USERS’ PRIVACY RIGHTS
This Policy describes the User’s privacy rights regarding Appzone’s collection, use, storage, sharing and protection of a User’s personal information on the Platforms and in respect of the Services.
Data Protection Officer
12B, Admiralty Way,
Your rights in relation to Your Personal Data are as follows:
(I) the right to have access to Your Personal Data;
(II) the right to be informed about the processing of Your Personal Data;
(III) the right to rectify any inaccurate Personal Data or any information about You;
(IV) the right to review, modify or erase Your Personal Data and any other information we have about You;
(V) the right to restrict the processing of Your Personal Data;
(VI) the right to block Personal Data processing in violation of any law;
(VII) the right to be informed about any rectification or erasure of Personal Data or restriction of any processing carried out;
(VIII) the right to the portability of Your Personal Data; and
(IX) the right to lodge a complaint to a supervisory authority within Nigeria.
USERS’ PERSONAL INFORMATION
Appzone collects and use any information you supply when you interact with the mobile app, you share personal details like your name, Bank Verification Number, Valid Identification, address and picture. By using the mobile app to transact, you also share details of your transactions with us. Additionally, we may request explicit permission to see other information like your address book, location, photos and data from your camera.
- Details you give when you sign up on the Mobile App, like your BVN, name, date of birth, gender, phone number, residential address, and email address.
- Images would also be collected for the purpose of KYC and other features like adding your profile picture.
- Information you give us through the in-app chat so we can help you.
- We shall also access your contact list information to enable you to perform certain functions like sending airtime and data to a person on your contact list.
- We collect certain information from the User’s browser using small data files called “cookies”. The Platform may use session cookies to help recognize a User who visits multiple pages during the same session so that the User does not have to enter a password to access each page. Session cookies terminate once the User closes the browser.
- We also use persistent cookies to collect, store and track information. The Platform uses persistent cookies to store the User’s login ID (but not the User’s password) to make it easier for the User to login when the User returns to the website. We encode our cookies so that only us can interpret the information stored in them. You can remove or block persistent cookies using the settings in your browser, but this may limit your ability to use our Platform.
- We may employ a software technology called clear gifs or web beacons that help us better manage content on the Platform as well as on the Platform emails, by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar function to cookies and are used to track the online movements of the Web users. In contrast to cookies, which are stored on a User’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence.
Appzone will always comply with the principles outlined below for the purpose of collecting, storing and using a User’s personal information.
- Data shall be collected and processed with a specific, legitimate and lawful purpose which shall be consented to by the User before collection and processing;
- Data may be further processed for archiving, scientific research, historical research and statistical purposes for public interest without obtaining the consent of the User;
- Data collection and processing shall be adequate, accurate and with consideration for the dignity of the human person;
- Data shall only be stored for the period which is reasonably needed and as required by the relevant and applicable laws; and
- Data shall be secured against all foreseeable hazards and breaches such as theft, cyberattack, viral attack, dissemination, and manipulations of any kind.
The lawful basis we rely on for processing your Personal Information are:
- Your consent; Where you agree to us collecting your Personal Information by using our Services.
- We have a contractual obligation: Without your Personal Information, we cannot provide our Services to you.
Appzone also has a legal obligation to ensure full compliance with all Anti-Money Laundering and Counter-Terrorist Financing Laws. Appzone protects against fraud by checking your identity with your Personal Information.
SHARING AND PROTECTION OF USERS’ PERSONAL INFORMATION TO THIRD PARTIES
Appzone may share User information with law enforcement agencies, government officials, or other third parties in the event of a court order or similar legal procedure, regulatory disclosure or when Appzone believes in good faith that the disclosure of User information is necessary or advisable to report suspected illegal activity or to protect Appzone’s property or legal rights.
SECURITY OF USERS’ PERSONAL INFORMATION
Appzone has implemented physical, technical, and procedural safeguards to protect User information from unauthorized access, disclosure, alteration, or destruction. Appzone uses computer safeguards such as firewalls and data encryption and authorizes access to personally identifiable information only for those employees, contractors, and agents who require it to fulfil their job responsibilities.
Appzone utilizes a higer duty of care to protect User information, such as credit card or bank account numbers, if disclosure of a particular type of User information could cause direct financial loss, Appzone further encrypts such information and transmits it under Secure Socket Layer (SSL).
Appzone shall only retain personal information reasonably required to keep providing Services to you. Where we no longer provide services to you, your information will be stored on our servers to the extent necessary to comply with regulatory obligations and for the purpose of fraud monitoring, detection and prevention. Where we retain your Personal Information, we do so in compliance with limitation periods under the applicable law.
DATA CONFIDENTIALITY RIGHTS
REPORTING A PERSONAL DATA BREACH
Appzone is required to comply with the Nigeria Data Protection Regulation 2019 (“NDPR”) and other relevant laws and regulations regarding reporting requirements in relation to data breaches and report any personal data breach where there is a risk to the rights and freedoms of a User. Where a personal data breach results in a high risk to a User, such a User also has to be notified unless subsequent steps have been taken to ensure that the risk is unlikely to materialise, security measures were applied to render the personal data unintelligible (e.g. encryption) or it would amount to disproportionate effort to inform the User directly. In the latter circumstances, a public communication must be made, or an equally effective alternative measure must be adopted to inform such a User, so that he/she can take any necessary remedial action.
CHANGES TO THIS POLICY
This Policy is made according to the provisions of NDPR and any other relevant Nigerian laws, regulations or international conventions applicable to Nigeria.