•★INTRODUCTION:
At Africadataplan Limited (Africadataplan), the privacy of our (prospective) customers, users of our services and their Personal Data is of utmost importance to us. In line with our resolution, wehave developed this Privacy Policy to explain our privacy practices, particularly regarding how we collect, process, retain, share and protect your Personal Data when you visit our website, premises or use our digital platforms (collectively, "the Platform" or "Services") as well as your rights as a data subject. This Privacy Policy constitutes our commitment to protecting user privacy and compliance with the relevant data protection laws on all our platforms. It is designed to provide information regarding ourprivacy practices and help you understand how we handle your data, in full compliance with the provisions of the Nigeria Data Protection Act, 2023 and other applicable data protection regulations.
►1. Lawful basis for processing your data
Depending on our interactions with you, our legal basis forprocessing your personal data may be one of the following:
• For the performance of a contract, we have or are about to enter with you
• Based on your consent; or
• For our legitimate business interest or that of a third party.
►2. Consent
You give your consent to our processing of your personal data when you access our platforms or, when you accept our cookies policy; or in particular, as you use the services offered on our website and digital platforms or visit any of our offices and submit your data for official or non- official purposes.
►3. What Personal Data do we collect?
We collect Personal Data about you when you use the services offered on our website and digital platform, including the following:
•1. Sign-up information: When you register to use the services offered on our digital platform, we will collect Personal Data as necessary to offer and provide the service you request. Depending on the service you choose, in line with regulatory requirements for Know Your Customer (KYC) purposes, we may require that you provide us with your name, age, mother's maiden name, gender, birthday, facial photo, residential address, ID information (photo, number), utility bill, email address, mobile number, to create an account.
We will also require your NIN and/or your BVN in line with regulation and in furtherance of our KYC Computation processes. We may also require you to provide additional, necessary personal details kas you use our services.
•2. Transaction information: When you use our digital platform to send and receive money, make purchases from merchants, pay bills, we collect information about the transaction, as well as other associated information as necessary to offer and fulfil the service (like transaction receipts W) that we are obliged to; such as: the amount sent or received, amount paid for products or services, merchant information including information about your device and geolocation.
•3. Participant Personal Data: When you use our services, we may collect Personal Data about the other participants associated with the transaction, including your phone Contacts with your Consent, so you can easily transact with your friendsand Contacts and enable instant messaging (IM). We collect Personal Data such as name and financial account information about the participant who is receiving money from (or sending money to) you, when you send or receive money through the Services.
•4. Image Information: We may collect your image (upload, storage, and use) information to support account opening, such as uploading your portrait. We may also collect information from your images when you use our customer support to upload evidence such as statements and checks. In addition, we may collect your image information in connection with regulatory KYC purposes. When you visit any of our offices as well, our CCTV cameras may also process your images.
•5. Information from other sources: We may collect information from other sources, such as our social media platforms when you reach out to us to lodge a complaint about our services. However, we will only ask for information relevant to the help required of us to you. In addition, we also indirectly collect information from NIBSS, credit bureaus, NIMC, or other third-party verification service providers.
►6. Other information we collect related to your use of our website or Services:
We may collect additional information from or about you when you Communicate with us, contact our customer Support teams,respond to a survey or use functionality offered by third-party service providers through our Platform.
•7. When you apply for a job with us: We may request Personal Data about your education, employment and state of health. As part of your application, you will be asked to provide your express consent to our use of this information to assess your application and any monitoring
activities which may be required of us under applicable laws as an employer. We may also carry out screening checks(including reference, background and criminal record checks). We may exchange your Personal Data with academic institutions, recruiters, health maintenance organisations, law enforcement agencies, referees and your previous employers. Without your Personal Data, we may not be able to process your application for positions with us.
•8. We do not collect the information of minors:
If you are under the age of 18, you are not eligible to use the service offered on our digital platform.
►4. How Do We Retain Personal Data?
We retain Personal Data in an identifiable format only for as long as required for our business purposes, with specific reference to the service rendered to you, and to fulfil our legal or regulatory obligations. Subject to applicable law, which might, from time to time, oblige us to retain your Personal Data for a certain period of time, we will retain your Personal Data for as long as necessary to fulfil the purposes we collect it for, including the purposes of satisfying any legal, accounting, or reporting obligations.
►5. How Do We Process Personal Data?
We collect your personal data to provide you an efficient and secure customer experience. We may process your Personal Data fokr the following reasons:
•1. Provide services, including to: Initiate a payment, send or request money, or pay a bill; ·Authenticate your access to an account;
· Communicate with you about your account;
•2. Manage risk, fraud and abuse of our services prevent you from fraud (by developing and
adopting measures of verifying your identity). Our risk and fraud tools use personal data, device
information and geolocation from our Platform that offers services to help detect and prevent
fraud and abuse of the services.
•3. Comply with our legal and regulatory obligations and to enforce the terms of our sites and services, including to comply with all applicable laws and regulations.
•4. Trail and track information (data) breaches and remediate such identified breaches.
✓5. Resolve disputes and troubleshoot problems.
→6. With your prior consent:
· Use cookies to provide a targeted display, feature, service or offer to you.
• To provide you with location-specific functionality like searching nearby agents if you authorize us to access your Geolocation information through the Services.
If/onceyou unsubscribe or object, we will stop sending further marketing communications to you by SMS or email.
Additionally, you can withdraw your consent at any time and free of charge.
►6. Sharing your Personal Data
We may share your Personal Data or other information about you with others for the
following reasons:
• With other companies that provide services to us:
We may share Personal Data with third-party service providers that perform services and actions at our direction and on our behalf. These third-party service providers may, for example, provide you with services, verify your identity, assist in processing transactions, send you advertisements for our products and services, provide customer support. Rest assured that we make double sure that these companies have compliant, legal measures in place to ensure the security and confidentiality of your Personal Data.
• With unaffiliated third-party service providers that offer functionality through our Platform, with your prior consent, to help complete the service you request.
• With the other parties to transactions when you use the services, such as other users and their service providers. This includes other users you are sending or receiving funds from and their service providers. The information might include: Personal Data and account information necessary to facilitate the transaction; and
• Personal Data to help other participant(s) resolve disputes and detect and prevent fraud.
Where permitted or required by law, we may share information about you with other parties for Africadataplan's business purposes or as permitted or
required by law, including:
• If we need to do so to comply with a court proceeding, other legal process or an
applicable regulation;
• To law enforcement authorities or other government officials, or other third parties pursuant to a court order or other legal process or requirement applicable to Africadataplan or an affiliated entity;
• Where we reasonably believe that the disclosure is necessary or appropriate to prevent an imminent physical harm or financial loss, or in connection with an investigation of suspected (or actual) illegal activity,
• With credit agencies and data processors for credit reference checks and anti-fraud and compliance purposes all in accordance to applicable data privacy regulations and laws;
• To investigate violations of or enforce a user agreement or other legal terms applicable to any service;
• To protect our property, services and legal rights; As reasonably and legally permitted, to facilitate a purchase or sale of all or part of Africadataplan's business, or in the instance of some merger and acquisition
• To support our audit, compliance, and corporate governance functions.
►7. How We Use Cookies
Cookies are small files placed on your device's browser that enable the website to identify your device as you view different pages. Like most interactive websites, our website usescookies to enable us track of your activity for the duration of session. Our website uses only encrypted session cookies which are erased either after a predefined timeout period or once the user logs out of the platform and closes the browser. Session cookies do not collect information from your device. They will typically store data in the form of a session identification that does not personally identify you. Certain aspects of our website are only available through the use of cookies, So your use of our website may be limited or not possible if you choose to disable or decline cookies. You may also choose to accept, decline, or manage cookie settings, which affects how you interact with our website and determines the cookies. You may also choose to accept, decline manage cookie settings, which affects how you interact with our website and determines the functionality of the pages
8. Waht Are Your Rights?✓
1. Requests to Access, Rectify or Erase.✓
a. Access Request✓
As permitted under law and applicable data protection legislation, you have the right to ask us
whether we hold any Personal Data relating to you and, if we do, to be provided with a copy of that Personal Data in electronic form, unless you want to receive it in any other way (for example, a paper Copy). n addition, you can ask us for information on how we use your Personal Data, who we share it with, how long we keep it, where it is stored, and other information to help you understand how we use it.
•b. Rectification Request
You have the right to ask us to correct your Personal Data (including by means of providing a
supplementary statement) if it is inaccurate, or update Outdated or incomplete Personal Data
without undue delay.
•c. Erasure Request
You have the right to ask us to erase your Personal Data if:
•i. Your Personal Data are no longer necessary for the purpose(s) they were collected for.
•ii. Your Personal Data have been unlawfully processed.
•iii. Your Personal Data must be erased to comply with a legislation or court order.
•iv. You withdraw your consent for the processing of the Personal Data (and if this is the only basis h on which we are processing your Personal Data).
•V. You object to the possession, provided there are no overriding legitimate grounds for continued processing, or
•vi. You object to processing for direct marketing purposes. We may refuse to act on your request to erase your Personal Data if the processing of your Personal Data is necessary:
•d. To exercise our right of freedom of expression and information.
•e. To comply with the relevant Nigerian laws and regulations.
•f. For the performance of a task carried out in the public interest or authority vested in us. to exercise some official function
•g. To establish, exercise or defend legal claims.
•h. to comply with pertinent legal and regulatory directives.
In these cases,we can restrict the processing instead of erasing your Personal Data if requested to do so by you.
•2. Object to processing: You have the right to object at any time to the processing of your
Personal Data provided we do not have any other lawful basis to process it. We will stop processing your Personal Data unless we can demonstrate
compelling legitimate reasons for continuing the processing. We may reject your request if the
processing of your PerSonal Data is needed to establish, exercise or defend legal claims or other legitimate purposes. You have the right to object at any time if we process your Personal Data for direct marketing purposes. In such cases, we wil stop processing your Personal Data when we receive your objection.
•3. Requests to Restrict: You have the right to ask us to restrict the processing of your Personal Data if:
•a. You contest the accuracy of your Personal Data and we are in the process of verifying the Personal Data we hold.
•b. The processing is unlawful and you do not want us to erase your Personal Data.
•C. We no longer need your Personal Data for the original purpose(s) of processing, but you need them to establish, exercise or defend legal claims and you do not want us to delete the Personal Data as a result, or
•d. You have objected to processing carried because of our legitimate interests while we verify if our legitimate grounds override yours. If processing is restricted, we may process your Personal Data (excepting for storage purposes), only:
•a. If you have given us your consent.
•b. For establishing, exercising or defending legal claims.
•C. For protecting the rights of another natural or legal person, or
•d. For reasons of important public interest as defined under the NDPA and relevant Nigerian laws and to comply with pertinent legal and regulatory directives. Once processing is restricted following your request, we will inform you before we lift the restriction.
►8. Requests for Portability:
Subject to the directives of the Nigeria Data Protection Commission and technical possibilities, you can exercise you right to portability by requesting us to exercise you right to portability by requesting us to provide your data in a commonly used and bymachine-readable electronic format.
If your request relates to a set of Personal Data that also concerns other individuals, we may restrict the transfer to only the portion relevant to you, unless you establish that you have also gotten their consent.
♥Automated Decision-Making: Generally, you have the right to object to
any decision concerning you or which otherwise significantly affects you if this is based solely on the automatedprocessing of your Personal Data without human intervention. This includes automated decisions based on profiling.
However, we may refuse your request regarding such automated decisions where:
•a. Necessary to enter into a contract with you, or for the performance of your contract with us.
•b. Permitted by regulations, or
•C. Based on your explicit consent.
Right to be informed: The NDPA requires us, as controllers, to provide certain information to you before processing your personal data. It is in compliance withthat obligation that we have publishedthis privacy notice.
Additional information are also provided in Our Terms of use as well as other notices in our premises when you visit.
Withdrawal of consent:
Your decision to give consent to the processing of your data also comes with corresponding right to withdraw the consent at any time. Hence, you have the right to communicate to us to stop processing your personal data with ot without reasons and we are duty-bound to stop such processing except other lawful bases exist for us to continuethe processing activities.
Right to lodge complaint:
In the unlikely event of an infringement on any of your rights, you are atb liberty to lodge complaint to the Nigeria Data Protection Commission (NDPc) or any other regulatory agency for redress.
9. How Do We Protect Your Personal Data?
Security
We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access Controls to our premises, as well as information access authorization controls.
Confidentiality
Your Personal Data is regarded as confidential and will not be divulged to any third party, except under legal and/or regulatory conditions. You have the right to request sight of, and copies of any and alI information we keep on you, if such requests are made in compliance with the Freedom of Information Act and other relevant enactments.
While we are dedicated to securing our systems and services and safeguarding the informatio
entrusted to us, your role in fulfilling confidentiality duties includes but is not limited to, adopting and enforcing appropriate security measures such as securing and maintaining the privacy of your password(s) and account/profile registration information, adherence with physical security protocols on our premises, verifying that the Personal Data we maintain of you is accurate and ucurrent. We will inform you of any breaches which may likely result in high risks to your rights and freedoms. We have drafted policies and other documents that ensure the safety, integrity and confidentiality of your personal data. We also periodically train and equip Our authorised staff on the Contemporary measures for data security.
►10. Remedies for Violation and Time-frame for Remedy
In the unlikely event of violation of any of your rights as a data subject, our Data Protection Officer shall within 30 days of your notice of the said violation, address the issue and redress the violation as practicable as possible. The available remedies include but not limited to correction or deletion of your data, grant of access to your data, due information on the processing of your data, restriction on further processing and other applicable remedies as the relevant laws prescriber.
►11. Changes to our Privacy Policy
This privacy policy is reviewed periodically and when there is any substantial change to business or regulatory requirements. The revised Privacy Policy will be effective as of the published updated date. At the minimum, we shall review thiannually and communicate via our communication channels such as Website, Social Media Accounts etc. If the revised version includes a substantial change, we may notify you of the change using emails or other means.
►12.Contact Us
If you have any general questions or concerns about this Privacy Policy or the way in which we handle your Personal Data, kindly contact the details below:
AFRICADATAPLAN LIMITED
Office address:. 11 oruma Lane Old A/C GN49/32 Ughelli, DT, NGN
Email: info@africadataplan.com