This Privacy Policy (this “Privacy Policy”) explains how personal information is collected, used, stored, and disclosed by Fintech Association of Nigeria, (“FinTechNGR,” “we,” “us,” and “our”).
The provisions contained in this Privacy Policy supersede all previous notices and statements regarding our privacy practices with respect to our Services.
Application of this Privacy Policy
This Privacy Policy applies generally to the business of FintechNGR and serves to set out our approach to personal data, inclusive of personal data of our consumer users (“Users”). This Privacy Policy applies to systems, operations and processes of FintechNGR that involve the collection, use, storage, and disclosure etc of Personal Information.
This Privacy policy applies to use of our websites, applications, other online services and/or any related services, sales, marketing, promotional or events, and social media activities (collectively, our “Services”). For our Users, this Privacy Policy is part of our Terms of Use.
This Privacy Policy applies to your use of (regardless of means of access) our Services. You may access or use our Services through a desktop, laptop, mobile phone, tablet, or other consumer electronic device (each, a “Device”). This Privacy Policy also applies to offline interactions with FintechNGR.
By accessing or using our Services, you agree to this Privacy Policy.
Consent
By using our website and webapps (or by ticking the consent box below) you agree to the terms of this Privacy Policy, as to allow us to utilise your data to service you more accurately.
It is important that you read this Privacy Policy together with any other policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy complements other notices and policies and is not intended to override them.
By accessing the services of FintechNGR and voluntarily providing us with the requested personal information, you consent to the collection and use of the information in accordance with this Privacy Policy. Your consent can be withdrawn at any time by sending a request to that effect to the contact information supplied below. If you do not consent to the collection, use or disclosure of your personal information as outlined in this policy, please do not provide any personal information to FintechNGR.
By consenting to this policy, you are assumed to be of reasonable age for the purpose of using this website within the relevant country from where you access this website. This website is not intended for children, and we do not knowingly collect data relating to children.
Scope of this Privacy Policy
Please note that this Privacy Policy applies to the FintechNGR main web pages (i.e. those in https://fintechng.org) and generally to the business of FintechNGR. If you follow a link to any other website, please check to confirm their policies before you submit any personal information to those websites.
Guiding Principles
FintechNGR is committed to maintaining the principles in the Nigerian Data Protection Regulation (NDPR), the Nigerian Data Protection Act (NDPA) and other applicable privacy and data protection laws regarding the processing of Personal Data.
The collection and processing of your Personal Data shall be in accordance with the legitimate and lawful purpose consented to and shall only be stored for the period, which is reasonably required, provided also that your Personal Data shall be adequately secured against foreseeable hazards within our contemplation.
To demonstrate this commitment as well as our aim of creating a positive privacy culture within FintechNGR, FintechNGR adheres to the following basic principles relating to the processing of Personal Data: lawfulness, fairness and transparency; data accuracy; purpose limitation; data minimization; storage limitation; integrity and confidentiality; and accountability.
Information We Collect and How We Collect it
- Information You Provide Us
In general, you can visit the FinTechNGR Website without telling us who you are or revealing any information about yourself.
When you submit an inquiry to us via any means, register for a FintechNGR account, register to attend a FintechNGR event, interact with us on social media, partake in competitions and promotional activities and volunteer information to us; we may collect personal information from you, which may include your name, email address, mobile phone number, banking information, image and other information that identifies you (collectively, “Personal Information”). By providing your Personal Information to us, you expressly agree to our collection, use, storage, and disclosure of such information as described in this Privacy Policy.
As a User, we may also ask you to create login information for your FintechNGR account, such as a username and password. When you provide your mobile phone number, we may ask for your consent to receive text messages relating to our Services at that number.
In general, we collect Personal Information you give us by filling in forms or by corresponding with us by phone, email, social media posts & messages, or otherwise.
- Information About Your Transactions
We collect Personal Information about your transactions with us and others.
- Information from Third Parties
We also collect Personal Information about you from other companies. For instance, we may receive Personal Information about you from a consumer reporting agency or we may collect Personal Information from your employer where your employer is providing a service to Fintech Nigeria.
We may collect your Personal Information from a User where your Personal Information is filled in a Next-of-Kin form.
- Information Automatically Collected
We (or our service providers acting on our behalf) may collect information about your use of our Services. This information may include Personal Information as well as statistical information that does not identify you (“Analytics”). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy.
Information that we automatically collect in connection with your access or use of our Services may include:
Device Information: We may collect Device-specific information (such as hardware model, operating system version, unique Device identifiers, and mobile network Information, including your mobile phone number). We may associate your Device identifiers or mobile phone number with your Fintech Nigeria account.
Log Information: We may record or log information from your Devices, their software, and your activity accessing or using our Services. This information may include:
- The Device’s Internet Protocol (“IP”) address
- Identification numbers associated with your Devices.
- Device event information, such as crashes, system activity, and hardware settings
- Location preferences
- Date and time stamps of transactions
- System configuration information
- Other interactions with our Services
- Information Collected Through Cookies and Similar Technologies
We use cookies to personalize our Services for you and to collect aggregate information about usage of our Services. A cookie is a text file or other local storage identifier provided by your browser or associated applications. We use cookies for record-keeping purposes and to enhance the quality of your use of our Services. The cookies assign random, unique numbers to your Devices to enable our systems to recognize your Devices and to allow us to see how you use our Services.
The cookies we use in connection with our Services include:
Session cookies: Session cookies are temporary cookies that expire and are automatically erased whenever you close your browser window. We use session cookies to grant users access to content and to enable actions they must be logged into their Fintech Nigeria account to perform.
Persistent cookies: Persistent cookies usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve our Services. For example, we may use a persistent cookie to associate you with your Fintech Nigeria account or to remember your choices for our Services.
Third-party cookies: We permit certain third parties to place cookies through our Services to provide us with better insights into the use of our Services and user demographics and to advertise our Services to you. These third parties may collect information about your online activities over time and across different websites when you access or use our Services. For example, we utilize Google Analytics to analyze usage patterns for our Services. Google Analytics generates a cookie to capture information about your use of our Services, which Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify its cookie, but this will not be associated with any other data held by Google. We may also permit third-party service providers to place cookies for our Services, as indicated above, to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties.
By accessing or using our Services, you consent to the placement of cookies on your Devices as described in this Privacy Policy. If you prefer not to receive cookies through our Services, you may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Unless you set your browser settings to refuse all cookies, our system may issue cookies when you access or use our Services. If you set your browser settings to refuse all cookies, the performance of certain features of our Services may be limited or not work at all.
- Do-Not-Track Signals
Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.
How We Use Information
We may use Analytics as described elsewhere in this Privacy Policy and for research and commercial purposes, such as to improve our Services.
We may use Personal Information for the purposes described elsewhere in this Privacy Policy and internally for our general commercial purposes, including, among other things, to offer our products and services and products and services of third parties that we think you might find of interest, but only FintechNGR and our third-party service providers involved in distributing the offers or providing the products or services will have access to your Personal Information. Our third-party service providers will only be permitted to use Personal Information for that intended purpose.
We may use your email address to respond to your inquiries and to provide you information about our Services. You may elect not to receive promotional emails from us either by “unsubscribing” to an email you receive from us or by contacting us as indicated below. As a User, if you unsubscribe from receiving emails from us, we may still send you non-promotional emails, such as emails about your Fintech Nigeria account or our ongoing business relations, unless you withdraw your consent to receive electronic communications as provided in our Terms of Use.
How We Share Information
We do not share your Personal Information with: (1) other financial companies for joint marketing purposes; (2) affiliated companies for their everyday business purposes; or (3) any third parties so they can market to you.
We may share your Personal Information with unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to help complete a transaction for you; (3) if the information is provided to: (a) comply with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas; (b) enforce our Terms of Use or other agreements; or (c) protect our rights, property, or safety or the rights, property, or safety of our users or others (e.g., to a consumer reporting agency for fraud protection, etc.); (4) if the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets); (5) if the information is provided to our third-party service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); (6) for our everyday business purposes; (7) for publication of our events and competitions on digital and print media (8), we share your Personal Information with delivery companies and may publish your image where you have won a gift in our competitions, giveaways and promotions or (8) as permitted by applicable law or otherwise described in this Privacy Policy.
When you are no longer our User, we may continue to share your information as described in this Privacy Policy.
We may disclose Analytics with third parties as described elsewhere in this Privacy Policy and for our commercial purposes.
Opt-Out Rights
If you do not wish to receive offers or other notices from us in the future, you can “opt out” by contacting us as indicated at the end of this Privacy Policy or by following the “unsubscribe” contacting us as indicated at the end of this Privacy Policy instructions in any communication you receive from us. Please be aware that if you are a User, you are not able to opt out of receiving communications about your FintechNGR account or related transactions with us.
Data Security
We have well-maintained systems for storing and managing your data, and we commit to conscientiously utilising your data in consonance with the provisions of this policy. We have suitable security measures in place to prevent your personal data from being accidentally lost or used or accessed in an unauthorised way by a third party. 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.
To ensure the secure transmission of your Personal Data, our website employs Secure Sockets Layer/Transport Layer Security (SSL/TLS), this is evident in the padlock symbol in your URL address bar once you are successfully logged into the platform. The URL address will also begin with https://, the “s” indicating that the page is secure. SSL encrypts communication between two points, such as your computer and the connecting server. Any data sent during the session will be encrypted before being sent and decrypted at the receiving end. This is done to ensure that data cannot be read during transmission.
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. Information which you provide to us will ordinarily be stored on our secure servers. By submitting personal information, you agree to this transfer, storing and processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
We have put in place 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.
We admit however that no website or database is completely secure or “hacker proof” and we only guarantee the safety of your data to the extent of our undertaking all reasonable measures to protect the data.
Your Rights
You have rights under data protection laws in relation to your personal data. It is FintechNGR’s policy to respect your rights and FintechNGR will act promptly and in accordance with any applicable law, rule or regulation relating to the processing of your personal data.
Details of your rights are set out below:
- Right to be informed about how personal data is used –you have a right to be informed about how we will use and share your personal data. This explanation will be provided to you in a concise, transparent, intelligible and easily accessible format and will be written in clear and plain language;
- Right to access personal data –you have a right to obtain confirmation of whether we are processing your personal data, access to your personal data and information regarding how your personal data is being used by us;
- Right to have inaccurate personal data rectified– you have a right to have any inaccurate or incomplete personal data rectified. If we have disclosed the relevant personal data to any third parties, we will take reasonable steps to inform those third parties of the rectification where possible;
- Right to have personal data erased in certain circumstances –you have a right to request that certain personal data held by us is erased. This is not a blanket right to require all personal data to be deleted. We will consider each request carefully in accordance with the requirements of any laws relating to the processing of your personal data;
- Right to restrict processing of personal data in certain circumstances –you have a right to block the processing of your personal data in certain circumstances. This right arises if you are disputing the accuracy of personal data, if you have raised an objection to processing, if processing of personal data is unlawful and you oppose erasure and request restriction instead or if the personal data is no longer required by us, but you require the personal data to be retained to establish, exercise or defend a legal claim;
- Right to data portability –in certain circumstances you can request to receive a copy of your personal data in a commonly used electronic format. This right only applies to personal data that you have provided to us (for example by completing a form or providing information through a website). Information about you which has been gathered by monitoring your behaviour will also be subject to the right to data portability. The right to data portability only applies if the processing is based on your consent or if the personal data must be processed for the performance of a contract and the processing is carried out by automated means (i.e., electronically);
- Right to object to processing of personal data in certain circumstances, including where personal data is used for marketing purposes –you have a right to object to processing being carried out by us if (a) we are processing personal data for the performance of a task in the public interest, (b) if we are using personal data for direct marketing purposes, or (c) if information is being processed for scientific or historical research or statistical purposes. You will be informed that you have a right to object at the point of data collection and the right to object will be explicitly brought to your attention and be presented clearly and separately from any other information.
- Right to lodge a compliant with the Nigeria Data Protection Commission (“NDPC or Regulator”) – If you believe that the processing of your personal data violates data protection law, you also have the right to complain to the data protection supervisory authority.
- Right not to be subject to a decision based solely on automated processing of personal data– you have the right to object to solely automated processing of your personal data including profiling, which produces legal or similar significant effects concerning the data subject.
You may exercise any of your rights by contacting our team at (damilola.adeyanju@fintechng.org). You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one calendar month. Occasionally it may take us longer than one calendar month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Information You Share Socially
Our Services may allow you to connect and share your actions, comments, content, and information publicly or with friends. We are not responsible for maintaining the confidentiality of any information you share publicly or with friends.
Our Services may also allow you to connect with us on, share on, and use third-party websites, applications, and services. Please be mindful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those sites and services directly if you want to learn about their privacy practices.
Data Retention and Erasure
We generally retain your personal information for as long as is necessary for the purposes we collected it for and also giving you better service. To this end, we are committed to maintaining the confidentiality of the personal information.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, and the applicable legal requirements.
By accessing this Website and any of its pages you are agreeing to the terms set out above. You may also request to have all your personal information deleted entirely. Please note that if you request the erasure of your personal information. We may retain and use your personal information to the extent necessary to comply with our legal obligations, including but not limited to tax, legal reporting and auditing obligations.
If you would like to know more about the retention periods we apply to your personal data, please contact us at (damilola.adeyanju@fintechng.org)
Protecting Children’s Privacy
Our Services are not directed, or intended to be attractive, to children under the age of 18. We do not knowingly collect Personal Information from children under the age of 18. If you are under the age of 18, do not use our Services or submit any information to us.
Links to Third-Party Websites
When you use our Services, you may be directed to other websites that are beyond our control. We may also allow third-party websites or applications to link to our Services. We are not responsible for the privacy practices of any third parties or the content of linked websites, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties and websites. This Privacy Policy only applies to our Services.
Changes to our Privacy Policy
Subject to applicable law, we may revise this Privacy Policy at any time and in our sole discretion. When we revise this Privacy Policy, we will post the revised version via our Services and will update the date at the top of this Privacy Policy. The revised Privacy Policy will be effective upon posting via our Services, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing or using our Services. If you do not agree to the terms of this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access and use of our Services. Except as otherwise expressly stated by us, your access and use of our Services is subject to the version of this Privacy Policy in effect at the time of access or use.
Remedies
In the event of any violation of this Privacy Policy by FintechNGR, the user shall be entitled to demand the return of all Personal Data collected and to demand the end of use of any such Personal Data. This remedy shall be available from the time of breach of this Privacy Policy, provided the user has already sent a complaint which was not attended to.
How can I contact FintechNGR?
If you have any questions, comments, or concerns with respect to your Personal Information or this Privacy Policy please contact us at (damilola.adeyanju@fintechng.org 09090000198)