DATA PROTECTION AND PRIVACY STATEMENT ("PRIVACY STATEMENT")


A. Our Commitment to Protect Your Privacy

1. At First Discount House we recognise the importance of personal information entrusted to us. It is one of our fundamental responsibilities as a discount house to ensure that we protect the information entrusted to us by our clients

B. Scope of Privacy Statement

2. This Privacy Statement relates to the collection, use and disclosure of Personal Data, including special or sensitive Personal Data, by First Discount House (Discount House, we or our).

C. Interpretation

3. In this Privacy Statement, unless the context otherwise requires ‐

Personal data means any information which identifies an individual person or from which an individual person is identifiable.
Data controller means a person who, acting either alone or in common with other persons, determines the purpose for which, and the manner in which, any personal data is processed, or is to be processed and thus, controls and is responsible for the keeping and using of personal data, and the term includes a person who collects, processes or stores personal data;
Data subject means a person from whom data relating to that person is collected, processed or stored by a data controller;
processing of data means any operation or set of operations which is performed upon data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction;

D. Discount House as a Data Controller

We are a data controller under the Electronic Transactions and Cyber Security Act, 2016. Our head office address is: NO. 8 Victoria Avenue North
P.O Box 512
Blantyre
Malawi

E. How to contact us

Please contact us if you have any questions about our Privacy Statement or information we hold about you:

Call Centre Number: 525
E-mail Address:  firstdiscounthouse@fdh.co.mw

F. What personal data we collect about you and the source

Personal Data that we will collect from you includes but not limited to:

We may also collect your Personal Data from other sources, including but not limited to credit bureaus, credit reference agencies, your employers, your guarantors and your joint account holders.

G. Purposes for which we may process your Personal Data

To enable us to fulfil the contract between us for the products or services you have requested, we need to process your personal data for purposes including the following:

  1. processing applications for products and services, effecting payments, transactions, updating records and completing instructions or requests;
  2. providing products and services (including electronic services);
  3. assessing suitability for products and services;
  4. credit assessment, including conducting credit checks and setting credit limits;
  5. operational purposes;
  6. statistical purposes;
  7. establishment, continuation and management of relationships and accounts.

For some purposes in connection with the service you have requested, we have a legal or regulatory obligation to process your Personal Data. These purposes include:

  1. the prevention, detection, investigation and prosecution of crime in any jurisdiction (including, without limitation, money laundering, terrorism, fraud and other financial crime);
  2. identity verification and due diligence checks;
  3. enforcing obligations, including without limitation the collection of amounts outstanding from you and your provision of security for the facilities;
  4. to comply with local or foreign law, regulations, directives, judgments or court orders, government sanctions or embargoes, reporting requirements under financial services legislation, and demands of any authority, regulator, tribunal, enforcement agency, or exchange body.

We may also process your Personal Data where it is in our legitimate interests to seek professional advice, including, in connection with any legal proceedings (including any prospective legal proceedings), for obtaining legal advice or for establishing, exercising or defending legal rights.

If you do not provide us with Personal Data we need to meet our legal and regulatory obligations or to enter into an agreement with you, we may not be able to provide you with the products or services you have requested.

H. To whom we may disclose Personal Data

Any member of the Discount House, including our officers, employees, agents and advisers, may disclose your Personal Data to any of the following parties for any of the purposes specified above:

  1. any member of the Discount House anywhere in the world, including any officer, employee, agent or director;
  2. professional advisers (including auditors), third party service providers, agents or independent contractors providing services to support our business;
  3. our business alliance partners who may provide their product or service to you;
  4. a merchant or a member of a card association where the disclosure is in connection with use of a card;
  5. upon your death or mental incapacity, your legal representative and their legal advisers, and a member of your immediate family for the purpose of allowing him/her to make payment on your account;
  6. any security provider or any person authorised to operate your account and to act on your behalf in giving instructions, to perform any other acts under our agreement or use any product;
  7. any person to whom disclosure is allowed or required by local or foreign law, regulation or any other applicable instrument;
  8. any court, tribunal, regulator, enforcement agency, exchange body, tax authority, or any other authority (including any authority investigating an offence) or their agents;
  9. any debt collection agency, credit bureau or credit reference agency, rating agency correspondents, insurer or insurance broker, direct or indirect provider of credit protection and fraud prevention agencies;
  10. any financial institution to conduct credit checks, anti-money laundering related checks, for fraud prevention and detection of crime purposes;
  11. anyone we consider necessary to facilitate requests for services or applications for products with any member of the Discount House;
  12. anyone we consider necessary in order to provide services in connection with a product;
  13. any actual or potential participant or sub-participant in relation to any of our obligations in respect of any agreement, assignee, novatee or transferee (or any officer, employee, agent or adviser of any of them) located in any jurisdiction.

I. Security

The security of your Personal Data is important to us. The Discount House has technical and organisational security measures in place to safeguard your Personal Data. Regardless of where Personal Data is transferred, we take all steps reasonably necessary to ensure that personal data is kept securely.

You should be aware that the Internet is not a secure form of communication and sending us any Personal Data over the Internet carries with it risks including the risk of access and interference by unauthorised third parties. Information passing over the Internet may be transmitted internationally (even when sender and recipient are located in the same country) via countries with weaker privacy and data protection laws than in your country of residence.

J. Other Terms and Conditions

There may be specific terms and conditions in our product agreements that govern the collection, use and disclosure of your Personal Data. Such other terms and conditions must be read in conjunction with this Privacy Statement.

J. Retention

We retain your personal data in line with our legal and regulatory obligations and for business and operational purposes.

L. Automated Decisions and Profiling

We may use profiling, including behavioural analysis, to assist us to provide you with better services, to make decisions and to prevent money laundering, terrorism, fraud and other financial crime, for example using profiling may help us to try and detect whether use of your credit card may be fraudulent. If any profiling will result in an automated decision relating to you, we will let you know and you will have the right to discuss the decision with us.

J. Retention

We retain your personal data in line with our legal and regulatory obligations and for business and operational purposes.

M. Marketing

We may use your Personal Data:

  1. to conduct market research and surveys with the aim of improving our products and services;
  2. for marketing purposes, promotional events, competitions and lucky draws.

We process your Personal Data for these purposes because it is in the interest of our business to do so with the intention of improving our products and services and generating business. We will not send you marketing material if you have specifically asked us not to do so. You have the right to opt out of receiving marketing material at any time. To do so please contact your branch or relationship manager. If you ask us not to send you marketing material or other promotional or research material, we may need to retain a record that you have asked us not to do so to ensure that you do not receive anything further.

N. Monitoring

To the extent permitted by law, we may record and monitor your electronic communications with us to ensure compliance with our legal and regulatory obligations and internal policies for the purposes outlined above.

N. Your Rights

Subject to applicable law, regulations and/or discount house industry guidelines, you may have the following rights:

  1. Right to be informed
    Your right to be informed is met by the provision of this Privacy Statement, and similar information when we communicate with you directly ‐ at the point of contact.
  2. Right of access
    You have the right to request a copy of the personal data processed in relation to you. The Discount House may be allowed by law to charge a fee for this.
  3. Right to rectification
    You have the right to ask us to rectify any inaccurate data that we hold about you.
  4. Right to erasure ('right to be forgotten')
    You have the right to request that we erase Personal Data about you that we hold. This is not an absolute right, and depending on the legal basis that applies, we may have overriding legitimate grounds to continue to process the data.
  5. Right to object
    You have the right to object to processing of personal data about you on grounds relating to your particular situation. The right is not absolute and we may continue to use the data if we can demonstrate compelling legitimate grounds. If you have any concerns about how we process your personal data, please discuss this at your branch or with your Relationship Manager. We may not be able to offer you services if you do not want us to process the Personal Data we consider it necessary to process to provide the services.
  6. Restriction You have a right to restrict how your Personal Data is processed in certain cases, such as when the accuracy of your Personal Data is contested. If you have any concerns about how we process your Personal Data, please discuss this at your branch or with your Relationship Manager.

P. Complaints

If you have a complaint in relation to the processing of your Personal Data and you are not happy with the way we deal with it, please discuss this with any of the Discount House's Call Centre Agents or write to the above e-mail address or visit the nearest branch.

Q. Changes to this Privacy Statement

This Privacy Statement may be updated from time to time and where this happens, we shall give you notification by any means of either electronic mail or announcements on our website or otherwise.

R. Linked Websites

Our Privacy Statement does not apply to third-party websites where our online advertisements are displayed or to linked third-party websites which we do not operate or control.