Privacy Policy.

Application of this Privacy Policy

This Privacy Policy applies generally to the business of Kwaba 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 Kwaba 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 Kwaba.

By accessing or using our Services, you agree to this Privacy Policy.

2. Collection of Personal Data

You may be asked to provide your information including Personal Data anytime you contact us, and we shall use your Personal Data in accordance with this Privacy Policy.

2.1 Categories of Personal Data

We collect Personal Data you provide to us when you apply for a Kwaba account or when you communicate with us about your Kwaba account. The types of Personal Data we may collect include your name, address, phone number, email address, date of birth, bank account information, BVN, username, password, and next of kin details. 2.2 Personal Data About Your Transactions With Us As you use your Kwaba account to perform financial transactions, we collect Personal Data in connection with each transaction, including transaction time, Naira amount and merchant details. We may also collect photos, memos or other information that you attach to your transactions.

2.3 Personal Data From Other Sources

When you create a Kwaba account, we may collect information, including Personal Data about you from non-affiliated third party service providers in order to verify your identity and for fraud prevention, including your prior addresses and names.

LAWFUL BASIS FOR PROCESSING PERSONAL DATA

We will only use your Personal Data if we have a proper reason for doing so. We consider the lawful basis for using your Personal Data as set out in the Nigeria Data Protection Regulation (NDPR).
This include: To comply with our legal and regulatory obligations.
To perform a contract with you or to take steps at your request before entering into a contract.
To use your Personal Data as is necessary for our legitimate interests or the legitimate interests of others.
To protect your interest, the interest of another Data Subject or for the performance of a task carried out in the public interest or in exercise of official public mandate vested in us.

Your Rights

The Nigeria Data Protection Regulation (NDPR) gives you certain rights in respect of the Personal Data we hold about you. Below is a highlight of some of those rights. It is not a complete, exhaustive statement of your rights in respect of your Personal Data:
  1. You have a right to consent to this Privacy Policy and to withdraw your consent at any time.
  2. You have a right to a copy of the Personal Data we hold about you, as well as the information about what we do with it, who we share it with and how long we hold it for. We may make a reasonable charge for additional copies of that data in the case of unfounded and excessive requests.
  3. You have a right to freely transfer your data received from us to any other person.
  4. You have the right to have the Personal Data we hold about you corrected, if it is factually inaccurate. You may contact us for this purpose.
  5. In some circumstances, you have the right to the deletion of the information that we hold about you.
  6. You have a right to lodge a complaint about the handling of your personal information with the National Information Technology Development Agency (NITDA).
  7. You have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your Personal Data to any third party for such purposes.


NITDA’s website has a wealth of useful information in respect of your rights over your personal data.

If you wish to exercise your rights, you may write to us at hello@kwaba.ng

CLOSING YOUR Kwaba ACCOUNT

You may decide to close your kwaba Account, and cancel these Terms and Conditions at any time by sending a termination notice to us at hello@kwaba.ng and following any further instructions as provided by us. if there are pending transactions on your Kwaba Account prior to us receiving your termination notice, we will close your Account immediately after such transactions are completed. Once your Account is closed, we will transfer the balance funds in your Account, if any, to your provided Bank Account within five minutes and your data will be deleted from our servers.

Note that your termination of these Terms and Conditions will not affect any of our rights or your obligations arising under these Terms and Conditions prior to termination.

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.

Security

Kwaba takes reasonable measures to help protect all Personal Data about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Additionally, Kwaba implements policies designed to protect the confidentiality and security of your nonpublic Personal Data, including a privacy protection policy. Kwaba limits access to your Personal Data to employees that have a business reason to know such Personal Data, and implement security practices and procedures designed to protect the confidentiality and security of such Personal Data and prohibit unlawful disclosure of such Personal Data in accordance with its policies.

Where you have chosen a password that allows you to access certain parts of the website and mobile application, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. We have also taken measures to comply with provision of security facilities for the protection of your Personal Data through the set up of firewalls, limited access to specified authorized individuals, encryption and continuous capacity building for relevant personnel. We therefore have digital and physical security measures to limit and eliminate possibilities of data privacy breach incidents.

Although we use appropriate security measures once we have received your Personal Data, the transmission of data over the internet (including by email) is never completely secure. We endeavour to protect Personal Data, but we cannot guarantee the security of Personal Data transmitted to us or by us. We will notify you and any applicable regulator of a breach where we are legally required to do so.

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 are subject to the version of this Privacy Policy in effect at the time of access or use.