Oyoyo Privacy Policy

Introduction

Oyoyo (collectively referred to as 'we', 'us' or 'our' in this privacy notice), respects your privacy and is committed to protecting your personal data. This privacy notice will inform you on how we look after your personal data when you use our services or our website and tell you about your privacy rights and how the law protects you.

Oyoyo is the data controller responsible for your personal data and determines the purposes for and the manner in which your personal data is processed or is to be processed.

Purpose of this privacy notice

Generally, this privacy notice aims to give you information on how the company collects, uses, shares, stores, protects, and processes your personal data when you use our services or our website, and also tells you about your privacy rights and our legitimate basis for processing your data.

Please note that this website is not intended for children and we do not knowingly collect or process data relating to children. If you have inadvertently provided personal data of a child to us, please notify us and we will delete such personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

You have the right to make a complaint at any time to the National Information Technology Development Agency (NITDA), the Nigerian supervisory authority for data protection issues https://nitda.gov.ng/. We would, however, appreciate the chance to deal with your concerns before you approach the NITDA so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

We will occasionally update this privacy notice to reflect changes in our practices and services. When we post changes to this privacy notice, we will revise the “last updated“ date at the top of this privacy notice. If we make any material changes in the way we collect, use, and share personal data, we will notify you by prominently posting notice of the changes on our website. We recommend that you check this page from time to time to inform yourself of any changes in this privacy notice.

This version was last updated on 1st March 2021. As a 2021 start-up company there are no historic versions available.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing your personal data so that you are fully aware of why and how your personal data is being used.

It is also essential that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. You are required to evaluate the security and trustworthiness of any other site connected to our website or accessed through our website yourself, before disclosing any personal information to them. We will not accept any responsibility for any loss or damage in whatever manner, howsoever caused, resulting from your disclosure to third parties of personal information

The data we collect about you

We obtain personal information voluntarily provided by you when you use our services or our website to give you an efficient, enjoyable and secure service. In this privacy notice, “personal information“ or “personal data“ means any information relating to a natural person (data subject) who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or an online identifier. It also refers to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of a natural person. Personal data will be collected and processed in accordance with specific, legitimate and lawful purpose consented to by the data subject.

We receive or collect this information to operate, provide, improve, understand, customise, support, and market our services to you, including when you access, or use our services. The types of information we receive and collect depends on how you use our services. Where we need to collect personal data required by law, or in fulfilment of the terms of a contract we have with you and you fail to provide the data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Please see below, the kinds of personal data we collect about you, which we have grouped together as follows:Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

| Identity Data Includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. | Contact Data Includes home address, employer's address, company address, business address, email address and telephone numbers. | | --- | --- | | Technical Data Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. | Profile Data Includes your username and password, preferences, feedback and survey responses. | | Transaction Data Includes details about payments to and from you and other details of the services you use from us. | User Data Includes information about how you use our website, products and services. | | Marketing and Communications Data Includes your preferences in receiving marketing from us, our affiliates and otheur third parties and your communication preferences. | |

Special Categories Data

Owing to the services we offer, we occasionally require the processing of sensitive personal information (known as special category data) about you. Where we collect such information, we will only request and process the minimum information necessary for the specified purpose. By agreeing or ticking the box at the bottom of this privacy notice, you consent to us collecting and processing your special category personal data (racial or ethnic origin, religious beliefs or none, physical or mental health condition, sexuality and biometric data) for the purposes stated above. We will promptly act on your notice to modify or withdraw consent at any time if you wish to do so, unless there is a legitimate or legal reason preventing us from doing so.

How is your personal data collected?

We use different methods to collect personal data from and about you including through the following:

| Direct interactions | You may give us your identity / contact data by filling in forms provided by us or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: - Apply to obtain for our products or services - Create an account on our website - Subscribe to our service or publications - Request marketing to be sent to you - Undertake aEnter a survey - Apply for employment or to provide us with services | | --- | --- | | Automated technologies or interactions | As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns, includingbut not limited to - data about the pages you access, computer IP/Mac address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, standard web log data, still and moving images. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details. | | Third parties or publicly available sources. | We may receive personal data about you from various third parties, including technical data from the following parties: - Analytics providers [such as Google based in any global location]. - Advertising networks [such as Google based in any global location]. - Search information providers [such as Google based in any global location]. |

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

We will only use and process your personal data as permitted by the law. We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

• Contact details • Profile • Special category data • Financial and banking information• Biometric data | • Performance of a contract with you • Performance of contract with statutory and other agencies • Necessary to comply with a legal obligation • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) | | To manage our relationship with you which will include: • Notifying you about changes to our terms or privacy policy. • Asking you to leave a review or take a survey | • Identity • Contact details • Profile • Marketing and communication•Financial and banking information• Biometric data | • Performance of a contract with you • Necessary to comply with a legal obligation • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) | | • To enable you to complete a survey | • Identity • Contact details • Profile • Biometric data | • Performance of a contract with you • Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) | | • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | • Identity • Contact • Technical data•Financial and banking information• Biometric data | • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) • Necessary to comply with a legal obligation | | • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | • Technical data • Usage data | • Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) | | • To make suggestions and recommendations to you about goods or services that may be of interest to you | • Identity • Contact details • Technical data • Usage data • Profile•Financial and banking information• Biometric data | • Necessary for our legitimate interests (to develop our products/services and grow our business) | | To perform our services to you including: • Manage payments, fees and charges • Collect and recover money owed to us | • Identity • Contact details • Transaction • Financial and banking information• Biometric data | • Performance of a contract with you • Necessary for our legitimate interests (to recover debts due to us) |

Consent

Generally, we do not rely on only consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

However, where processing is based on consent, and upon your granting us your consent, you accept that you have the legal capacity to give consent, you have read our privacy policy and are aware of your privacy rights and your option to withdraw your consent at any given time.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Oyoyo group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transactions.

Cookies

This website uses cookies. A cookie is a small text file stored in your computer containing text data. We use cookies for certain functions to improve the usability of the website. EHowever, enabling cookies in your web browser is necessary if you wish your selections to be remembered for future visits on the same computer. 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. Our website uses only encrypted session cookies which are erased either after a predefined timeout period or once the user logs out of the platform and closes the browser. Session cookies do not collect information from the user's computer. They will typically store information in the form of a session identification that does not personally identify the user. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. For more information about cookies and instructions on how to adjust your browser settings to restrict or disable cookies, see the IAB website at allaboutcookies.org. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in accordance with the above stated lawful groundsrules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in 'How we use your personal data:':

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We may legitimately transfer your personal data to a foreign country. Where we need to transfer your data to another country, such country must have an adequate data protection law. We will seek your consent where we need to send your data to a country without an adequate data protection law and you will be provided with the following information: the purpose of the transfer; the identity of the recipient Company; the identity or categories of third parties to which the personal data will be transferred; the categories of data that will be transferred; the country to which the data will be transferred; and your option to refuse or withdraw his consent at any time. We do legitimately transfer your personal data internationally.

Data sSecurity

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Some of the safeguards we use are firewalls and data encryptions, physical access controls to our data centerscentres, and information access authorization controls, pseudonymisation, Cloudflare CDN, SiteScanner, anti-virus/malware, Secure Sockets Layer/Transport Layer Security (SSL/TLS) to ensure secure transmission of your personal data, you should see the padlock symbol in your URL address bar once you are successfully logged into our platform. Our URL address will also start with https:// depicting a secure webpage.

If you have created an account, username, password, or any other piece of information, as part of our access security measures, you must treat such information as confidential, and you must not disclose it to any third party. If you know or suspect that anyone other than you is in possession of your access details without your consent, you must promptly notify us.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We have several layers of security measures in place such as SSL, TLS, encryptions, pseudonymisation, restricted access, Cloudflare CDN, SiteScanner, IT authentication, firewalls, anti-virus/malware.

Data Rretention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

Supervision and cCompliance

We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy notice and ensuring our compliance with the applicable data protection laws and regulations. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our data protection officer using the following details: (insert details).

Complaints and Rremedies

A data subject may file a complaint in accordance with this privacy policy if he believes that any provision of this policy or their privacy rights under applicable local law have been violated in respect of his or her Data. Any such complaint must be made in writing and must be addressed to the company or the data protection officer of the company using the following details: (Insert details).

The company will investigate your complaint and give you information in writing of its findings on the complaint and any action taken or to be taken in response to the complaint. Please note that, the complaint and resolution procedure is not prejudicial to your right to complain to the data protection authorities or seek redress in a court of competent jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the data protection authorities. K, kindly contact us in the first instance using the following details: (insert details).

Your Llegal Rrights

This Privacy Policy describes your privacy rights regarding our collection, use, storage, sharing and protection of your personal information. Some of your privacy rights under data protection laws in relation to your personal data have been identified below:

• 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 making the request for information, we may request the provision of additional information necessary to confirm the identity of the Data Subject.
• 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, though we may need to verify the accuracy of the new data you provide to us.
• Right to request erasure 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 processing (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 of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Right to object to the processing of your personal data: Where we are relying on a legitimate interest (or those of a third party) and there maybeis something about your particular situation which could justify anmakes you want to objection to processing on this ground as you may feel it impacts on 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 override your rights and freedoms.

• 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:

• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• 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

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party: We will provide to 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.
• Withdraw consent at any time where we are relying on consent to process your personal data: However, 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Please click on the links below to find out more about your privacy rights (Insert link). If you wish to exercise any of the rights set out above, please contact us here (insert details). Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond to data subject rights request

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary