Privacy policy
Last Updated: October 10, 2023
1. Introduction
Brass takes the privacy of your information very seriously. This Policy explains how and for what purposes we may use the information collected from you via the Site.
Additional information on our Privacy Policy may be found on our Sites and within Frequently Asked Questions (FAQs) as set out on the Sites.
Please read this Policy carefully. By using the Site and any services we offer via the Site, you are agreeing to be bound by this Policy with respect to the information collected about you via this Site.
You may use the Site only for lawful purposes. You may not use the Site:
- In any way that breaches any applicable local, national or international law or regulation.
- In any way that is unlawful or fraudulent or has any unlawful or fraudulent purpose or effect.
- For the purpose of harming or attempting to harm any person and in any way.
- To bully, insult, intimidate or humiliate any person.
- To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards.
- To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).
- To knowingly transmit any data, send or upload any material that contains viruses, trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other programs or similar computer code designed to adversely affect the operation of any computer software or hardware.
- Not to reproduce, duplicate, copy or re-sell any part of our Site as this is in contravention of the provisions of our terms of use.
- Not to access without authority, interfere with, damage or disrupt:
- any part of our Site;
- any equipment or network on which our Site is stored; or
- any software used in the provision of our Site.
2. Personal information collected
- name, username, gender, date of birth;
- email address, postal address, telephone number;
- your interests;
- account number, card number and expiry date
- or any other information that may be required
3. Use of collected information
We may also contact you via electronic means to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, or as otherwise necessary to service your account.
Conclusively, we may contact you with the information provided as necessary to enforce our policies, applicable law, or any agreement we may have with you. When contacting you via phone, to reach you as efficiently as possible we may use, and you consent to receive, autodialled or pre-recorded calls and text messages. Where applicable and permitted by law, you may decline to receive certain communications.
4. Record Retention
The broad categories of AML/CFT-related records are:
- Customer identification and verification documents.
- Transaction records, including currency transaction reports.
- Suspicious transaction reports, together with supporting documentation.
- AML/CFT-related records may be maintained by way of original documents, stored in microfiche, and in computerized or electronic form, subject to the provisions of the law on what is acceptable as evidence.
5. Sharing collected information
In order for services to be provided, we may share some necessary details about you with the Business Partners, and according to our business dynamics and the continued provision of efficient services to you, we may, from time to time, transfer such details to other Business Partners as we deem fit. However, under any circumstance, we will take steps to ensure that your privacy rights continue to be protected.
We may transfer your personal information to any other third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected.
In addition, we may pass your information onto one of our carefully selected business partners or to other carefully selected third parties to enable them to send you information which may be of interest to you but only if you have given us permission to do so. You can stop receiving such mail whenever you choose by unsubscribing via the link provided.
Other than as set out above, we will not disclose any of your personal information without your permission unless we are required by law to do so (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime).
6. Information automatically collected from your computer
- Log files/IP addresses: When you visit the Site, our web server automatically records your IP address. This IP address is not linked to any of your personal information. We use IP addresses to help us administer the Site and to collect demographic information for aggregation purposes.
- Other technologies including pixel tags, web beacons, and clear gifs: These may be used in connection with some Site pages, downloadable mobile applications and HTML-formatted email messages to measure the effectiveness of our communications, the success of our marketing campaigns, to compile statistics about usage and response rates, to personalize/tailor your experience while engaging with us online and offline, for fraud detection and prevention, for security purposes, for advertising, and to assist us in resolving account holders’ questions regarding the use of our Site.
- Aggregated and de-identified data: Aggregated and De-identified Data is data that we may create or compile from various sources, including but not limited to accounts and transactions. This information, which does not identify individual account holders, may be used for our business purposes, which may include offering products or services, research, marketing or analysing market trends, and other purposes consistent with applicable laws.
- Through your browser or device: Certain information is collected by most browsers and/or through your devices, such as your Media Access Control (MAC) address, device type, screen resolution, operating system version and internet browser type and version. We use this information to ensure Sites function properly, for fraud detection and prevention, and security purposes.
7. Cookies
- so that you will not have to re-enter your details each time you visit the Site to track how our Site is used and to improve and update our content
- store your preferences
- customise elements of the layout and/or content of the site for you
- collect statistical information about how you use the site so that we can improve the site
8. Advertisement and information about other products and services
Brass advertises online (e.g., pages within our Sites and mobile apps, through the Company’s managed social media presence, and on other sites and mobile apps not affiliated with Brass) and offline (e.g. in banking centres, through call centres, and direct marketing). In order to understand how our advertising performs, we may collect certain information on our Sites and other sites and mobile apps through our advertising service providers using cookies, IP addresses, and other technologies. The collected information may include the number of page visits, pages viewed on our Sites, search engine referrals, browsing activities over time and across other sites following your visit to one of our Sites or Apps, and responses to advertisements and promotions on the Sites and on sites and apps where we advertise.
Brass uses the information described in this Policy to help advertise our products and services. We use such information to:
- Present tailored ads to you, including;
- Banner ads and splash ads that appear as you sign on or off of your online accounts on our Sites, within mobile banking and other mobility applications;
- E-mail, postal mail, and telemarketing;
- On other sites and mobile apps not affiliated with Brass;
- Analyse the effectiveness of our ads; and
- Determine whether you might be interested in new products or services
Advertising on third party sites and mobile apps: Brass contracts with advertising companies to advertise our products and services on sites and mobile apps not affiliated with us. We may use Aggregated and De-identified Data and information provided by you to these third-party sites and mobile apps to select which of our advertisements or offers may appeal to you, display them to you and monitor your responses. Third-Party Sites and mobile apps are not subject to Brass Privacy Policy. Please visit the individual sites and mobile apps for additional information on their data and privacy practices and opt-out policies.
9. Changes to your details
10. Use of forums or chat rooms
11. Security
We have implemented technology and policies to safeguard your privacy from unauthorised access and improper use. We use secure server software (SSL) to encrypt any financial information you need to input before it is sent to us.
12. Linking to third-party websites and other aggregation website
We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our Site and recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
Using Other Aggregation Websites: Other companies offer aggregation websites and services that allow you to consolidate your financial account information from different sources (such as your accounts with us or with other financial institutions) so that you can view all your account information at one online location. To do this, an aggregation provider may request access to personal information, such as financial information, usernames and passwords. You should use caution and ensure that the aggregator company has appropriate policies and practices to protect the privacy and security of any information you provide or to which they are gaining access. We are not responsible for the use or disclosure of any personal information accessed by any company or person to whom you provide your Site username and password.
If you provide your Site username, password or other information about your accounts with us to an aggregation website, we will consider that you have authorized all transactions or actions initiated by an aggregation website using access information you provide, whether or not you were aware of a specific transaction or action. If you decide to revoke the authority you have given to an aggregation website, we strongly recommend that you change your password for the Site to ensure that the aggregation website cannot continue to access your account.