Introduction

Instant Payments Namibia (IPN) ("we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our services.

As a payment infrastructure provider operating under the mandate of the Bank of Namibia, we adhere to the highest standards of data protection and comply with applicable Namibian data protection laws and regulations.

1. Information We Collect

1.1 Personal Information

We may collect personal information that you provide directly to us, including:

• Name and contact information (email address, phone number, physical address)
• Organization or business details (for institutional users)
• Financial institution information
• Professional credentials and documentation
• Communications with us (inquiries, feedback, support requests)

1.2 Automatically Collected Information

When you access our website, we automatically collect:

• Device and browser information
• IP address and location data
• Usage data and analytics
• Cookies and similar tracking technologies

1.3 Transaction Data

For platform participants, we collect transaction-related information necessary for payment processing, reconciliation, and regulatory compliance.

2. How We Use Your Information

We use the collected information for the following purposes:

• Service Delivery: To operate and maintain the IPN platform and provide payment infrastructure services
• Communication: To respond to inquiries, provide customer support, and send important updates
• Compliance: To meet regulatory obligations and comply with legal requirements
• Security: To detect, prevent, and address fraud, security threats, and technical issues
• Analytics: To understand how our services are used and improve user experience
• Business Operations: To evaluate partnership applications and manage business relationships

3. Information Sharing and Disclosure

We do not sell your personal information. We may share your information with:

• Regulatory Bodies: Bank of Namibia and other authorized regulatory authorities
• Platform Participants: Banks, financial institutions, and payment service providers connected to the IPN network (limited to necessary transaction data)
• Service Providers: Third-party vendors who assist in operating our platform (under strict confidentiality agreements)
• Legal Requirements: When required by law, court order, or governmental authority
• Business Transfers: In connection with a merger, acquisition, or sale of assets (with continued privacy protection)

4. Data Security

We implement robust security measures to protect your personal information, including:

• Encryption of data in transit and at rest
• Secure access controls and authentication mechanisms
• Regular security assessments and audits
• Employee training on data protection and confidentiality
• Incident response and breach notification procedures

While we strive to protect your information, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security.

5. Your Rights

Under applicable data protection laws, you have the right to:

• Access: Request copies of your personal information
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your personal information (subject to legal obligations)
• Objection: Object to certain processing activities
• Restriction: Request restriction of processing in certain circumstances
• Portability: Request transfer of your data to another service provider
• Withdraw Consent: Withdraw consent for processing where consent was the legal basis

To exercise these rights, please contact us using the information provided below.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes outlined in this policy, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods vary based on:

• Regulatory and legal requirements (typically 7-10 years for financial records)
• The nature of the information and purpose of collection
• Business and operational needs

7. International Data Transfers

Your information may be transferred to and processed in countries outside Namibia. When we transfer data internationally, we ensure appropriate safeguards are in place, including standard contractual clauses and ensuring the recipient country provides adequate data protection.

8. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will take steps to delete such information.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience on our website. For detailed information about our use of cookies, please refer to our Cookie Policy.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on our website with a new "Last Updated" date. Your continued use of our services after changes become effective constitutes acceptance of the updated policy.

11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

12. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Republic of Namibia. Any disputes arising from this policy shall be subject to the exclusive jurisdiction of Namibian courts.