you about it and the fact that you have the right not to be subject to these types of decisions based solely on automated processing and to receive more information about why that decision was made.
We will honor all these rights and everything that is required as provided by law.
To exercise your rights (or other rights that may be available to you under your local data protection laws), please contact us by sending an email to atendimento@FaciPay.ao.
We try to respond to all requests within Thirty (30) days after receiving the request or as required by applicable law. If the response takes longer, we will notify you. If we have reasonable doubts about your identity, we may request that you provide us with additional information to verify your identity.
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