Notification of Changes:
Information We Collect
To use the AZA Services, you must provide your designated contact’s name & email address, business name, business address, business phone number, incorporation certificate and incorporation documents reflecting the directors and shareholders, the identification document of the directors and shareholders, proof of address of directors and shareholders or other information to be determined by AZA from time to time. We may also ask you to choose different security questions to answer.
Using your device:
When you use AZA Services using any device (whether connected to AZA 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.
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).
Website Traffic Information:
Because of the way Internet communication standards work, when you arrive at or leave the AZA 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.
Cookies, Web Beacons, Local Storage and Similar Technologies:
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.
When you communicate with us for customer service or other purposes (e.g., by emails, phone calls, 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.
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, customized experience and in Complying with applicable laws and regulations, including cooperating with relevant authorities and regulators.
You agree that we may use your personal information to:
- Verify identity and conduct screening, including during account creation and or password reset processes;
- Manage risks, Detect, prevent or remediate violations of policies or applicable user agreements;
- Planning, performing and managing the business relationship with Users;
- 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 AZA account (please refer to the section “Our Contact with AZA Customers” below) and your activities when using the AZA Services; and
- 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 AZA 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;
- Conduct customer surveys; and
- Investigate suspicious transactions.
We use your email or physical address to confirm your 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 unsubscribe.
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 carry out our services to our customers. 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 service providers, payment providers or payment processors (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 any of the AZA 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 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 or a civil or criminal legal process.
- Disclose necessary information to the payment processors, auditors, services providers 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.
Cross Border Transfers of your Information
AZA is committed to adequately protect 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.
AZA is committed to handling 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 AZA account also relies on your protection of your AZA password. You may not share your AZA 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 AZA 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.
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 AZA account, at any time by logging in to your account on the AZA website. If you close your AZA 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 fulfil our data retention requirements to comply with applicable laws and regulations, and for other legitimate 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
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.