This Privacy Policy (“Policy”) sets out the basis on which any personal data we collect from you or that you provide us will be processed by us, including the type of information being collected, the method of collection of the information, the use of the information, the protection of the information, and the sharing of the information with third parties. This policy applies to all the products, subscriber-based services, mobile applications (“services”), and websites offered by PFI FINANCE COMPANY LTD “(PAYPADY)”, “Us”, “We”) or its numerous branches or affiliated companies. We treat your personal information as private and confidential.

We encourage you to review the privacy policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.

INFORMATION WE COLLECT

· When you use our mobile applications, websites and services, we collect and store your personal information, which you provide from time to time.

· Contact information, such as your name, address, phone number, email and other similar information.

· Financial Information, such as the full bank account numbers and/or credit or debit card numbers that you link to your PFI FINANCE COMPANY LTD (PAYPADY) account or give us when you use PFI FINANCE COMPANY LTD (PAYPADY) services.

· Detailed personal information such as your date of birth, driver’s licence number, or other identification information or documents, and any other information we deem necessary.

· We collect information when you create an account, subscribe, participate in any interactive features of our services, fill out a form, use your credit or debit cards, request customer support, or otherwise communicate with us.

· We may obtain information through our mobile applications that you install on your mobile devices to access and use our services.

· We may also collect other information, such as video footage of you whenever you step into any of our branches, telephone conversations when you call any of our contact centre lines, or geographic information.

We are the custodians of data on behalf of the users that use our services, and we do not own data; users own their data. We will store the data provided for only the period within which it is reasonably needed.

WHAT WE DO WITH YOUR INFORMATION

The collection and use of personal data by PFI FINANCE COMPANY LTD (PAYPADY) is guided by certain principles. These principles state that personal data should:

• Be processed fairly, lawfully, and in a transparent manner.
• Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with such purposes.
• Be adequate, relevant, and limited to what is necessary to fulfill the purpose of processing.
• Be accurate where necessary, up to date. In the event that data is inaccurate, steps should be taken to rectify or erase such data.
• Not to be kept for longer than necessary for the purpose of processing.
• Be processed in accordance with the data subject’s rights, and
• Be kept safe from unauthorised processing and accidental loss, damage, or destruction using adequate technical and organisational measures.

Any personal information provided by you to PFI FINANCE COMPANY LTD (PAYPADY) will be used with your consent or when we are required by law to do so. These include:

• Cases where processing of personal data is required for the fulfillment of a contractual obligation.
• Cases where processing of personal data is required for compliance with legal and/or regulatory requirements.
• Cases where processing is required to protect your vital interest or that of any other natural person.
• Cases where processing is required for an activity to be carried out in significant public interest.
• Cases where processing is required for the legitimate interests of PFI FINANCE COMPANY LTD (PAYPADY) or a third party, insofar as this does not conflict with the requirements for the protection of your personal data.

Your personal information will be used in;

• Updating and enhancing PFI FINANCE COMPANY LTD (PAYPADY) records.
• Executing your instructions.
• Establishing your identity and assessing applications for our products and services.
• Administering our products and services.
• Managing our relationship with you.
• Managing our risks.
• Identifying and investigating illegal activity (i.e.), such as fraud.
• Contacting you, for example in instances where we suspect fraud on your account or when the need arises to tell you about recent occurrences in the banking sector or some event(s) of significance.
• Conducting and improving our business and your experience with us.
• Preventing money laundering or terrorism financing activities.
• Complying with our legal obligations and assisting government and law enforcement agencies or regulators/supervisors.
• Identifying and informing you about other products or services that we think may be of interest to you.
• Processing your job application if you apply for a job with us.

We may also collect, use, and exchange your information in other ways permitted by law.

HOW LONG WE STORE YOUR INFORMATION

We retain your data for as long as is necessary for the purpose(s) that it was collected. Storage of your data is also determined by legal, regulatory, administrative or operational requirements.

We only retain information that allows us to comply with legal and regulatory requests for certain data, meet business and audit requirements, respond to complaints and queries, or address disputes or claims that may arise.

Data which is not retained is securely destroyed when it is identified that is no longer needed for the purposes for which it was collected.

WHERE WE STORE YOUR INFORMATION

All Personal Information you provide to us is stored on our secure servers as well as secure physical locations and cloud infrastructure (where applicable) for the purposes of providing seamless services to you, including but not limited to ensuring business continuity, the data that we collect from you may be transferred to or stored in cloud locations at globally accepted vendors' data center. Whenever your information is transferred to other locations, we will take all necessary steps to ensure that your data is handled securely and in accordance with this privacy policy.

SECURITY OF INFORMATION

We adopt appropriate technical, data collection, storage, and processing practices and security measures to protect against unauthorized access, misuse, alteration, disclosure, or destruction of your personal information, username, password, transaction information, and data under our control. This may include the use of encryption, access controls, and other forms of security to ensure that your data is protected.

We require all parties, including our staff and third parties processing data on our behalf, to comply with relevant policies and guidelines to ensure confidentiality and that information is protected in use, when stored, and during transmission. Our security controls and processes are also regularly updated to meet and exceed industry standards.

Where we have provided you (or where you have chosen) with a password that grants you access to specific areas of our site, you are responsible for keeping this password confidential. We request that you do not share your password or other authentication details (e.g., token-generated codes) with anyone.

DATA RETENTION

We retain your data for as long as it is necessary for the purpose(s) for which it was collected. The storage of your data is also determined by legal, regulatory, administrative, or operational requirements. We only retain information that allows us to comply with legal and regulatory requests for certain data, meet business and audit requirements, respond to complaints and queries, or address disputes or claims that may arise.

Data that is not retained is securely destroyed when it is identified as no longer needed for the purposes for which it was collected.

CROSS-BORDER PERSONAL DATA TRANSFERS

PFI FINANCE COMPANY LTD (PAYPADY) is committed to protecting customers’ personal information regardless of where the data resides and to providing appropriate protection for where such data is transferred across borders, including outside of Nigeria. To ensure that these transfers are in line with permissible conditions outlined by the Nigerian Data Protection Regulation, we have taken appropriate and suitable safeguards to ensure that personal data will remain protected when cross-border transfers occur. These safeguards include transferring personal data to countries with adequate data protection regulations and ensuring that standard contractual clauses are in place to mandate that personal data is secured using best practices.

COOKIES

We use data collection devices such as “cookies” on our website and applications. “Cookies” are small text files stored on your computer; mobile devices whenever you visit a website. They assist us in providing services customized to your requirements and tastes. Cookies have many uses, such as memorizing your preferences to tailor your experiences while on our site– or to help us analyze our website traffic. PFI FINANCE COMPANY LTD (PAYPADY) uses cookies to improve your experience while on this site. We would like to let you know a few things about our cookies:

• Some cookies are essential to access certain areas of this site.
• We use analytics cookies to help us understand how you use our site to discover what content is most useful to you.

THIRD-PARTY SITES AND SERVICES

PFI’S websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices, and we will not be liable for any breach of confidentiality or privacy of your information on such sites. We encourage you to learn about the privacy practices of those third parties.

DISCLOSURE OF INFORMATION

Due to the existing regulatory environment, we cannot ensure that all your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this policy. By way of example (without limiting and foregoing), we may be forced to disclose information to the government, law enforcement agencies, our parent and/or subsidiaries, and third parties for the performance of a task carried out in the interest of the public, for the protection of your vital interests, for the performance of a contract to which you are a party, and also where you have expressly given us written consent to disclose the same.

YOUR INFORMATION AND YOUR RIGHTS

You have the following rights:

• The right to be told how we use your information and obtain access to your information.
• The right to have your information rectified or erased, or to place restrictions on processing your information.
• The right to object to the processing of your information, e.g., where the processing is based on our legitimate interests.
• The right to have any information you provided to us on an automated basis returned to you in a structured, commonly used, and machine-readable format or sent directly to another organization, where technically feasible (“data portability”).
• Where the processing of your information is based on your consent, the right to withdraw that consent is subject to legal or contractual restrictions.
• The right to object to any decisions based on the automated processing of your personal data, including profiling, and
• The right to lodge a complaint with the supervisory authority responsible for data protection matters.
• Request that your personal data be made available to you in a common electronic format and/or request that such data be sent to a third party.

If we have any information about you that is incorrect or if there are any changes to your details, please let us know so that we can keep our records accurate and up to date.

NOTIFICATION OF CHANGES TO PRIVACY POLICY

We review this privacy policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. The policy on this page and such revised policies become effective as of the time they are posted. Hence, our privacy policies will be dated to reflect the most recent update. We will notify you when any changes to our privacy policy have been made. We also encourage you to check this page from time to time for updates to this policy.

CONTACT

We are dedicated to protecting your privacy. If you have any questions, comments and request regarding this privacy policy please contact our Data Protection Officer at www.paypady.com or by email at hello@paypady.com. We will use reasonable efforts to respond promptly to requests, questions, or concerns.