Privacy Policy

PRIVACY AND COOKIE POLICY

1. The Information we Collect

1.1. Personal Data You Provide Directly We collect personal data you provide to us. For example: ?

Contact information. As part of our operations, PayS may collect information such as your name, telephone number, email address, address, etc. to provide you with our Services.
Payment information. If you make a purchase or other financial transaction through the Platform, such as when you checkout with PayS on a Merchants website, we collect card data, limited financial account information, and other payment details.
Communications. If you contact us directly, for example, with an inquiry or a support request, or participate in our customer surveys, customer support outreaches, promotional events and Corporate Social Responsibility events, we may receive additional personal data about you, including your email address and the content of your communications.

1.2. Personal Data We Collect Automatically

Device Information. We receive information about the device and software you use to access our Services, including Internet Protocol (IP) address, web browser type, operating system version, and device identifiers.
Usage Information. To help us understand how you use our Services, , and to help us improve them, we automatically receive information about your interactions with our Services. This information includes records of your transactions and information about your other activities related to our services, such as the date and time of your sessions, the pages you view, links to/from any page, and time spent in a session. We gather some of the data through cookies and similar technologies as discussed in other parts of this document.
Location Information. We may collect or infer your general location information when you use our Services. For example, your IP address may indicate your general geographic region, which will be matched against our IP whitelist.

1.3. Personal Data That We Receive from Others ?

Partners. We may retrieve additional personal data about you from third parties and other identification/verification services, such as credit bureaus, your financial institution and payment processor. We may combine that data with other information we have about you.
Publicly available sources. We may also gather additional data about you from public sources of information, such as open government databases.
Inferences. We may infer additional Personal Data based on the Personal Data described above. For example, we may infer your interests for website visitors based on the web pages you view.

When you are asked to provide personal data, you may decline. You may also use the web browser or operating system controls to prevent certain types of automatic data collection. However, where you choose not to provide or allow information necessary for certain services or features, those services or features may not be available or fully functional.

2. How Cookies

We and our partners use cookies and similar technologies on our website to help collect information and operate the website. We use cookies to remember Users and make your user experience easier; customise our services, content and advertising; help you ensure that your account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety on our website. Cookies are small text files placed by a website and stored by your browser on your device. You can learn more about the types of cookies we use through the Cookie Banner on our website.

Our cookies hold a unique random reference to you so that once you visit the site, we can recognise who you are and provide certain content to you.

Most web browsers are set to accept cookies by default. You can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this may impact your experience using our website.

3. We Use Personal Information

We use the Personal Data we collect to:

Provide you with the required services in addition to related products and services of interest.
Respond to your questions or requests.
Improve features and content, and analyse data to develop products and services.
Address inappropriate use of our website.
Prevent, detect and manage risk against fraud and illegal activities using internal and third-party screening tools.
Send you marketing content, newsletters and service updates curated by PayS (only with your explicit consent).
Verify your identity and the information you provide in line with PaySs statutory obligations using internal and third-party tools.
Maintain up-to-date records.
Resolve disputes that may arise, including investigations by law enforcement or regulatory bodies.
Any other purpose that we disclose to you in the course of providing PayS services to you.

4. How We Share Personal Data

PayS does not sell, trade or rent personal data to anyone. Further, we will not share or disclose your data with or to a third party without your consent except as necessary to provide the Services or as described in this Privacy Policy.

Service providers. We may share personal data with vendors or agents working on our behalf, to the extent that is required. to facilitate the proviso of the Services described in this statement. These may include companies we have hired to provide customer service support, support our marketing and communication campaigns across offline and digital media, to protect and secure our systems and services, or to perform sanctions screening and identity verification services which may need access to personal data to provide those functions. The processing by such third parties shall be governed by a written Confidentiality contract with PayS to ensure adequate protection and security measures for the protection of personal data in accordance with the terms of this Privacy Policy.
Financial services & payment processing. When you provide payment data, for example, to make a purchase, we will share payment and transactional data with banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, or other related financial services.
Affiliates. We enable access to personal data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access is needed to provide services and operate our business.
Partners. We may share your data with companies we partner with for industry networking events, mixers, and other learning and development opportunities, but only with your explicit consent and with the option to opt out.
Legal and law enforcement. We may access, disclose, and preserve personal data in accordance with applicable law and when we believe that doing so is necessary to comply with applicable law or respond to valid legal processes, including from law enforcement or other government agencies.
Security, safety, and protecting rights. We will disclose personal data if we believe it is necessary to:

> protect our Users and others, for example, to prevent fraud or to help prevent the loss of life or serious injury of anyone;

> operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or

> protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies.

We leverage third-party analytics to analyse personal data collected through our websites, APIs and apps, including account information, marketing and communications data, demographic data, content and files, geolocation data, usage data, and inferences associated with identifiers and device information (such as cookie IDs, device IDs, and IP address) as described in the Cookies section of this statement. This data is aggregated and enables us to perform analytics and track the performance of our website.

Finally, we may share de-identified information in accordance with applicable law.

5. How We Protect your Information

PayS has established adequate technical and organisational controls to protect the integrity and of personal data, both in digital and physical format and to prevent personal data from being accidentally or deliberately compromised.

PayS is committed to managing your data in line with applicable data protection laws and best practices. We protect your data using physical confidentiality, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration, we also use industry-recommended security protocols to safeguard your data. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to our building and files. They only grant access to personal data to employees who require it to fulfil their job responsibilities. Employees may have access to personal data only as is appropriate for the type and scope of the task in question and are contractually forbidden to use personal data for their own private or commercial purposes or to disclose them to unauthorised persons, or to make them available in any other way.

Personal Data Breach

At PayS, we take the security of personal data seriously and have implemented measures to prevent data breaches from occurring. However, in the event of a data breach, we have established procedures for reporting and managing incidents. PayS also maintains a data breach procedure to deal with incidents concerning personal data or practices leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed. You may contact our Data Protection Officer (DPO) upon becoming aware of any breach of personal data or if your access credentials have been compromised to enable us to take the necessary steps towards ensuring the security of your data or account.

When we become aware of a data breach that affects personal data, we will notify the affected individuals and relevant authorities in accordance with applicable data protection laws and regulations. The notification will include the following information: o

A description of the nature of the data breach, including the categories of personal data involved;
The likely consequences of the data breach; and
The measures taken or proposed to be taken by PayS to address the data breach, including any measures to mitigate its possible adverse effects.

We will notify affected individuals without undue delay, but no later than 72 hours after becoming aware of the data breach, unless there are exceptional circumstances that prevent us from doing so. We will also record any data breaches and provide this information to the relevant authorities upon request.

We encourage all users and customers to take reasonable steps to protect their data, such as using strong passwords, regularly updating their account information, and reporting any suspicious activity to us immediately.

We will report any breaches that will compromise your rights and freedoms to the Relevant Authority within 72 hours of discovery.

6. Storage Limitation

We will retain your information for the following periods:

As long as reasonably necessary for providing our Services to you;
For the duration your account is active (if applicable) and we have your consent;
For the period needed to comply with our legal and statutory obligations;
As needed to verify your information with a financial institution.

PayS is statutorily obliged to retain the data you provide to process transactions, ensure settlements, make refunds, identify fraud and comply with applicable laws and regulatory guidelines.

Under Nigerias Money Laundering (Prevention and Prohibition) Act, we are mandated to retain transactional records (customer and beneficiary names, addresses, identification number, amount, currency etc.) for at least five years following the completion of the transaction. Under the Central Bank of Nigerias Framework for Mobile Payment Services in Nigeria, PayS must maintain records of identification data, account files and relevant business correspondence for seven years following the termination of an account and/or business relationship. We keep our data retention policy under regular review.

Upon expiration of the applicable storage limitation periods, we will delete, erase, anonymise or pseudonymise any information we hold about you.

This Privacy Policy also applies when we retain your Personal Information after our relationship ends. We may also retain your Personal Information for the duration of any period necessary to establish, exercise or defend any legal rights. We may keep Personal Information indefinitely in a de-identified format for statistical purposes, which may include, for example, statistics of how you use the Services.

7. Transfer of Data

As part of our service provision, we may rely on third-party servers, resident in foreign jurisdictions, which constitutes transferring your data to computers or servers in foreign countries. An example is PaySs use of cloud storage solutions, with servers in Ireland. We take steps designed to ensure that the data we collect under this Privacy Policy is processed and protected according to the provisions of this Policy and applicable law, wherever the data is located.

At PayS, we take the security of personal data seriously. We comply with all relevant data protection regulations and guidelines to ensure that personal data is always protected. Specifically, we use contractual terms to ensure that the personal data is adequately protected or that the country to which the data is being transferred has adequate data protection laws in place. We take additional measures to ensure that the country to which the data is being transferred meets our standards for data protection.

Should you wish to transfer your personal data to a country deemed to have inadequate data protection laws, PayS will take all necessary steps to ensure that it is transferred under relevant, appropriate safeguards, and where relevant, with your informed consent, and that you are made aware of the risks associated with such a transfer. In any instance, PayS will ensure personal data is transmitted safely and securely. Details of the protection given when your data is transferred abroad and details of the basis of such transfers shall be provided to you upon request.

8. Grounds for Processing of Personal Data

Processing of Personal Information by PayS will be lawful if one of the following applies:

the Data Subject has given consent to the processing of his/her Personal Information for one or more specific purposes. You can revoke your consent by closing your PayS account (where applicable) and/or by emailing us;
the processing is necessary for the performance of a contract to which the Data Subject is party or to take steps at the request of the Data Subject prior to entering into a contract;
processing is necessary for compliance with a legal obligation to which PayS is subject;
processing is necessary for legitimate interests pursued by PayS or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data; or
processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in PayS.

9. Choices and Rights

At PayS we respect the rights of our customers and users, and we allow you to exercise them under the applicable data protection laws and regulations. Individuals who have Personal Information held by PayS are entitled to reach out to PayS to exercise the following rights:

Right to request for and access any Personal Information collected and stored by PayS. This right allows you to request a copy of your personal information held by PayS. To exercise this right, you can submit a request to the Data Protection Officer (DPO) or to our Data Subject Rights Team athelp@pays-app.com;
Right to be informed regarding the use of your Personal Information;
Right to be informed about appropriate safeguards in place whenever your personal information is transferred abroad;
Right to object to automated decision making and processing. You have the right to object to the processing of your personal information and to exercise this right you can submit a request to the DPO or our Data Subject Rights Team;
Right to request rectification and modification of Personal Information whenever you want us to correct your inaccurate or incomplete personal information which PayS keeps;
Right to request the deletion of your personal information; o Right to request the movement of your personal information from PayS to a third party - this is the right to the portability of data;
Right to revoke consent; o Right to object to direct marketing, and to request that PayS restricts the processing of your information; and o Right to submit a complaint to the Nigeria Data Protection Commission (NDPC). Your request will be reviewed and answered by PaySs Data Protection Officer within a 30-day period.

10. Compliance to Childrens Privacy

Our Services are directed to people at least 18 years old or older. We do not knowingly collect any personal data (as defined by the Nigeria Data Protection Regulation) from anyone under 18 without valid parental consent. If we become aware that we have collected such personal data without parental consent, we will take reasonable steps to delete it as soon as possible.

11. Changes to This Privacy Policy We may need to update, modify or amend our Privacy Policy as our technology evolves and as required by law. If we materially change how we use or share personal data previously collected from you through our Services, we will provide notice or obtain consent regarding such changes as may be required by law. The Privacy Policy will apply from the effective date provided on our website.

12. Policy Violations

Any violation of this Privacy Policy should be brought to the attention of the Data Protection Officer (details below) for appropriate sanctioning and treatment.

13. Contact PaySs Data Protection Officer (DPO)

If you have any questions relating to this Privacy Policy or would like to find out more about exercising your data protection rights, please reach out to our DPO via email athelp@pays-app.com For any further queries, our Data Protection Officer may be reached at the following address:

7A, Oluwa Rd, Ikoyi, Lagos.