1. Personal Data
1.1. While using Our Service, IPA may ask customers to provide certain personally identifiable information that can be used to contact or identify the customer. Personally identifiable information may include, but is not limited to: usage data. Usage Data is collected automatically when using the Service. Usage Data may include information such as customers’ mobile phone number.
2. Data protection principles
2.1. IPA is committed to processing data in accordance with its responsibilities under the relevant privacy and data protection laws such as Personal Data Protection Proclamation No. 1321/2024 of the Federal Democratic Republic of Ethiopia and Financial Consumer Protection Directive No. FCP/01/2020 Of National Bank of Ethiopia. The data protection laws requires that personal data shall be:
2.1.1. processed lawfully, fairly and in a transparent manner in relation to individuals;
2.1.2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
2.1.3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
2.1.4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
2.1.5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the law in order to safeguard the rights and freedoms of individuals; and
2.1.6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
3. Lawful purposes, fair and transparent processing
3.1. To ensure its processing of data is lawful, fair and transparent, IPA shall maintain a Register of Systems and the Register of Systems shall be reviewed at least annually.
3.2. All data processed by IPA must be done on one of the following lawful bases: consent, contract or legal obligation.
3.3. IPA shall note the appropriate lawful basis in the Register of Systems.
3.4. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
3.5. IPA shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
4. Retention of Personal Data
4.1. IPA will retain users Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain the data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
4.2. IPA will 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, or We are legally obligated to retain this data for longer time periods.
5. Transfer of Personal Data
5.1. User information, including Personal Data, is processed at the IPA's operating offices and in any other places where the parties involved in the processing are located.
5.2. Users’ consent to this Privacy Policy followed by their submission of such information represents their agreement to that transfer.
5.3. IPA will take all steps reasonably necessary to ensure that users’ data is treated securely and in accordance with this Privacy Policy and no transfer of their Personal Data will take place to another party unless there are adequate controls in place including the security of the data and other personal information.
6. Disclosure of Personal Data
6.1. If the IPA or its owners are involved in a merger, acquisition or asset sale, users Personal Data may be transferred. IPA will provide notice with the appropriate media of its choice before Personal Data is transferred and becomes subject to a different Privacy Policy.
6.2. Under certain circumstances, IPA may be required to disclose Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
6.3. IPA may disclose users’ Personal Data in the good faith belief that such action is necessary to:
a) Comply with a legal obligation
b) Protect and defend the rights or property of IPA
c) Prevent or investigate possible wrongdoing in connection with the Service
d) Protect the personal safety of Users of the Service or the public
e) Protect against legal liability
7. Security of Personal Data
7.1. IPA shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
7.2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
7.3. When personal data is deleted, this should be done safely such that the data is irrecoverable.
7.4. Appropriate back-up and disaster recovery solutions shall be in place.
7.5. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, IPA shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the appropriate authority.
8. General provisions
8.1. This policy applies to all personal data processed by IPA.
8.2. This policy shall be reviewed at least annually.