PRIVACY POLICY

This privacy policy discloses the privacy practices of Adashe mobile application, website and all services provided (collectively platform) which operates as a financial savings platform owned by ADASHE FINANCE LIMITED (Herein after referred to Adashe, we, our, us) collects, uses, stores, and discloses information collected from our consumer users (“Users”, “you”). This policy describes what information we collect about you, how we collect and use the information you share with us, and with whom we share that information. You don’t have to share any information with us, but to use our services, we’ll need some information from you. This policy also contains information about when we share your personal information with third parties (such as our service providers and credit bureaus).

This privacy policy applies solely to information collected by this platform. It will notify you of the following: 

What personally identifiable information is collected from you through the platform, how it is used and with whom it may be shared. 

The choices available to you regarding the use of your data. 

Security procedures in place to protect misuse of your information. 

How you can correct any inaccuracies in the information. 

You agree and understand that the Company is responsible for operation and maintenance of the platform and all information collected and processed on the platform is collected and processed by us strictly in relation to our business.

By using our platform, you confirm that you have read, understood, and agree with the privacy practices described in this PRIVACY POLICY, and the Terms of Use (the “Terms”) and the collection, storage and processing of your information in accordance with them.

INFORMATION COLLECTION

When you access the platform, you may provide, or we may collect information that may specifically identify you or any other individual. Given below are the types of information that we may collect:

Information you give us: we receive and store any information you enter on our platform. When you register on the platform, we collect registration details such as phone number, name, geographical address, email address, BVN, password, bank account details. You can choose not to provide certain information, but then you may consequently not be able to take advantage of many of our features.

Information from other sources: When you create an Adashe 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. We also work closely with third parties (including financial service providers, security agencies, etc) and will notify you when we receive information about you from them and the purposes for which we intend to use that information.

Information about personal transactions: As you use your Adashe account to perform financial transactions, we collect Personal Data in connection with each transaction, including transaction time and amount. 

Automatic Information: We (or our service providers acting on our behalf) may collect information about your use of our platform. 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 platform may include:

Device Information: We may collect Device-specific information (such as hardware model, operating system version, unique Device identifiers, and mobile network Information, including your mobile phone number). We may associate your Device identifiers or mobile phone number with your Adashe account. 

Log Information: We may record or log information from your Devices, their software, and your activity accessing or using our Platform. This information may include: 

The Device's Internet Protocol ("IP") address 

Identification numbers associated with your Devices

Device event information, such as crashes, system activity, and hardware settings

Date and time stamps of transactions 

System configuration information 

Other interactions with our Service 

Location Preferences: We may collect your location information from your mobile device with your prior consent. Also, we have incorporated Google Maps into our Platform, and you may consent to the collection of location information by Google Maps in connection with your use of this maps service. Any information collected via your use of Google Maps will be transmitted directly to Google and is not collected by us. Please refer to Google’s privacy policy for details about their collection, use and sharing of this information. 

Information Collected by Cookies and Other Tracking Technologies: We use cookies to personalize our platform and services for you as well as to collect aggregate data about how our platform is used. A cookie is as defined in paragraph 5 below. Cookies are used for record-keeping and to improve the quality of your use of our platform. The cookies assign random, unique numbers to your devices so that our systems can recognize them and see how you use our platform. We collect information on our platform using various technologies, which may include sending cookies to your computer or mobile device. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. 

Do Not Track Signals: Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser. We allow Do Not Track browser configurations. We use cookies and other tracking technologies, and Do Not Track status may alter the available services with certain browsers, when these tracking functionalities are used to provide services. We do not alter the information our applications attempt to collect based on your Do Not Track configuration

GOVERNING LAW

This privacy policy is in compliance with the Constitution of Federal Republic of Nigeria and Nigeria Data Protection Regulation rules (NDPR) as related to protection of personal data by government agencies or private establishments. The NDPR regulates the collection, usage, retention and disclosure of personal data, and defines PERSONAL DATA as;

“means any information relating to an identified or identifiable natural person (‘Data Subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; It can be anything from a name, address, a photo, an email address, bank details, posts on social networking websites, medical information, and other unique identifier such as but not limited to MAC address, IP address, IMEI number, IMSI number, SIM, Personal Identifiable Information (PII) and others;”

CONSENT FOR COLLECTION OF DATA:

Collection, use and disclosure of personal information requires your express consent according to the NDPR regulation, this consent is automatically given by you once you make use of our platform. You may choose to not provide us with personal information, but in the event that you do so, we will be unable to provide you access to our platform or access to the services on our platform.

HOW DO WE USE THE INFORMATION WE COLLECT?

We use information we collect, in a variety of ways in order to provide the services on the platform and the site and to operate our business, including the following:

To carry out our obligations arising from your requests for the services on the platform;

To operate and improve the platform in order to foster a positive user experience and to improve our business as a whole;

Verify your identity and prevent fraud. 

Send you technical notices, updates, security alerts and support and administrative messages. 

Respond to your comments, questions and requests and provide customer service

Communicate with you about products, services, offers, promotions, rewards, and events offered by Adashe, and provide news and information we think will be of interest to you. 

Monitor and analyze trends, usage and activities in connection with our Services. 

Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests. 

Process and deliver contest or promotion entries and rewards. 

Link or combine with information we get from others to help understand your needs and provide you with better service. 

Carry out any other purpose for which the information was collected.

To conduct audits and quality assessment procedures;

To analyze the use of our resources, troubleshooting problems and improving our products and services, by using the information regarding your mobile device and software.

To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our terms, or as otherwise required by law;

We also use your information to respond to you when you contact us for complains;

To investigate complaints or concerns based on our legitimate interest to ensure that such complaints or concerns are addressed appropriately; 

To send optional customer satisfaction surveys once your complaint has been resolved based on our legitimate interest to continue to improve our processes;

To contact you, by way of SMS, email and phone calls, from time to time to record your valuable feedback on our services, as they currently stand, and/or any potential products and services that may be offered in the future.

MODE OF COLLECTION OF INFORMATION:

We utilize “cookies” and other tracking technologies. A “cookie” is a small text file that may be used, for example, to collect information about activity on the platform. Some cookies and other technologies may serve to recall information previously indicated or submitted by a user. Most browsers/mobile settings allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers/mobile application to notify you if you receive a cookie, or you may choose to block cookies with your browser/mobile applications. However, by doing so, you may not be able to use certain features on the platform or take full advantage of all the offerings and interest-based advertising. You can remove cookies by following directions provided in your mobile’s “help” file or the browser.

We may use “cookies” information and “automatically collected” information we collect on the service to (i) personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the service; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of the service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the service. 

We may access or store your information if it is necessary to detect, prevent or address fraud and other illegal activity or to protect the safety, property or rights of ADASHE or other third parties’ providers.

We may collect, analyze, use, publish, create and sell de-identified information, of which your personal or sensitive personal information might be a component, for any business or other purpose not prohibited by applicable law, including for research and marketing purposes. (collectively “purposes”).

Tracking technologies may record information such as internet domain and host names, internet protocol (IP) addresses, browser software and operating system types, stream patterns, and dates and times that our site or app is accessed. Our use of cookies and other tracking technologies allows us to improve our site or the app and your experience.

DO WE SHARE INFORMATION WE RECEIVE?

Information about you and the other users of the platform forms an integral part of our business. We only share the personal information as described below: 

If you request or authorize it;

If the information is provided to help complete a transaction for you;

If the information is required 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; or 

     (c) prevent a crime or in interest of national security; or 

(d) protect our rights, property, or safety or the rights, property, or safety of our users or others (e.g., to a consumer reporting agency for fraud protection, etc.); 

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); 

For our everyday business purposes;

Sharing with third party service provider: We may also share your personal date with a third party after ensuring that such third party has implemented measures to assure data protection measures and that are either subject to this privacy policy or follow practices at least as protective as those described in this privacy policy. By using the site or the platform, you accept the terms hereof and hereby consent to the storage and processing of the personal information by third parties. We, have arrangements with third parties (including as mentioned below) such as affiliates or group companies, service providers, banks, payment gateways, who are the intended recipients and may have access to the personal data but shall not disclose such information to any other individual / entity. 

Sharing upon merger or amalgamation or intra-group transfer: Any third party to which we transfer or sell our assets, merge or consolidate with, will have the right to continue to use the information (personal data) provided to us by you, in accordance with the terms and this privacy policy. We may disclose information to our partners, affiliates, subsidiaries, group entities, investors, stakeholders or potential associates in an anonymized and aggregate manner, so that they too may understand how users use our site or app and enable us to create a better overall experience for you; and

By using the platform, you accept the terms hereof and hereby consent to us, sharing and/or processing your personal data with third parties and in any of location and outside Nigeria. We will make best efforts to ensure that the third party or the location to which the personal data is transferred accords same level of data protection as would be afforded under the Nigerian law.

When you are no longer our User, we may continue to share your information as described in this Privacy Policy. We may disclose Analytics with third parties as described elsewhere in this Privacy Policy and for our commercial purposes.

HOW WE SECURE YOUR INFORMATION?

We maintain electronic, physical and procedural safeguards in connection with the collection, storage and disclosure of personal information (including sensitive personal information). Our security procedures may warrant that we may occasionally request proof of identity before we disclose personal information to you.

We work to protect the security of your information during transmission by using secure sockets layer (SSL) software, which encrypts information you input in addition to maintaining security of your information as per the international standards on "information technology security techniques information security management system-requirements".

We restrict access to personal information, to our employees and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations, and may be disciplined or whose relationship with us may terminate if they fail to meet these obligations.

No employee or administrator will have knowledge of your password of your account on the site or platform. It is important for you to protect your account against unauthorized access to your password and your mobile phone, as detailed in the ‘user account, password and security’ section of the terms. You must be sure to log off from the site or platform when you have finished use thereof. We do not undertake any liability for any unauthorized use of your account and password.

If you suspect any unauthorized use of your account, you must immediately notify us by sending an email to the contact details indicated in the contact section. You shall be liable to indemnify us due to any loss suffered by us due to such unauthorized use of your account or password.

Under certain circumstances, we shall not be able to take your prior consent before disclosing your information in case the information is demanded by government agencies or otherwise mandated under law to obtain personal data, or during investigation of cyber incidents, prosecution of offenses etc.

Further, we shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond our reasonable control including but not limited to acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of internet service or telephone service of the user, etc.

No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your username and password for your Adashe account and do not share them with others. If we receive instructions using your Adashe account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your account or any other breach of security. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate accounts, and to remove or edit content.

ACCESS AND CONTROL OVER INFORMATION

You may opt out of any future contacts from us at any time. You can do the following at any time by contacting us via the email address or phone number given on our website: 

   • See what data we have about you, if any. 

   • Change/correct any data we have about you. 

   • Have us delete any data we have about you. 

   • Express any concern you have about our use of your data. 

Should you choose to update your personal data or modify it in a way that is not verifiable by us, or leads to such information being incorrect, we will be unable to provide you with access to our site or platform, as described under the terms, and such modification may be regarded as the user seeking to discontinue his or her access to our site, app or the services.

We reserve the right to verify and authenticate your identity and your personal information in order to ensure accurate delivery of products and services. Access to or correction, updating or deletion of your personal data may be denied or limited by us if it would violate another person’s rights and/or is not otherwise permitted by applicable law.

You can also opt to delete: If you would like to delete your account or personal data that you have provided to us or that you believe we may have collected about you, please follow the steps below

IOS/ANDROID

• Click on account 

• Click on delete account 

• Click on the checkbox 

• Click on Delete 

• Account deletion Successful 

ACCEPTANCE OF TERMS

By using this Application, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our application. Your continued use of  our platform following the changes to this policy will be deemed your acceptance of those changes.

ARE CHILDREN ALLOWED TO USE THE PLATFORM?

By accessing or using the Platform, or by otherwise giving us your information, you confirm that you have the capacity to enter into a legally binding contract under Nigeria law. 

If you are under 18 years of age, then please do not use or access the platform at any time or in any manner. If we learn that a person under 18 years of age has used or accessed the platform or service or any personally identifiable information has been collected on the platform from persons under 18 years of age, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an account on or otherwise accessed the service, then you may alert us at [email protected]  and request that we delete that child’s personally identifiable information from our systems.

DISCLAIMER ON OTHER WEBSITES:

This Policy applies only to our platform and website policies, practices, technologies, and services. Our online properties may include links to websites and online services that are operated by other companies not under the control or direction of Adash. If you provide or submit personal data to those websites or online services, the privacy policies on those websites or online services apply to your personal data. We encourage you to carefully read the privacy policies of any website you visit.

UPDATES 

Our Privacy Policy may change from time to time and all updates or changes will be posted on the platform, website or sent to you via email. 

HOW TO CONTACT US

If you have any questions about this Privacy Policy or your dealings with our platform, please contact us by mail at [email protected]