Introduction
This Data Protection & Privacy Policy (“policy”) describes how personal data is collected, handled, used, stored and disclosed by Electronic PayPlus Limited & its subsidiaries (collectively referred to as “Electronic PayPlus”) to meet the standards set by the Nigerian Data Protection Regulations 2019 and applicable law. By this policy, our users, customers, business partners, clients, suppliers and the general public (hereinafter referred to as “you” “your” “their” or “data subject”) know how we use and look after their personal data, their privacy rights and how we plan to protect them. Any reference to "we" "us" "our" “Electronic PayPlus” and “the Company” is to Electronic PayPlus Limited. This Policy ensures that Electronic PayPlus Limited maintains best practices and complies with data protection policies in force, protects the rights of all its stakeholders, is open about how it stores and processes personal information and protects itself from the risks of a data breach.
Policy Scope
This Policy applies to all staff (whether permanent, contract, or interns), contractors, and suppliers of Electronic PayPlus Limited. It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the NDPR, and includes but is not limited to the names of individuals, postal addresses, email addresses, date of birth, sex, and telephone numbers.
Application of this Privacy Policy
This Privacy Policy applies generally to the business of Electronic PayPlus Limited and sets out our approach to personal data, inclusive of personal data of our customers, business partners, clients, suppliers, and the general public ("Users"). This Privacy Policy applies to the systems, operations, and processes of Electronic PayPlus Limited that involve the collection, processing, use, storage, and disclosure of personal information. It applies to the 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 governs your use of our Services which may be accessed through a desktop, laptop, mobile phone, tablet, or other electronic device ("Device") and applies to offline interactions with Electronic PayPlus Limited. By accessing or using our Services, you agree to this Privacy Policy.
Information We Collect
When you contact us or interact with any of our touchpoints, or volunteer information to us such as information on how we can improve our product and services, we may collect personal information including but not limited to –
- Your name
- Email address & mobile phone number
- Digital identifiers such as Bank Verification Number (BVN) and NationalIdentity Number (NIN)
- Banking information
- Residential & business address
- Picture or video of your face during a liveness check
- Other information that exclusively identifies you
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 -
- The Mobile Network and Operating System you use.
- Your Internet Protocol address and Device Information.
- Your location and location preferences.
How We Use Information
We may use Personal Information for the purposes described above, for our business and operational purposes, to offer our products and services, and products and services of third parties that we think you might find of interest. Only Electronic PayPlus Limited and our third-party service providers involved in 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 the stated purpose only. We may use your email address to respond to your inquiries and to provide information about our Services. Your residential address may be used for customer due diligence purposes. 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 emails about your Electronic PayPlus account or other ongoing business relations between us, unless you withdraw your consent to receive electronic communications as provided in our Terms of Use. We may share your Personal Information with unaffiliated third parties -
- If you request or authorize it.
- If the information is provided to enable the completion of a transaction you request
- 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; (c) protect our rights, property, or safety or the rights, property, or safety of our users or others (e.g., to a law enforcement or regulatory agency)
- 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)
- If the information is provided to our third-party service providers to perform functions on our behalf (e.g processing orders, etc.)
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" instructions in any communication you receive from us. Beyond your right to opt out of our processing Personal Information, you also have the option of exercising any of the below rights with respect to your Personal Information - Request Correction to your Personal Information
Request Access to and Restrict further processing of your Personal Information
You can request a copy of your Personal Information in our custody. Before sending you any Personal Information, we will ask you to confirm your identity. If you are not able to confirm your identity, we reserve the right to decline your request for any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information, we hold about you. Request partial or complete erasure of your Personal Information. You may request that we delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note however that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Additionally, if you are denied your rights without a valid legal justification, you may file a complaint with the Data Protection Supervisory Authority of Nigeria (NDPC) at info@ndpc.gov.ng.
Why Do We Need the Data
We need to collect your personal data in order for us to provide you with our services. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose(s) only, and will in no way invade your privacy. If there is a need to use your personal data for marketing purpose, Electronic Payplus Limited will ensure to seek additional consent from you. Electronic Payplus Limited shall not collect or process more data than is reasonably required for a particular processing activity. In addition, every processing purpose has at least one lawful basis for processing to safeguard the rights of the data subjects, as listed below
| Purpose of processing | Lawful Basis of Processng |
|---|---|
| To allow you to use our products | To meet our contractual obligations and to comply with our legal and regulatory obligations. |
| To communicate with you about any new update on our site, products and any changes to our terms and conditions or Privacy Policy | We need to process this data to meet our contractual obligations, to comply with our legal obligations and it is our legitimate interest to keep accurate records. |
| To receive feedback from you about our products | To meet our contractual obligations and it is our legitimate business interest to understand how we can improve our products and services. |
| To provide customer support services | It is in our legitimate business interests to respond to any communications we receive from you. If you do not provide us with this information, we would not be able to identify you as our customer. |
| Payment of staff salaries | We need to process this information to meet contractual obligation we both agreed on. |
| To train our staff (For employees that works with Electronic Payplus Limited Limited) | Its is in our legitimate interest business interest to provide you with helpful service. |
Information You Share Socially
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.
Security and Storage of Your Personal Information
We have suitable security measures in place to prevent your Personal Information 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. We have put in place procedures to actively 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. You also play a role in protecting your Personal Information. Please safeguard your Personal Information and do not share it with others.
Retention Period
When determining the retention period, we take into account various criteria, such as the type of sector you belong. Also the nature and length of our relationship with you and the impact on the services we provide to you. If we have to delete some information from or about you, we follow mandatory retention periods provided by law and the statutory limitations.
Changes to our Privacy Policy
This Privacy Notice may be updated periodically to reflect changes in our privacy practices. We will indicate at the top of the Notice when it was most recently
updated and publish in our website privacy page the date these update occurred.
How to Contact Us
If you have any questions, comments, or concerns regarding this Privacy Policy, please get in touch with us at dpo@epayplusng.com, +234 909 174 8953