PRIVACY POLICY

Who We Are

PocketMoni is a Product of eTranzact International Plc (hereinafter referred to as both “Data Processor and Data Controller”). It is a digital Wallet that enables Users to make bank transactions, pay bills, create social contributions, trade in stocks, and purchase other value-added services.

As a Data Processor and Controller, eTranzact is up-to-date with compliance of relevant data protection laws, including; Constitution of Federal Republic of Nigeria, Nigeria Data Protection Act (NDPA) 2023 (including regulations made thereof) and all other legal instruments designed to protect the privacy rights of natural persons.

Bearing in mind our duty to protect the personal data of Data Subjects (Users), who use our Services via the Website or Portal and obtaining your consent to process, store and access the Data which we will require to provide the best Services, we have hereunder, outlined the basis for Data collections and procedures for dealing with such Data.

This Privacy Policy is therefore designed to inform you in the simplest language about the personal data we collect, how it is collected, uses of the data and your rights relating to Personal Data when you use this Service.

Consent of a Data Subject (User)

As a User of our Services you have the right to protection of your personal data which you supply. Except as otherwise required by law, you have the rights over your data as stated in this Policy. However, by continuing to use this Service, and acceptance of this Policy, you have unequivocally consented to the use, storage and processing of the data which you supply in the course of use of our Services.

Purpose of Collection and Processing of Personal Data

eTranzact collects your personal data for the following purposes:

• to provide our Services to you.
• to develop new Products and Services on the Application.
• to provide analytics on how our Services are used and Users preference.
• to respond to your feedback and resolve complaints.
• for other legal basis as may be required for regulatory compliance.

Nature of Data Collected

The specie of Data collected and processed is dependent on the particular use and consent of User of the Service. Therefore, each Data is collected only for the particular requirement and purpose; however, certain data are compulsory in order to provide you the Services. If you withhold such data, it may be difficult to provide such Service. The specie of data collected include;

• Personal Name
• Residential Address
• Picture
• Phone Number
• Email Address
• Bank Verification Number (BVN)
• Date of Birth
• Card PIN, PAN and CVV
• Wallets Number
• Wallet PIN
• IP address of device
• IMEI number
• Means of Identification

Storage and Protection of Data

Our Website/Application has been built with strong security features that ensures personal data you provide is continually protected using encryption, firewalls, secured file transfer protocol and strict access control while they are stored and processed within our system. Also present are security features that ensures detection and blockage of threats to data storage. Personal data you provide may be stored in any form including onsite server, Cloud and any other method that ensures its security, access and processing in accordance with the Service provision and request.

Non-Disclosure of Personal Data

We do not disclose personal data to Third-Parties except on the following grounds:

• where you have expressly granted a consent to share such data;
• compliance with relevant regulatory or law enforcement directive;
• for the purpose of providing you the Services, we may disclose the information to any of our business Partners or external Data Processor who are under confidentiality and data protection obligation in provision of such Service.

Cookies

Cookies are small files with small pieces of data placed on your computer’s hard drive that enable the website to identify your computer as you view different pages. Cookies allow websites and applications to store your preferences in order to present contents, options or functions that are specific to you. Like most interactive websites, our website uses cookies to enable the tracking of your activity for the duration of a session and to distinguish you from other users of our websites. This provides you with a better browsing experience and allows us to improve our websites. Users have the preference to select the limits of collections of cookies on the Site.

Links to Third-Party Sites/Services

Links to Third-Party Sites aimed at giving you options to Third-Party services or information may be found in our Website. It is entirely your choice to click on those Sites as this policy would not apply to the protection of your data in such Third-Party sites. You are advised to contact those Sites directly for information on their privacy policy.

Alteration of Privacy Policy

In order to remain up to date with provision of the Services or regulatory requirement, we reserve the right to alter, modify or change this Policy. Such update shall be made available for your acceptance on the Website/App, and it is your duty to constantly check the Site for updates. Any change shall not affect the safety of data already stored.

Your Privacy Rights

You have the following rights under the Nigeria Data Protection Act, 2023 and other relevant regulations:

• right to information on how your personal data is processed
• right of access to your personal data
• right to withdraw consent at any time
• right to object to processing of your data
• right to rectification of your data
• right to request electronic transfer of your data to another entity
• right to lodge a complaint to the supervisory authority-Nigeria Data Protection Commission (NDPC).