Data Privacy Policy

2. Objective

This Privacy Policy has been put in place to:

• Inform data subjects about their rights, responsibilities, and privileges.
• Ensure the protection of Client and other Stakeholder's information.
• To ensure confidentiality as much as possible.
• Take corrective action if wrongdoing is discovered.

3. Scope and Applicability

This Policy applies to all employees, clients and stakeholders of the Company. This policy highlights the basis on which personal data collected from Clients and other stakeholders shall be processed by the Company. This policy applies to the Company's website and physical contact with the Company regardless of how you access or use them. By continuing to visit our website, users of the website accepts and consent to the practices described in this policy.

4. Ownership, Review and Approval

The Head of Data Protection shall be responsible for the development and maintenance of the data protection policy. The policy shall be reviewed periodically in line with the provisions of extant Data Protection laws.

Final approval of this policy lies with the Managing Director of the Company.

5. Interpretation

• i. Personal Data: This means any information relating to an identified or identifiable natural persons (Data Subject); an identifiable natural person is one who can be identified, directly or indirectly.
• ii. Data Subject: This refers to all person who can be identified, directly or indirectly, via an identifier such as a name, an ID Number, Location data, etc.
• iii. Personal Identifiable Information (PII): This means information that can be used on its own or with other information to identify, contact or locate a single person, or to identify an individual In a context.
• iv. Processing: This means any operation or set of operations which is performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, use, disclosure by transmission, etc.

6. Policy

This Privacy Policy describes your privacy rights with respect to personal information which the Company may collect, use, store, or otherwise process when you engage our services. It applies to the Company's website and all database, applications, services, products, and physical contact with us, regardless of how you access or use them.

7. Responsibility of Data Subject

• a.Usernames, identification codes, passwords, or any other piece of information used as part of our access security measures must be treated as confidential and must not disclose to any third party.
• b.We reserve the right to disable any user identification code or password, whether chosen or allocated by the Company at any time, if in the Company's opinion, there has been non-compliance with any of the provisions of this privacy policy.
• c.All enquires, complaints or suspicion of a data breach should be forwarded to [email protected]

8. Consent

You accept this privacy policy when you give consent upon access to the Company's platforms, or use of the Company's services, features, technologies, or functions offered on our website, or visit to our office for official or non-official purposes. The Company may amend this privacy policy at any time by posting a revised version on its website or placing such notice at conspicuous points at its office.

9. Use/Processing of Data Subject's Data

During onboarding (electronically) and when you use our website, we collect information such as website visits, identification documents (driver's license, BVN, NIN, Passport, etc), documents reflecting personal information such as name, address, passport details, identification numbers, telephone number, occupation, as is necessary. In the course of carrying out our due diligence as required by our Regulators, we may also use information obtained from third parties such as friends, employers, regulators, and publicly available sources such as the press, public search engines, etc.

The Company will only collect personal data in other to give efficient, enjoyable, and secure services. We may use your information to:

• a.provide necessary services and support
• b.process applications and send notices about transactions to requisite parties
• c.verify your identity
• d.manage risk, or detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities
• e.detect, prevent, or remediate violation of laws, regulations, standards, guidelines and frameworks
• f.improve the NITDA Services by implementing aggregate customer or user preferences
• g.measure the performance of the NITDA Services and improve the content, technology and layout
• h.track information breach and remediate such identified breaches
• i.manage and protect our information technology and physical infrastructure; or
• j.contact you at any time through your provided telephone number, email address or other contact details.

10. Third-Party Disclosure

As a policy, the Company does not share its Clients or other stakeholder's information with third parties (unless with prior obtained approval of the data subject) except for website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also disclose the personal information of Data subjects under Regulatory requirements. However, non-personally identifiable visitor information may be provided to other parties in some limited cases.

11. Data Confidentiality Rights

• a.Your information is regarded as confidential and will not be divulged to any third party, except under legal and/or regulatory conditions.
• b.You have the right to request sight of, and copies of any and all information we keep on you, if such requests are made in compliance with the Freedom of Information Act and other relevant enactments.
• c.You also have the right to request for the correction of information we keep on you.
• d.While the Company is responsible for safeguarding the information entrusted to us, you are also required to practice appropriate security measures such as non-sharing of passwords and other platform login details.

12. Cookies

Cookies are small text files stored on your computer or mobile devices whenever you visit a website. Cookies have many uses, such as memorizing your preferences to tailor your experiences while on our site– or to help us analyze our website traffic.

The Company uses cookies to improve your experience while on its website. We would like to let you know a few things about our cookies:

• Some cookies are essential to access certain areas of this site;
• We use analytics cookies to help us understand how you use our site to discover what content is most useful to you

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