Privacy Policy

Introduction

This Data Privacy and Protection Policy (the "Privacy Policy") describes your privacy rights regarding SPENDIVE LIMITED's ("we", "the Company", "us", or "our") collection, use, storage, sharing, transfer, and protection of your personal identifiers, network activity information, professional data, location information, and other types of information. It applies to our platform, website, and all related sites, applications, services, and tools (the "Services"), regardless of how you access or use them.

This Privacy Policy covers all systems, operations, and processes within our environment that involve the collection, storage, use, transmission, and disposal of Personal Information (as defined below). It is provided to help you understand what information we collect from you, how we use it, how we safeguard it, the legal grounds upon which we process it, and the rights you have in relation to your personal information. This Policy applies solely to the Services provided by SPENDIVE LIMITED and does not extend to third-party platforms or services not controlled by us. We are committed to handling all personal data provided to us in compliance with applicable laws and best practices, including the Nigeria Data Protection Regulation (NDPR), Nigeria Data Protection Act 2023 (NDPA), and, where appropriate, elements of international frameworks such as the General Data Protection Regulation (GDPR).

The Information We Collect

Personal Information

As part of our operations, we collect and process certain types of information that identify you. This includes current, past, and prospective employees, merchants, suppliers/vendors, customers, registered users ("Users"), and other individuals ("Data Subjects") with whom we communicate or conduct business. To use our Services, you voluntarily provide us with Personal Information, which may include both direct identifiers and information that, while anonymized initially, can later be associated with you (for example, IP addresses). We may collect the following information:

• Name, username, gender, and date of birth;
• Email address, postal address, and telephone number;
• Interests and other personal details you choose to provide;
• Any other information that may be required to deliver our Services.

We use your personal information to:

• Administer your accounts and process orders or applications;
• Send you details about our products and services, including important updates and changes to terms or policies;
• Carry out marketing analyses and improve our website and Services;
• Obtain your views or comments on our Services;
• Plan promotional activities and deliver tailored marketing communications (for non-essential communications, we obtain your explicit consent beforehand);
• Personalize your experience on our site;
• Allow you to apply for and evaluate your eligibility for various products or services (including prequalification for loans, account openings, etc.);
• Verify your identity and/or location to secure your account and prevent fraudulent activities;
• Enable participation in market research, surveys, contests, and other promotional activities, each potentially having its own specific rules;
• Support business purposes such as data analysis, audits, product development, and risk management;
• Comply with legal obligations, including law enforcement requirements, when necessary;
• Access additional data from trusted third-party verification or identification services (such as your financial institution or payment processor) where required and with your consent.

In addition, we record details of your transactions and other interactions with our Services once you begin using our platform. We will not share or disclose your Personal Information to any third party without your consent, except as required to provide the Services or as mandated by applicable legislation.

Information from Platform Visitors

When you visit our website or platform, we collect only the Personal Information for which you have given explicit consent. For monitoring and improving our platform and Services, we also collect non-personally identifiable information. This information is used solely for purposes such as customizing advertisements and enhancing user experience and will not be shared with third parties except as necessary for providing our Services.

Purpose Limitation

We collect and process Personal Information solely for the purposes explicitly identified at the time of collection. Such data will not be reused for any other purpose that is materially incompatible with the original purpose, unless further consent is obtained.

Data Processing Principles

Your personal data will be:

• Collected and processed only for specific, legitimate, and lawful purposes with your consent when required;
• Maintained in an accurate and up-to-date form;
• Stored only for the period during which it is reasonably necessary or as required by law, after which it will be securely disposed of or anonymized using appropriate security measures; and
• Secured against foreseeable risks, including theft, cyberattack, unauthorized disclosure, loss, or accidental damage caused by physical or natural hazards.

Data Minimization

We limit the collection and retention of Personal Information to only that which is relevant, necessary, and adequate for fulfilling the stated purposes. Where possible, anonymized data may be used to further reduce risks associated with retention of directly identifiable data.

Cookies and Automated Data Collection

A "cookie" is a string of information which assigns you a unique identifier that we store on your computer. We use cookies to recognize you as a User and improve your experience on our Services. Cookies help us to customize content, secure your account, track website usage, and prevent fraudulent activities. In this regard, Essential Cookies are necessary to enable the basic functionalities of the website and to secure your access.

Non-Essential Cookies are used for advertising, analytics, and personalization. We will obtain explicit consent from you before deploying non-essential cookies.

Cookies do not store personal or sensitive information directly. If your browser allows, you may disable cookies; however, please note that doing so may affect your overall experience with our Services.

We reserve the right to make changes to this Cookie Policy at any time and for any reason. We will alert you about any changes by updating the "Last Updated" date of this Cookie Notice. Any changes or modifications will be effective immediately upon posting the updated Cookie Notice on the Site, and you waive the right to receive specific notice of each such change or modification.

Information Automatically Collected from Your Computer

Our servers, as well as those of our third-party service providers, automatically collect certain technical information when you access our Services, including:

Acceptable Use

The Personal Information we collect is used for business purposes such as operating, improving, and developing our Services, verifying user identities, billing, and communicating technical and security updates. It is also used to comply with legal requirements (e.g., tax reporting) and to respond to your inquiries and customer support requests.

Furthermore, your data assists in personalizing the overall Service experience, enabling us to provide customized information about products, services, events, and promotions that we believe might interest you. We also analyze data trends to monitor site usage, detect fraudulent or malicious activity, and address security concerns.

How We Share the Personal Information You Provide

We do not sell, trade, or rent your Personal Information. However, to deliver our Services effectively, we may share your information with trusted third parties. These include:

Your Personal Information may be stored on servers or databases located outside our direct control. In all cases, we take steps to ensure that your data is protected in accordance with this Policy.

Transfer of Personal Information

Third-Party Processors within Nigeria

We may engage third-party processors to handle Personal Information on our behalf. Such processors are under contract with us and are required to implement appropriate safeguards to protect your data in line with this Privacy Policy.

In circumstances where sharing of your information is necessary (for instance, to comply with law enforcement or regulatory obligations), we ensure that the disclosures are strictly governed by the terms of our contract and that your data remains protected.

Transfer of Personal Information to Foreign Countries

In instances where Personal Information is transferred outside Nigeria, we ensure that appropriate legal mechanisms are in place. In particular, we shall, among other things, confirm whether the country is on the Nigeria Data Protection Commission ("NDPC") White List of Countries with adequate data protection laws which may be issued from time to time.

Transfer of Personal Information out of Nigeria would be in accordance with the provisions of the Nigeria Data Protection Act 2023 ("NDPA"), and other applicable data protection laws like the Nigeria Data Protection Regulation 2019. We will therefore only transfer Personal Information out of Nigeria on one of the following conditions:

• The consent of the Data Subject has been obtained;
• 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;
• The transfer is necessary to conclude a contract between us and a third party in the interest of the Data Subject;
• The transfer is necessary for reason of public interest;
• The transfer is for the establishment, exercise or defense of legal claims;
• The transfer is necessary in order to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent.

We will take all necessary steps to ensure that your Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside Nigeria shall be provided to you upon request.

Our Lawful Basis for Processing Personal Information

We process your Personal Information only as permitted by the NDPA and other applicable laws. Our processing is founded on one or more of the following legal bases:

• Where you have given a clear, affirmative indication of consent for specific processing activities.
• When processing is necessary for the performance of a contract to which you are a party.
• Where processing is required by law.
• When processing is needed for our legitimate business purposes, provided this does not override your fundamental rights.
• In exceptional cases where processing is necessary to protect your vital interests or those of another person.

Please contact us at … if you require details regarding the specific legal grounds for processing your Personal Information.

For the purpose of this Policy, "consent" is defined as any freely given, specific, informed, and unambiguous indication of your wishes whereby you agree to the processing of your Personal Information.

Advertisement and Information About Other Products and Services

From time to time, we may send you information about other financial products and services offered by the Company, which we believe may be of interest to you.

We advertise online (on our Sites, mobile apps, through our managed social media presence, and on other sites not affiliated with SPENDIVE LIMITED) as well as offline. To assess the performance of our advertising campaigns, we may collect information via cookies, IP addresses, and other technologies. The data collected may include page visits, viewed content, browser interactions, and responses to our advertisements and promotions.

The information gathered assists in presenting tailored advertisements, including banner or splash ads, email campaigns, postal mail, and telemarketing initiatives, and in analyzing the effectiveness of these ads.

You may request to opt-out or stop receiving such communications by contacting us at …..

Choices and Rights

Once your Personal Information is collected by us, you have the following rights:

If you wish to exercise any of these rights, please contact us or our designated Data Protection Officer (DPO) at …. We aim to process your request within 30 days of receipt; complex requests may require an extension, in which case we will inform you accordingly.

Age Restriction

Our Services are not directed to children under 18 years of age. We do not knowingly collect information from children under 18. If you access our Services and are under 18, you confirm 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 immediately at …. so that we can delete such data.

Compliance with Local and International Regulatory Best Practices

We confirm our compliance with Nigerian data protection requirements as set forth in the NDPA, NDPR, and other applicable laws. In addition, we incorporate best practices from international frameworks, such as the GDPR, in so far as they do not conflict with Nigerian law.

Changes to Privacy Policy

We reserve the right to update, modify, change, or revise this Privacy Policy from time to time due to changes in law or business practices. The revised Policy will be effective immediately upon posting and will govern our ongoing relationship with you. We encourage you to check this page regularly for any updates. Material changes may also be communicated via email associated with your account or through a prominent notice on our platform.

Complaints and Remedies

If you believe any part of this Privacy Policy or our data handling practices have violated your privacy rights, you may file a complaint with us at …. Additionally, you have the right to lodge a complaint with the data protection authority, the Nigeria Data Protection Commission (NDPC), using the following contact details:

In the event of any data breach, we will notify you promptly and report to the NDPC within 72 hours of becoming aware of the breach.

Questions and Enquiries

If you have any questions, comments, or requests regarding this Privacy Policy or if you would like further information on exercising your rights, please contact us at contact@spendive.com