Third Party Websites: Some pages on the BFX Website include links to third-party websites. These sites are governed by their own privacy statements, and AZA is not responsible for their operations, including, but not limited to, their information practices. Users submitting information to or through these third-party websites should review the privacy statements of these sites before providing them with personally identifiable information.
2. Information We Collect
Required Information: To open a BFX account or use the AZA Services, you must provide your name, address, phone number, date and place of birth, nationality, the details of your identification document, and email address, or other information to be determined by AZA from time to time. In order to fund your balance with BFX Account or make certain payments through the AZA Services, you must provide (where applicable) your bank (or another payment instrument, such as mobile wallet) account information. We may also ask you to choose different security questions to answer.
We will also require other commercial and/or identification information if you send or receive certain high-value transactions or high overall payment volumes through the AZA Services, or as is otherwise required in order for us to comply with our anti-money laundering obligations under applicable laws.
Using your device: When you use AZA Services using any device (whether connected wirelessly or by a fixed line or otherwise), we may additionally collect and store device sign-on data (including but not limited to device ID) and geolocation data, in order to provide AZA Services.
Photographs: If you use certain functionalities provided by us, we may ask you to upload a picture of you (for example, the photo of your ID) in order to provide these specific services. Your face must be recognizable.
Transaction Information: When you use the AZA Services to send funds to someone else or request money from someone else, we ask you to provide information related to that transaction. This information includes the amount and type of the transaction (purchase of goods, purchase of services, or simple peer-to-peer transfer), other purchase/transactional details and the details pertaining to the identity of the third party. Also, when you send money or funds to another BFX Customer, you may be asked to provide personal details of that customer to complete the transaction. Those details may also be passed on to us from that customer. We also collect the Internet address (IP address) and other identifying information about the computer or device you use to access your BFX account or use the AZA Services, in order to help us authenticate you and detect possible instances of unauthorized transactions.
Information About You From Third Parties: In order to protect all our customers against potential fraud, we verify the information you provide with Payment Partners and/or Credit Reference and Fraud Agencies as well as information available through internet and publicly accessible social network data. In the course of such verification, we may receive personally identifiable information about you from such services. In particular, if you connect a debit or credit card or register a bank account connected with BFX Account, we may use card authorization and fraud screening services to verify that your bank or card or mobile wallet information and address match the information you supplied to AZA, and that the card has not been reported as lost or stolen.
If you send or receive high overall payment volumes or display inconsistent transactional patterns through the AZA Services, or if you have a limited transactional history with us, in some circumstances we will conduct a background check on you by obtaining information about you and your business, and potentially (if legally permitted) also about your directors, shareholders and partners, from a credit reference or a fraud agency. If you owe us money, we may conduct a credit check on you by obtaining additional information about you from a credit reference or a fraud agency, to the extent permitted by law. AZA, at its sole discretion, reserves the right to periodically retrieve and review a business and/or consumer credit report supplied by such credit reference or a fraud agency for any account, and reserves the right to close an account based on information obtained during this credit review process.
If you use your BFX Account to receive payments for goods or services, we may also collect public information about your business and your behavior on social media platforms (such as the e-mail address and the number of “likes” and “followers”), to the extent relevant to confirm an assessment of your transactions and/or your business, including its size and the size of its customer base.
Information About You from Other Sources: We may also collect information about you from other sources, including from other entities of the group to which AZA belongs, other companies (subject to their privacy policies and applicable law), and from other accounts we have reason to believe you control (whether in part or in whole).
Additional Verification: If we cannot verify the information that you provide, or if you request a withdrawal to an account, payment instrument or digital wallet not previously used by you, we may ask you to upload or send us additional confirmations or to answer additional questions online to help verify your information.
Website Traffic Information: Because of the way Internet communication standards work, when you arrive at or leave the BFX Website, we may automatically receive the web address of the site that you came from or are going to. We also collect information on which pages of our website you visit, IP addresses, the type of browser you use and the times you access our website.
You are free to decline our Cookies if your browser or browser add-on permits, unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with your use of our website and AZA Services.
Communications: When you communicate with us for customer service or other purposes (e.g., by emails, phone calls, tweets, etc.), we may retain such information and our responses to you in the records of your account, for the purpose of proof of commercial transactions and communications.
Questionnaires, Surveys, Sweepstakes and Profile Data: From time to time, we offer optional questionnaires, surveys and sweepstakes to our users for such purposes as collecting demographic information or assessing users' interests and needs. If we collect personally identifiable information from our users in these questionnaires, surveys, and sweepstakes, the users will be given notice of how the information will be used prior to their participation in the survey, questionnaire or sweepstake.
3. How We Use the Information We Collect
Internal Uses: We collect, store and process your information on servers located in the European Union. Our primary purpose for collecting your information is to provide you with a safe, smooth, efficient, and customized experience. You agree that we may use your personal information to:
- Process transactions and provide the AZA Services;
- Verify your identity, including during account creation and password reset processes;
- Resolve disputes, collect fees, and troubleshoot problems;
- Manage risks, or to detect, prevent, and/or remediate fraud or other potentially illegal or prohibited activities;
- Detect, prevent or remediate violations of policies or applicable user agreements;
- Provide you with customer support services;
- Improve the AZA Services by customizing your user experience;
- Measure the performance of the AZA Services and improve their content and layout;
- Manage and protect our information technology infrastructure;
- Provide targeted marketing and advertising, provide service updates, and deliver promotional offers based on the communication preferences you have defined for your BFX Account (please refer to the section "Our Contact with BFX Customers" below) and your activities when using the AZA Services; and
- Perform creditworthiness and solvency checks, compare information for accuracy, and verify it with third parties.
- Questionnaires, Sweepstakes, Surveys and Profile Data: If you choose to answer our optional questionnaires or surveys, we may use such information to improve AZA Services, send you marketing or advertising information, manage the sweepstakes, or as otherwise explained in detail in the survey itself.
Our Contact with BFX Customers: We communicate with our users on a regular basis via email and chats to provide requested services. We may also communicate with our users by phone to:
- Resolve customer complaints or claims made by users;
- Respond to requests for customer service;
- Inform users if we believe their accounts or any of their transactions have been used for an illegitimate purpose;
- Confirm information concerning a user's identity, business or account activity;
- Carry out collection activities;
- Conduct customer surveys; and
- Investigate suspicious transactions.
We use your email or physical address to confirm your opening of a BFX Account, to send you notice of payments that you send or receive through BFX, to send you information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be informational in nature, and not promotional.
We can also use your email address to send you other types of communications that you can control, including "news”, “customer surveys” and “notice of special promotions”. You can choose whether to receive all or none of these communications when you complete the registration process, or at any time thereafter, by logging in to your account and then selecting settings, and updating your communication preferences.
In connection with independent audits of our financial statements and operations imposed by applicable law, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.
If you don't wish to receive marketing communications from us, or to participate in our ad-customization programs, simply update your preferences.
5. How We Share Information with Other BFX Users
If you are a registered BFX User and you are sending funds or transacting with another registered BFX User, as a part of the transaction, some personal information of both parties (name, e-mail address) may be shared as a part of transaction notification. However, your card number, bank account and other financial information will not be revealed to anyone whom you have paid or who has paid you through the AZA Services or third parties that use the AZA Services, except with your express permission or if we are required to do so pursuant to credit card rules, a court order or other applicable legal obligation.
We work with third parties to enable them to accept or facilitate payments from or to you using the AZA Services. In doing so, a third party may share information about you with us such as your email address or phone number, when a payment is sent to you or when you are attempting to pay that third party. We use this information to confirm that you are a BFX Customer and to ensure that we are able to properly authenticate and authorize the transaction and to complete a payment order, or (where a payment is sent to you by a third party) to send you a notification that you have received a payment. Please note that third parties you receive funds from, may have their own privacy policies, and AZA is not responsible for their operations, including, but not limited to, their information practices.
6. How We Share Information with Other Third Parties
Just like most banks or financial/payment service providers, AZA works with third-party service providers which provide important functions to us that allow us to be an easier, faster, and safer way to make payments, and other business partners. We need to disclose user data to them from time to time, so that the services can be performed.
In order to provide the AZA Services, some information we collect from or about you, may be required to be transferred to other AZA group entities or other entities, in their capacity as payment providers, payment processors or account holders (or similar capacities). You acknowledge that according to their local legislation, such entities may be subject to laws, regulations, inquiries, investigations, or orders which may require the disclosure of information to the relevant authorities of the relevant country.
Specifically, you consent to and direct AZA to do any and all of the following with your information:
- Disclose necessary information to: the police and other law enforcement agencies; security forces; competent governmental, intergovernmental or supranational bodies; competent agencies, departments, regulatory authorities, self-regulatory authorities or organizations and other third parties, including BTC Africa Group of companies, that (i) we are legally compelled and permitted to comply with, including but without limitation the Luxembourg laws of 24 July 2015 on the US Foreign Account Tax Compliance Act (“FATCA Law”) and 18 December 2015 on the OECD common reporting standard (“CRS Law”); (ii) we have reason to believe it is appropriate for us to cooperate with governmental agencies or payment or processing partners in investigations of fraud or other illegal activity or potential illegal activity, to the fullest extent permitted by law, or (iii) to conduct investigations of violations of our User Agreement (including without limitation, your funding source or mobile wallet or credit or debit card provider).
- If you are covered by the FATCA or CRS Law, we are required to give you notice of the information about you that we may transfer to various authorities. If we believe your account may be subject to these regulations, we may notify you separately.
- We and other organizations, including financial institutions that cooperate with AZA, may also share, access and use (including from other countries) necessary information (including, without limitation the information recorded by fraud prevention agencies) to help us and them assess and to manage risk (including, without limitation, to prevent fraud, money laundering and terrorist financing).
- Disclose necessary information in response to the requirements of other financial institutions, credit card associations or a civil or criminal legal process.
- Disclose necessary information to the payment processors, auditors, customer services providers, credit reference and fraud agencies, financial products providers, commercial partners, marketing and public relations companies, operational services providers, group companies, agencies, marketplaces and other third parties listed here. The purpose of this disclosure is to allow us to provide AZA Services to you.
- Disclose necessary information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
- Disclose aggregated (i.e.: anonymized) statistical data to our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in a certain city. However, this aggregated information is not tied to personal information.
- Share necessary Account Information with unaffiliated third parties (listed below for their use for the following purposes:
- Fraud Prevention and Risk Management: to help prevent fraud or assess and manage risk, as permitted by applicable law.
- Customer Service: for customer service purposes, including to help service your accounts or resolve disputes (e.g., billing or transactional).
- Legal & Compliance service providers: to help us comply with anti-money laundering and counter-terrorist financing verification requirements, as permitted by applicable law.
- Service Providers: to enable service providers under contract with us to support our business operations, namely fraud prevention, bill collection, marketing, customer service and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
7. Cross Border Transfers of your Information
AZA is committed to adequately protecting your information regardless of where the data resides and to providing appropriate protection for your information if your data is transferred outside of the EEA. In this regard, transfers to non-EEA Member States may notably be carried out on the basis of adequate contractual arrangements, a copy of which may be obtained by you by simple request sent to AZA.
8. Your Use of Information and AZA Services
In order to facilitate the transactions between BFX Users, AZA Services allows you limited access to other users' contact information. As a user, you may have access to another user’s ID, email address and other contact information as a part of transaction notification and confirmation process.
You agree that, with respect to other users' personally identifiable information that you obtain through the AZA Services or through a AZA-related communication or AZA-facilitated transaction, you will only use this information for: (a) BFX-related communications that are not unsolicited commercial messages, (b) ancillary actions in relation to the BFX payments or the transactions for which BFX has been used (e.g. insurance, delivery and fraud complaints), and (c) any other purpose that such user consents to after adequate disclosure of the purpose(s).
In all cases, you must provide users with the opportunity to remove their data from your database and review any information you have collected about them. More generally, you must comply with all applicable privacy regulations, in particular as they relate to the sending of marketing emails.
AZA does not tolerate spam. We strictly enforce our Anti-Spam Policy. To report AZA-related spam to AZA, please contact us.
9. Information Security
AZA is committed to handling your customer information with high standards of information security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfil their job responsibilities, and who have committed themselves to confidentiality undertakings.
The security of your BFX Account also relies on your protection of your BFX password. You may not share your BFX password with anyone. AZA representatives will never ask you for your password, so any email or other communication requesting your password should be treated as unauthorized and suspicious and forwarded to us. If you do share your BFX password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and changing your Profile settings, and also contact us right away.
10. Accessing and Changing Your Information
You can review the personal information you have provided to us and make any desired changes to such information, or to the settings for your BFX Account, at any time by logging in to your account on the BFX Website. If you close your BFX Account, we will mark your account in our database as "Closed", but will keep your Account Information in our database for a period of 10 years. This is for instance necessary in order to fulfill our data retention requirements to comply with applicable laws and regulations, and for other legitemate business reasons, such as to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement authorities, or as required by law. The information you provide us with will not be kept for longer than necessary with regards to the purpose of its processing described above, subject to statutory retention periods imposed by applicable law.
11. Contact us and Exercising Your Rights
By writing to the above address, and subject to certain conditions set out by applicable data protection law, you may also exercise your rights to:
- object to the processing of your information;
- ask for erasure of your information within the limits permitted by applicable laws and regulations;
- ask for portability of your information ;
- object to the use of your information for marketing purposes.
Finally, you acknowledge the existence of your right to lodge a complaint with a competent data protection supervisory authority.
LAST MODIFIED: September 2019