1. Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses;
2. Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies. Details of your visits to the website including, but not limited to, location data, weblogs and other communication data.

Other information and data about you which we may collect, use, and process include the following:

1. Transaction history Information that we may receive about you from other sources such as credit information;
2. Records of correspondence received via the website, email & telephone.
3. Your responses to surveys or customer research that we carry out from time to time;
4. Details of the transactions you carry out with us via the website, telephone or other means, including details of payment methods used.

Purpose Limitation

We collect Personal Information only for identified purposes and for which consent has been obtained. Such Personal Information cannot be reused for another purpose that is incompatible with the original purpose, except consent is obtained for such purpose.

Data Processing Principles

Your personal data will be:

1. collected and processed in accordance with specific, legitimate, and lawful purposes, consented to by you;
2. adequate, accurate and without prejudice to the dignity of the human person;
3. stored only for the period within which it is reasonably needed; and
4. secured against all foreseeable hazards and breaches such as theft, cyberattack, viral attack, dissemination, manipulations of any kind, damage by rain, fire, or exposure to other natural elements.

Data Minimization

We limit Personal Information collection and usage to data that is relevant, adequate, and necessary for carrying out the purpose for which the data is processed. We will evaluate whether and to what extent the processing of Personal Information is necessary and where the purpose allows, anonymized data will be used.

Our Lawful Basis for Processing Personal Information

We use your Personal Information to furnish our contract with you, such as when we provide you with products or services or communicate with you about them. This includes when we use your personal information to take and handle orders and process payments.

Additionally, we will only use and process your personal data as permitted by the Nigerian Data Protection Act, 2023. We have set out below a description of all the legal basis we may rely on to process your personal data:

1. Where you have given us consent to the processing of your personal data for one or more specific purposes;
2. where processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract;
3. where processing is necessary for compliance with a legal obligation to which we are subject;
4. where processing is necessary to protect your vital interests or the vital interests of another natural person;
5. where processing is necessary for the performance of a task carried out in the public interest or in exercise of an official public mandate vested in us, and;
6. for the purpose of the legitimate interests pursued by us as data controller or data processor, or by a third party to whom the data is disclosed.

1. We may use your personal information and data together with other information for the purposes of processing, operating and managing your Pivuka Account.
2. To maintain legal and regulatory compliance; most of our core Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, Pivuka must identify and verify customers using our Services in order to comply with Anti-Money Laundering laws across jurisdictions. This includes collection and storage of your business records. In addition, we use third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. When you seek to link a bank account to your Pivuka Account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. If you do not provide personal information required by law, we will have to close your account.
3. Regularly providing you with information about promotional offers, products and services.
4. Monitoring transactions for the purposes of preventing fraud, irregular gaming, money laundering and cheating.
5. Conducting screening of customers against Politically Exposed Persons (PEP) and global sanctions lists, global monitoring watchlists and adverse media to avoid violating various sanctions.
6. To provide customer service; We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
7. To ensure quality control; We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions.
8. To ensure network and information security; We process your personal information in order to enhance security, monitor and verify identity or service access, combat other malware or security risks, and to comply with applicable security laws and regulations in our jurisdiction.
9. For any purpose that you provide consent; we will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time, and as required under applicable law, we may request your permission to allow us to share your personal information with third parties. In such instances, you may opt out of having your personal information shared with third parties or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to limit the use of your personal information, certain features of Pivuka Services may not be available to you.
10. Pivuka will also process your personal data for the purpose of carrying out verification procedures in relation to your use of the services provided on the website. We may also use your information to improve our products and services and track/target the interest of our users so that we can enhance user experience.

1. Right to request access to your personal data (commonly known as a "data subject access request"): This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may notify you of our refusal to comply with your request in these circumstances. Where we have reasonable doubts concerning the identity of the natural person/customer making the request for information, we may request the provision of additional information necessary to confirm the identity of the Data Subject. Where data is held electronically in a structured form, such as in a Database, as the Data Subject, you have a right to receive that data in a common electronic format;
2. Right to request correction of the personal data that we hold about you: This enables you to have any incomplete or inaccurate data we hold about you corrected, complete or updated, though we may need to verify the accuracy of the new data you provide to us.
3. Right to request erasure or deletion of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing 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 the processing of your personal data (see below), 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 for the erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Right to object to the processing of your personal data: Where we rely on a legitimate interest (or those of a third party), there may be something about your situation that could justify an objection to processing on this ground as you may feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling, legitimate grounds to process your information, which overrides your rights and freedoms.
5. Right to request restriction of processing of your personal data: This enables you to ask us to suspend the processing of your personal data in the following scenarios:
   1. If you want us to establish the data's accuracy;
   2. Where our use of the data is unlawful but you do not want us to erase it;
   3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
   4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer/portability of your personal data to you or to a third party: We will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Right to withdraw consent at any time where we are relying on consent to process your personal data: This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent. Your request will be reviewed by us and carried out except as restricted by law or our statutory obligations. You may decline to provide your Personal Information when it is requested by us, however, certain services or all services may be unavailable to you. You may review and update your Personal Information directly or by contacting us.
8. Right to be informed: To know what personal data is collected about, and how long it is kept. The right to be informed gives you the ability to understand what personal data we collect about you and how long we retain it. This ensures transparency in how we handle your information, helping you make informed decisions about your data privacy.
9. Right to be Forgotten or Deletion: This right allows you to request the removal of your personal data from our records. This right empowers you to have your information erased when it is no longer necessary for the purpose it was collected or if you withdraw your consent.

Information Storage and Protection

Pivuka will take all reasonable steps to ensure that your information is secured and protected. We will process your information in compliance with the relevant provisions of the Nigerian Data Protection Regulation 2019 and the General Data Protection Regulation as applicable. We will only disclose personal information to other companies within associated or subsidiary companies and to business partners; successors in title to our business and suppliers that are engaged to process such information on our behalf. If you apply for an account with us then to help us make credit decisions about you, to prevent fraud, to check your age and identity and to prevent money laundering, we may use third parties including credit reference agencies who will record any searches on your file. We may also make enquiries of and disclose details of how you conduct your account to such agencies, security organizations and any other relevant third parties for fraud and money laundering prevention.

However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us using the contact information provided in the "Contact Us" section below.

What Are Cookies?

Cookies are small pieces of information sent from your browser to our server that allow us to recognize your device. They help us streamline your experience on our Website/App, manage essential functions, and ensure our services are tailored to your preferences.

Why We Use Cookies

When you register with us or continue to use the Website/App, you agree to our use of cookies for the following purposes:

1. Improving Usability: To make your visit to the Website user-friendlier by remembering preferences and simplifying navigation.
2. Managing Customer Logins: To streamline the login process, making it easier and more secure for returning users.
3. Security: To protect against security issues and unauthorized access, helping to safeguard user data.
4. User Preferences: To remember customer preferences such as language settings and personalized content, so you can have a consistent experience across sessions.

We do not set a persistent cookie to store your passwords to ensure that no one other than you can access your account.

Your Privacy and Data Protection

We take all reasonable steps to handle your information securely and in line with the NDPA 2023 and NDPR 2019. Our use of cookies is limited to purposes that enhance security and usability, and we maintain adequate security measures to prevent unauthorized access and ensure your data's safety.

Third-Party Cookies and Sharing of Information

All cookies used on our website/app are maintained and implemented either directly by us or by authorized third parties. We may work with third-party service providers to collect information about how you interact with our website/app. We are likely to disclose cookie-generated data to third-party processors who help us provide, protect, and improve our services.

These third parties may process your data in compliance with applicable data protection laws, and they may be located outside Nigeria. We ensure that such third parties implement adequate safeguards to protect your data, in line with our obligations under the Nigeria Data Protection Act 2023. If you have any questions about our third-party service providers, you can contact us at: [email protected].

Managing Cookies

You have the option to manage or disable cookies through your browser settings at any time. However, disabling cookies may affect your experience on our website/app, as some features rely on them.

For questions regarding this Cookie Clause or our privacy practices, please contact us at ( [email protected] ).

1. Conform to the law or comply with legal processes served on Pivuka or the site;
2. Protect and defend the rights or property of Pivuka and,
3. Act under exigent circumstances to protect the personal safety or property of users of Pivuka, or the public in the event of a claim or dispute regarding your use of our services.

1. the consent of the Data Subject has been obtained;
2. the transfer is necessary for the performance of a contract between us and the Data Subject or implementation of pre-contractual measures taken at the Data Subject's request;
3. the transfer is necessary to conclude a contract between us and a third party in the interest of the Data Subject;
4. the transfer is necessary for reason of public interest;
5. the transfer is for the establishment, exercise, or defense of legal claims;
6. the transfer is necessary to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent.

1. the contract terms agreed between us and the Data Subject or as long as it is needed for the purpose for which it was obtained; or
2. where the relationship has statutory implication or a required retention period; or
3. where there is an express request for deletion of the Personal Information by the Data Subject, provided that such request will only be treated where the Data Subject is not under any investigation which may require us to retain such Personal Information or there is no subsisting contractual arrangement with the Data Subject that would require the processing of the Personal Information; or
4. where we have another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.

1. Personal information collected to comply with our legal obligations under financial or anti-money laundering laws may be retained after account closure for as long as required under such laws;
2. Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe. Thereafter we will add your details to our suppression list to ensure we do not inadvertently market to you;
3. Content that you post on our Site such as support desk comments, photographs, videos, blog posts, and other content may be kept after you close your account for audit and crime prevention purposes (e.g., to prevent a known fraudulent actor from opening a new account);
4. Records of our telephone calls with you may be kept for a period of up to six years;
5. Information collected via technical means such as cookies, web page counters and other analytics tools is kept for a period of up to one year from the expiry of the cookie.

Age Restriction

If you access our services or platform and you are below 18 years, you represent and warrant that you have obtained consent from your parent(s) or legal guardian(s). If you have inadvertently provided personal data of a child to us, please notify us at (insert DPO email address) and we will delete such personal data.

Consistent with Section 8 of the Nigeria Child Rights Act ("the Act"), Cap C50, Laws of the Federation of Nigeria 2010, Section 31 of the Nigeria Data Protection Act 2023, we will never knowingly request Personally Identifiable Information from anyone below the age of 18 under the Act without prior verifiable parental consent. If we become aware that a child below the age of 18 under the Act has provided us with personal data without verifiable parental consent, we will use our best efforts to remove such information from our database. If as a parent or guardian, you become aware that your child or ward child has provided us with any information without your consent, please contact us through the contact details provided in this Privacy Policy.

Compliance

1. Constitution of the Federal Republic of Nigeria 1999 (as Amended);
2. Nigeria Data Protection Act 2023 ("NDPA");
3. Nigeria Data Protection Regulation 2019 ("NDPR");
4. NDPR 2019 Implémentation Framework;
5. Nigeria Cybercrimes (Prohibition, Prevention, Amendement) Act 2024;
6. Nigeria Money Laundering (Prevention and Prohibition) Act, 2022;
7. Nigeria Federal Competition and Consumer Protection Act, 2018 (FCCPA);
8. Nigeria Freedom of Information Act 2011;
9. Central Bank of Nigeria Risk-Based Cybersecurity Framework and Guidelines for Other Financial Institutions 2022.