3) Third Party Links:
Account: a unique account created for users to access our Service
Affiliate: an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority
Application: the software program provided by the Company downloaded by user on any electronic device, namely Ping Up
Company: means the same as “Ping Up”, “We”, “us”, or “our”
Customer: the individual, company, or entity accessing or using the Service
Data: stats or facts collected that can be used to calculate, reason, or analyse
Device: any device which can be used to access Ping Up
Personal Data: means any information about an individual from which that person can be identified
Service: the Application and its contents
Technical Data: means recorded information of a scientific or technical nature
Usage Data: data collected automatically either generated by the use of Service or fromService infrastructure itself
You: any individual, company, or entity accessing or using the Service
5) Collecting Data:
Types of Data Collected:
Whilst using Ping Up’s Services, Ping Up may ask the Customer to provide certain personally identifiable information (Personal Data) that can be used to contact or identify the Customer. Personally identifiable information may include but is not limited to:
Identity data: full name, date of birth, nationality, country of residence, gender, occupation, image of Identity Card
Contact data: email address, billing address, residential address, telephone number
Financial data: Bank name, Account number and IBAN.
Transaction details: payments to and from you and other details of products and services you have purchased from Ping Up.
Technical data: Information relating to your device, such as IP address, device model, OS type & version, timezone settings, geo-location details, network information like details and logs of when, where and how you used the service; browser information such as type, version and browser plug-in, and other technology on the devices you use to access this website.
Profile data: username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses
Usage data: how you use our website, products, and services
Marketing and communications data: receiving marketing from us
We may collect, use, and share Aggregated Data. Such Data will not directly or indirectly reveal your identity.
Ping Up may ask the Customer to provide further personal data that can be used to assist the Customer when purchasing. Such information may include but is not limited to:
Source of Income
Risk profile questions
6) How is Personal Data collected?
Direct Interactions: You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
Apply for our products or services
Create an account on our application
Respond to an email requesting for your details
Subscribe to our services or publication
Request marketing to be sent to you
Enter a competition, promotion, or survey
Give us feedback or contact us
Automated Technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources such as Google
Identity and Contact Data from data brokers or aggregators such as Refinitiv Ltd which may based inside or outside Pakistan.
Identity and Contact Data from publicly available sources including but not limited to the respective jurisdiction’s relevant authorities’ sanction lists and international sanction lists.
7) How your personal data is used:
We may use your Personal Data for the following purposes:
Your data will always be used for legitimate interest or where we need to comply with a legal obligation.
To provide, maintain, monitor and enhance our services
To fulfill the performance of a contract with you
To manage your account including registration of services and allowing access to various functionalities within the application
To process and deliver your order including a) managing payments, fees and charges and b) collect and recover any money owed to Ping Up.
To perform KYC checks on the Customer to enable a risk assessment
To manage our relationship by notifying you of changes in our Policies and asking for your feedback
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
To make suggestions and recommendations to you about goods or services that may be of interest to you
8) Sharing of your personal data:
With service providers: to monitor and analyse our Services offered to you.
With business partners to offer you certain products, services or promotions.
For business transfers associated with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or of a portion of the business to another company.
With other users, upon your consent when you share your information on a public forum within the application.
For other purposes, upon your consent.
With other third parties for the purposes of completing the transaction requested by you the Customer.
With law enforcement agencies, if ever requested
9) Change in Purposes of collection of data:
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
10) Data retention:
We may also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our service offered to you, or we are legally obligated to retain this data for longer time periods.
11) Your legal rights:
Under certain circumstances, you have rights under data protection laws in relation to your personal data such as the following:
Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
Request access to your personal data that we hold
Request correction of your personal data
Request erasure of your personal data as long as we are no longer legally obliged to hold that data and you cease to be a user of the services
Request restriction of processing your personal data
Right to withdraw consent
If you wish to exercise any of these rights please contact us.
12) Contact Us:
We are responsible for addressing questions and concerns in relation to this Privacy Notice. If you have any questions about the terms, including any requests to exercise your legal rights, please contact us email@example.com.
13) Third Parties:
The following third parties may have access to your personal data, including but not limited to:
Idenfo Limited: Ping Up uses Idenfo, a Third Party for Know Your Client (KYC) services. More information on how Idenfo processes your personal data and your data protection rights, is available at: https://www.idenfodirect.com/wp-content/uploads/2021/08/Idenfo-Direct-Privacy-Policy.pdf
NIFT PVT Limited: Ping Up uses NIFT to process your transactions. More information on how NIFT processes your personal data and your data protection rights is available at: https://www.nift.pk/NIFTeTRUST/NIFTeTRUST-Network-(NTN)/PRIVACY-POLICY-(1).aspx
The various funds you may choose to subscribe to.
14) Other information:
Our Services are not intended for use by Children under the age of 18. We do not knowingly collect personally identifiable information from Children. If you become aware that a Child has provided us with Personal Data, please contact us