Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may store and process all or part of your personal data in Nigeria and elsewhere in the world where our facilities or our service providers are located.

Further details are provided below.

Identity Data

Identity Data includes fullname, username or similar identifier, title, date of birth, gender, address, email address, BVN, etc.

We may collect, use, process, store, and transfer your Identity Data in order to provide our Services, comply with applicable laws and regulatory requirements, detect and prevent fraud, protect our vital interests and that of others, provide Service communications, provide customer service, maintain data and information security, facilitate corporate reorganizations, and implement direct marketing campaigns.

Transaction Data

Transaction Data includes details about payments to and from you and other details of Services you have received from us.

We may collect, use, process, store, and transfer your Transaction Data in order to provide our Services, comply with applicable laws and regulatory requirements, detect and prevent fraud, protect our vital interests and that of others, provide customer service, ensure quality control, maintain data and information security, research and development purposes, enhance customer experience, and implement direct marketing campaigns.

Technical Data

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, browser fingerprint, authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.

We may collect, use, process, store, and transfer your Technical Data in order to provide our Services, comply with applicable laws and regulatory requirements, detect and prevent fraud, research and development purposes, enhance customer experience, and implement third-party marketing campaigns.

Anonymized and Aggregated Data

We also collect, use, and share Aggregated Data such as statistical or demographic data for the purpose of analyzing web traffic and functionality of our website. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Transaction Data and Technical Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Disclosure Of Your Personal Data

We may share your personal data with certain third-party entities which we deem necessary in order to provide our Services effectively or comply with applicable laws and regulatory requirements. Our engagement terms with these third parties shall require them to only use your information in connection with the services they perform for us and prohibit them from selling your information to anyone else. Such engagements shall also be subject to a professional duty of confidentiality where applicable.

Further information is set out below:

• Third-party identity verification service providers: In order to detect and prevent fraudulent transactions and comply with applicable laws and regulatory requirements, we may share your personal data with third-party identity verification service providers who shall verify your identity against available public records and other third-party databases.
• Banks and other financial institution partners: In order to process payments and withdrawals and comply with applicable laws and regulatory requirements, we may share your personal data with banks and financial institutions.
• Service providers: We may share your personal data with service providers that we engage their services to execute different business functions. Examples of these service providers include cloud storages, network infrastructure providers, marketing, and data analytics.
• Professional advisors: We may share your personal data with professional advisors in order to avail ourselves of technical, financial, or legal consulting services or in compliance with our legal obligations.
• Companies or other entities during corporate reorganizations: If a change in our corporate structure occurs as a result of the sale, transfer, or merger of parts of our business or our assets or that of another entity by us, then the new corporate entity may use your personal data in the same way as set out in this privacy policy. You will receive prior notice of any change in applicable policies.
• Law enforcement agents and officials: We may share your personal data where we are bound by law or any legal procedure to share same or when we believe in good faith that the disclosure of your personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our Terms of Services or any other applicable policies.

Use Of Cookies And Similar Technologies

When you access our websites or use our Services, we may place small data files on your computer or other device. These data files may be cookies, pixel tags, "Flash cookies," or other local storage provided by your browser or associated applications (collectively referred to as "Cookies"). These technologies are used to:

• Recognize Users as customers.
• Customize the Service, content, and advertising; measure promotional effectiveness.
• Help ensure that account security is not compromised.
• Mitigate risk and prevent fraud.
• Promote trust and safety across the Service and related sites.

Users can freely decline our Cookies if the web browser or browser add-on permits unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with your use of our websites and the Service.

Third Party Websites

The Zenderpay Platform may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Zenderpay Platform, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website and take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services, or applications that may be linked to or from the Zenderpay Platform.

Data Security

We have put in place appropriate security measures (and contractually require third parties we share your information with to maintain) appropriate physical, technical, and administrative safeguards to prevent the personal data from being accidentally lost, misused, or accessed, altered, or disclosed without authorization. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

The security of your personal information is instructive to note as no method of electronic transmission or storage of data guarantees 100% security. Thus, we strive to use commercially acceptable means to protect your personal information, but we cannot guarantee its absolute security.

Based on the foregoing, we have established appropriate procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Retention Of Personal Data

We will only retain your personal information for as long as reasonably necessary to:

• Provide our services to you.
• Archive purposes to detect and investigate fraudulent transactions.
• Comply with our legal obligations under financial or anti-money laundering laws.
• Satisfy any tax, accounting, or reporting requirements.
• Upon our reasonable belief that there is a prospect of litigation in respect to our relationship with you.

Your Rights

Under certain circumstances, you can exercise certain rights provided under applicable laws and regulations in relation to the personal information we hold. These rights include the right to:

• Give and withdraw consent.
• Request access to your personal information.
• Request the rectification of your personal information.
• Request erasure of your personal information.
• Object to the processing of your personal information.
• Request that we restrict the processing of your personal information.
• Request the transfer of your personal information to you or a third party.
• Complain at any time with any relevant authority for data protection issues.

Limitation Of Liability

We will not be responsible for a breach of personal information which happens due to:

• An event which is beyond our control.
• An act or threats of terrorism.
• An act of God (such as fires, explosions, earthquakes, drought, tidal waves, and floods) which compromises our data protection measures.
• War, hostilities (whether war be declared or not), invasion, acts of foreign enemies, mobilization, requisition, or embargo.
• Rebellion, revolution, insurrection, or military or usurped power, or civil war which compromises our data protection measures.
• The transfer of your personal information to a third party on your instructions.
• The use of your personal information by a third party designated by you.