BlaBla Connect Limited (‘BlaBla’) is committed to protecting and respecting your privacy. Our Privacy Policy together with our Terms and Conditions apply to your use of our PassTo application and the services accessible through our app and website.
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It is important to us that you can trust us with your information when you use our services. Note that our services are not intended for children. Please take a few minutes to read our Privacy Policy to understand what information we collect, what we do with it and why.
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We have layered our privacy policy so that you can find the details you need as quickly and easily as possible. Our privacy policy gets updated from time to time. Whenever we make a change, we will post an update and inform you if there is a material change.

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We have a dedicated function (Head of Information Security) who constantly reviews and improves our measures to protect your personal information.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. All the measures are documented in a single document known as the IT Security Policy which includes BlaBla’s practices on acceptable encryption, information security review and audit, network security, data retention, archiving and destruction.
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Our app uses industry approved protection tools (encryption, passwords) to protect your personal information against unauthorized access or disclosure. In addition, we limit access to your personal data to those staff members or other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a strict duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and relevant supervisory authority of a breach where we are legally required to do so.

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We will collect information about you and this will vary based on the services you choose to use and subscribe to as well as the amount of funds involved. When you download our app, information may be accessed from or stored on your device to allow the app to operate and function.
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The specific types of information we may have are as follows and we have grouped them in relation to each service type:

• Your Identification Data: This includes your full name, nationality, date of birth, a picture of you, a copy of a proof of identity related documentation (passport or driving licence or national identity card), your street address, postcode, city and country.
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• Your Beneficiary’s Identification Data: This may include his/her first name, last name, phone number and email address.
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• Account Data: This includes your phone number and email address.
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• Your Beneficiary’s Account Data: This may include his/her phone number and email address.
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• Financial Data: This may include your bank account numbers, or debit/credit cards linked to your PassTo account when you make bank transfers. Additionally, we may collect your occupation and salary details for the last 3 (three) months, source of funds details and purpose of transactions. It may also include your beneficiary’s bank account details.
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• Technical Data: This includes internet protocol (IP) address, device information, such as device type and serial number, browser type and version, device operating system version, language, browsing patterns and user activity.
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• Usage Data: This includes details about how you use our products and services, your transaction amounts and dates, frequency of transactions, including their status.
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• Marketing and Communications Data: This includes your marketing preferences in receiving marketing from us and your communication preferences.
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• Customer Care Data: This includes your feedback to us, survey related information and chat logs.
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For more information about our data privacy policy, kindly check it from here.

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We will only use your personal data when the law allows us to, most commonly, in the following circumstances:
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• Where we need to perform the terms and conditions we are about to enter into or have entered into with you.
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• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. We have carried out a legitimate interests assessment to ensure that where we rely on legitimate interests, that those interests are valid.
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• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
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• Where we need to comply with a mandatory legal or regulatory obligation.
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• Where you provide your consent to us before processing.
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Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

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We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal requirements. Details of retention periods for different aspects of your personal data are set in our Data Protection Policy.
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In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case, we may use this information indefinitely without further notice to you.

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