Privacy Policy

Version 2.0 · 30th August 2022

At Zappay, the privacy of the Personal Data of our Data Subjects is of utmost importance to us. This policy explains your privacy rights regarding how we collect, use, share and protect your Personal Data when you visit our premises, website, or use our mobile application platform.

1. Consent

When you access our platforms and give your consent upon such access, you accept this privacy policy; in particular, as you use the services offered on our website and digital platform or visit any of our offices and submit your data for official or non-official purposes.

2. Type of Personal Data that we collect

We collect Personal Data about you when you use the services offered on our website and digital platform, including the following:

Registration details: When you register to use the services offered on our digital platform, we will collect the Personal Data necessary to on-board you; including your name, email address, mobile number and debit card details for funding your wallet. We may require you to provide additional, necessary personal details as you use our services.
Transaction details: When you use our digital platform to send and receive money, make purchases from merchants, pay bills, deposit & withdraw cash, we collect information about the transaction, as well as other associated information — such as the amount sent or received, amount paid for products or services, merchant information, and information about your device and geolocation.
User Personal Data: When you use our services, we collect Personal Data about the other participants associated with the transaction, including your phone contacts so you can easily manage account transfers and to 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.
Details from multiple 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 some of our services. We will only ask for information relevant to the help required of us to you.
Information related to your use of any of our platforms or services: We may collect additional information from or about you when you communicate with us, contact our customer support teams, or respond to a survey — customercare@zappay.ng
Application for jobs 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), and may exchange your Personal Data with academic institutions, recruiters, health maintenance organisations, law enforcement agencies, referees and your previous employers.

3. Privacy of minors

We do not knowingly collect names, email addresses, or any other personally identifiable information from children through the internet or any other touch-points. We do not allow children under the age of 18 to open accounts nor provide financial services for children less than 18 years of age without the consent of a guardian. If you are a parent or guardian and you are aware that your child has provided us with Personal Data without verification of parental consent, please promptly contact us at customercare@zappay.ng.

If you are under the age of 18, you are not eligible to use the service offered on our digital platform.

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. We may retain Personal Data for longer periods where legitimate business interests require it, and for purposes of judicial, regulatory or fraud monitoring or prevention.

4. What we do with your Personal Data

We collect your personal data to provide you an efficient and secure customer experience. We process your information to:

Provide services — initiate a payment, send or request money, or pay a bill; authenticate your access to an account; communicate with you about your account; manage risk, fraud and abuse of our services.
Comply with our legal and regulatory obligations and to enforce the terms of our sites and services, including compliance with all applicable laws and regulations.
Track information breaches and remediate identified breaches.
Resolve disputes and troubleshoot problems.
With your consent, market Zappay products and services to you, and use cookies to provide a targeted display, feature, service or offer.

We will not send unsolicited marketing communications to you by SMS or email if you have not opted in to receive them. You can withdraw your consent by unsubscribing at any time, free of charge.

5. How we share 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: third-party providers that verify your identity, assist in processing transactions, or provide customer support on our behalf, under compliant confidentiality measures.
With other financial institutions: partners we work with to offer Zappay-related services, and to process transactions and keep your financial information up to date.
With the other parties to a transaction: account information necessary to facilitate a transfer, and information to help resolve disputes and detect or prevent fraud.
Where permitted or required by law: to comply with court proceedings or legal process, to law enforcement or government officials, to prevent imminent harm or financial loss, with credit agencies for anti-fraud and compliance checks, or to support audit and corporate governance functions.
With your consent: we will share your Personal Data and other information with your consent or direction.

6. What are your rights?

As permitted under law and applicable data privacy regulations, you have a number of rights over your Personal Data:

Access — ask whether we hold Personal Data relating to you, and receive a copy of it along with details of how we use and share it.
Rectification — ask us to correct inaccurate, outdated or incomplete Personal Data.
Erasure — ask us to erase your Personal Data where it is no longer necessary, was unlawfully processed, or where you withdraw consent or object to processing (subject to limited legal exceptions).
Objection — object to processing based on our legitimate interests, including profiling, or to processing for direct marketing at any time.
Restriction — ask us to restrict processing while we verify accuracy, resolve a dispute, or while you establish a legal claim.
Portability — receive Personal Data you've provided to us in a structured, machine-readable format, or have it sent to another organisation where feasible.
Object to automated decisions — object to any legal or similarly significant decision about you based solely on automated processing, including profiling, subject to limited exceptions.

7. Ways 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. Our website uses only encrypted session cookies to track activity for the duration of a session; these are erased after a predefined timeout or once you log out and close the browser. Certain aspects of our website are only available through the use of cookies, so your use of our website may be limited if you choose to disable or decline them.

8. Ways we protect your Personal Data

We maintain technical, physical and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorised access, disclosure and alteration — including firewalls, data encryption, physical access controls, CCTV, and information access authorisation controls. You are responsible for securing and maintaining the privacy of your password(s) and account information. We will inform you of any breaches which may affect your Personal Data.

9. Timeframe and remedies for violation

In the event of a violation of this policy, our Data Protection Officer shall, within 7 days, redress the violation. Where the violation pertains to disclosure of your Personal Data without your consent, such information shall be retracted immediately, with confirmation sent to you within 48 hours of the redress.

10. Governing law

This Privacy Policy is made in accordance with the Nigeria Data Protection Regulation (2019) and any other relevant Nigerian laws, regulations or international conventions applicable to Nigeria.

11. Changes to our Privacy Policy

This Privacy Policy is reviewed periodically and whenever there is a substantial change to business or regulatory requirements. At minimum, we review it annually and communicate changes via our website and social media accounts.

12. Contact us

If you have any general questions or concerns about this Privacy Policy or the way we handle your Personal Data, kindly contact us at privacy-ng@zappay.ng.

Declaration

By using Zappay's website, app or services, you confirm that you have read the terms within this notice and consent to the use of your Personal Data for the purposes described above.