KIPA’s Privacy Policy

Kipa Global Innovations LTD (“KIPA”, “we” “our” “us”) value your privacy and the security of the information you share with us. This Privacy Policy explains how we collect, use, disclose and safeguard the information we obtain from you in relation to your use of our services, App, and application (“Platform”). This Privacy Policy applies to our App KIPA and all related websites, mobile applications, services, and tools regardless of how you access or use them.

By using our Platform, you consent to the terms and practices contained in this Privacy Policy and you grant us the right to collect and process your data in accordance with the terms of this Policy. Our policy complies with the Nigeria Data Protection (NDP) Act, including the EU General Data Protection Regulation (GDPR).

For the purposes of clarity, “User,” “customer,”, or “subscriber,” refers to visitors to our App. “Personal Information,” or “Personal Data,” means any information that identifies or can be used to identify a User, directly or indirectly, including, but not limited to name, email address, mobile number, photograph, or IP address.

The Information We Collect

When you use our platform, we may collect certain types of information about you including the following:

Personal Information We May Collect About You

We collect Personal Data about you when you use the services offered on our App and digital platform, including the following:

• Log/Technical information: when you access KIPA services, our server automatically records information sent by your browser whenever you visit a App, links you have clicked on, length of visit on certain pages, unique device identifier, log-in information, location and other device details.
• Sign-up information: When you register to use the services offered on our Platform, we will collect personal data as necessary to offer and fulfill the service you request. Depending on the service you choose, we may require that you provide us with your name, email address, and mobile number. We may also require you to provide additional, necessary personal details as you use our services.
• Transaction information: When you use our digital platform to make purchases from merchants, pay bills, we collect information about the transaction, as well as other associated information as necessary to offer and fulfil the service (like transaction receipt, account statement) that we are obliged to; such as: amount paid for products or services, merchant information – including information about your device and Geo-location.
• Marketing and Communications Data: this includes both a record of your decision to subscribe or to withdraw from receiving marketing materials from us or from our third parties.
• Financial Data: information such as Bank Verification Number (BVN), personal account number, the merchant’s name and location, the date and the total amount of transaction, and other information provided by financial institutions or merchants when we act on their behalf.
• Other Information We Collect Related to Your Use of our Services: We may collect additional information from or about you when you communicate with us, contact our customer support teams or our social media platforms when you reach out to us to lodge a complaint about our services. However, we will only ask for information relevant to the help required of us to you.
• Identity Data: information such as, your full name(s).

Information Collected Automatically

This includes but is not limited to your IP address, browser type, mobile device ID, device type, operating system version, connection information, mobile network information, location derived from GPS-enabled services, information based on your usage of the service such as time, date and duration of your use, referral URLs, search terms and search history, browsing history and advertisement interactions.

Information from Third Parties

We may retrieve additional personal information about you when you respond to a survey or use functionality offered by third-party service providers through our Platform. We will not share or disclose your personal information with a third party without your consent except as may be required for the purpose of providing you with KIPA’s service or under applicable legislation.

In providing you with our services, we may rely on third-party servers located in foreign jurisdictions from time to time, which as a result, may require the transfer or maintenance of your personally identifiable information on computers or servers in foreign jurisdictions. We will endeavour to ensure that such foreign jurisdictions have data protection legislation that is no less than the existing Data Protection Regulations in force in Nigeria and your personally identifiable information is treated in a safe and secure manner.

Why We Collect Your Information

We collect your information to ensure easy and seamless access to our services. We use the information we collect for the following purposes:

• To enable us provide you with a personalized experience of our product and services.
• Provide services, including to: initiate a payment, or pay a bill; authenticate your access to an account; communicate with you about your account.
• Manage risk, fraud and abuse of our services and prevent you from fraud (by developing and adopting measures of verifying your identity). Our risk and fraud tools use personal data, device information and Geo-location from our Platform that offers services to help detect and prevent fraud and abuse of the services.
• Comply with our legal and regulatory obligations and to enforce the terms of our sites and services, including complying with all applicable laws and regulations.
• Trail information breach and remediate such identified breaches.
• Resolve disputes and troubleshoot problems.
• To target advertisements, newsletters and service updates.
• As may be required by applicable laws and regulations, including for compliance with Know your Customer (KYC) and risk assessment, Anti-Money Laundering, anti-corruption and sanctions screening requirements, or as requested by any judicial process, law enforcement or governmental agency having or claiming jurisdiction over KIPA or KIPA’s affiliates.
• To evaluate and improve our business, including developing new products and service updates.
• To use data analytics to improve our App, products or services, user experiences and to optimize service.

With your prior consent:

• Market KIPA’s products and services to you.
• Use cookies to provide a targeted display, feature, service or offer to you.
• To provide you with location-specific functionality like searching nearby agents if you authorize us to access your Geo-location information through the Services.
• For other purposes for which we provide specific notice at the time of collection.

We will not send unsolicited marketing communications to you by SMS or email if you have not opted in to receive them. Additionally, we will provide you with an option to unsubscribe if you do not want to hear from us at any time and free of charge.

Rules on Sharing Information

Except as provided in this Privacy Policy, KIPA, WILL NOT disclose the information that it obtains from you to third parties without your express written permission, or where we believe, in good faith, that the law requires us to disclose the information. If you request that KIPA share information provided by or collected from you directly with a third party designated by you, you agree that you (and not KIPA) will be solely responsible for the use, storage, and maintenance of such information by such third party.

We may share your Personal Data or other information about you with others for the following reasons:

• With affiliates of KIPA that are subject to the equivalent level of internal control: We may share your Personal Data with affiliates of KIPA out of necessity to enable the technical service you request, to manage risk through risk model system, to prevent potentially illegal and fraudulent acts and violations of our policies and agreements, and to help us manage the connectivity of our services.
• With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with services, verify your identity, assist in processing transactions, send you advertisements for products and services on the platform, or provide customer support. Rest assured that we make sure that these companies have compliant, legal measures in place to ensure the security and confidentiality of your Personal Data.
• With other financial institutions: We may share Personal Data with other financial institutions that we have partnered with to only offer KIPA-related services, unless your consent extends to other uses. We may also share Personal Data to process transactions and keep your financial information up to date.
• With the other parties to transactions when you use the services, such as other users and their service providers. This includes other users you are sending or receiving funds from and/or transacting businesses with and their service providers.
• If we need to do so to comply with a court proceeding, other legal process or an applicable regulation;
• With credit agencies and data processors for credit reference checks and anti-fraud and compliance purposes – all in accordance to applicable data privacy regulations and laws;
• As reasonably and legally permitted, to facilitate a purchase or sale of all or part of KIPA’s business, or in the instance of some merger and acquisition;
• Your BVN. By accepting this policy, you agree that, in line with regulation and in furtherance of our KYC computation processes, we may access and utilize your BVN to upgrade your account.

Sharing Your Information with Third Parties

Currently, KIPA does not disclose any information that it obtains from you to third parties. As noted above, we will share information with people and parties who already have the right to that information, who were the source of the information, or who you have requested and consented in writing that we share information with.

If this changes, we will update the list above with information about: (i) the third party, (ii) the types of information shared, (iii) the scope (which customers are affected), and (iv) the reasons for us sharing that information, including the third-parties use of that information.

Marketing

We may process your Personal Information in order to contact you or send you marketing content and communication about our products, services or surveys. You may exercise your right to object to such contact from us or opt out from the marketing content, we may still send you messages relating transactions and our services related to our ongoing business relationship.

We may ask you for permission to send notifications to you. Our services will work if you do not grant us consent to send you notification.

Minors (Age Restrictions)

KIPA’s Apps and applications are not directed at persons under the age of Eighteen (18) and we do not collect any personal information knowingly or directly from minors who fall within this category. Where you have any belief that KIPA has mistakenly or unknowingly collected information from a minor, please contact us using the information provided under the Contact details segment to enable us to investigate, restrict and delete such data.

Cookie Policy

We use cookies to identify you as a User and make your user experience easier, customize our services, content and advertising; help you ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our App. Cookies allow our servers to remember IP addresses, date and time of visits, monitor web traffic and prevent fraudulent activities.

Our cookies never store personal or sensitive information; they simply hold a unique random reference to you so that once you visit the site we can recognize who you are and provide certain content to you.

If your browser or browser add-on permits, you have the choice to disable cookies on our App; however this may impact your experience using our App.

Governing Principles of Data Processing

We process your information in accordance with the provisions of the Nigeria Data Protection Regulation and these principles:

• Your personal data is collected and processed in accordance with specific, legitimate and lawful purpose consented to by you, provided that further processing may be done by archiving the data for public interest, scientific or research purposes, or statistical purposes.
• The data collected is adequate, accurate and without prejudice to the dignity of the human person.
• The data collected is stored only for the period within which it is reasonably needed.
• The data collected is secured against all foreseeable hazards and breaches such as theft, cyber-attack, viral attack, and dissemination, manipulations of any kind, damage by rain, fire or exposure to other natural elements.
• We owe a duty of care to you in respect of the data we have obtained from you.

Data Security and Protection

To prevent unauthorized access and maintain security against foreseeable hazards, we have in place physical, electronic and managerial procedures to protect, secure and safeguard our customer’s data and ensure accuracy of our records.

We use secure socket layer (SSL) protocol technology for the collection and any permitted transfers of your data. However, KIPA cannot guarantee the security of any personal data disclosed to it or collected by it to the extent that it has no control over the public or third-party network through which personal data may be sent to our App.

We have a management and corporate commitment to information security within the organization and provide clear direction, guidance and responsibilities and procedures in this respect.

We have in place a Data Protection Officer who deals with security of information and personal data together with relevant compliance with the Regulation and the knowledge and skills of our Data Protection Officer are continuously updated.

In addition to the security measures we employ, you must also ensure that you take responsibility for the protection of your personal information. We will not be liable for any loss or damage caused by the activities of hackers and fraudsters when we have taken all necessary and reasonable steps to protect your information in our possession. You are fully responsible for safeguarding your username, password, and financial information.

Your Privacy Rights

By providing us with your personal information, you have certain rights in accordance with the provisions of the Nigeria Data Protection Regulation which include:

• You have the right to be informed of the processing of your information typically through this privacy policy.
• You have the right to access your personal information in our possession.
• You have a right to ‘block’ or withdraw your consent to our processing of your information.
• You are entitled to have personal data rectified if it is inaccurate or incomplete.
• You have the right to request the deletion or removal of personal data where there is no compelling legal or regulatory requirement for its continued processing.
• We will ensure that personal data is moved, copied or transferred easily from one IT environment to another in a safe and secure way, without hindrance to usability at your request.
• You have the right to object to our processing of your information in some circumstances.
• The right not to be subject to automated decision-making. For the protection of rights and freedoms, the law prohibits decisions based solely on automated means including profiling except informed consent of the data subject is obtained.
• To unsubscribe from any electronic newsletters or other marketing communications, you can click on the unsubscribe link in the relevant communication.

All such requests will be reviewed and considered in accordance with the provisions of the applicable data protection regulations.

You also have the right to opt-out of receiving the informative materials we send to our users by clicking the “Unsubscribe” button found at the bottom of such emails. You also have the right to decline to provide your personal Information when it is requested, however, certain services or all the services may be unavailable to you.

Employee Training

KIPA ensures that employees who collect, access and process Personal Information receive adequate data privacy and protection training in order to develop the necessary knowledge, skills, and competence required to effectively manage the compliance framework under the Policy and the Nigerian Data Protection Act (NDPA) with regard to the protection of Personal Information. On an annual basis, KIPA develops a capacity-building plan for its employees on data privacy and protection in line with the NDPA.

International Transfer of Your Information

We may need to transfer your information in our possession to third parties outside Nigeria. Such transfers will only be done in accordance with the applicable data protection regulations in such jurisdiction. While undertaking the international transfer of your information, we will put security measures in place to reasonably protect your data during transmission. We shall, among other things, confirm whether the country is on the National Information Technology Development Agency (“NITDA”) White List of Countries with adequate data protection laws.

Data Protection Officer

KIPA has an appointed Data Protection Officer(s) responsible for overseeing the Company’s data protection strategy and its implementation to ensure compliance with the Nigeria Data Protection Act (NDPA). The Data Protection Officer is knowledgeable on data privacy and protection principles and is familiar with the provisions of the NDPA.

Data Retention Period

We may retain Personal Information about the User, as long as it is necessary for business and/or legal purposes. Also, we may retain aggregated anonymous information indefinitely. In addition, we may retain your information for an additional period as is permitted or required to, among other things, comply with our legal obligations, resolve disputes, and enforce agreements.

All Personal Information shall be destroyed by KIPA where possible. For all Personal Data and records obtained, used and stored by us, we shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity and requirement to retain.

The length of storage of Personal Information shall, amongst other things, be determined by:

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

Data Protection Audit

KIPA shall conduct an annual data protection audit through a licensed Data Protection Compliance Organization (DPCO) to verify KIPA’s compliance with the provisions of the NDPA and other applicable data protection laws. The audit report will be certified and filed by the DPCO to the Nigeria Data Protection Commission (NDPC) as required under the NDPA.

Contact Details

If you have questions regarding your data privacy rights or would like to submit a related data privacy right request/complaint, please email us at info@getkipa.com or lodge a formal compliant with the Nigeria Data Protection Commission at info@ndpc.gov.ng.

If you have general questions concerning this Privacy Policy, please contact us at: info@getkipa.com

We maintain a data breach procedure in order to deal with incidents concerning personal Information or practices leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal Information transmitted, stored or otherwise processed. You may contact us upon becoming aware of any breach of personal Information or if your access credentials have been compromised, to enable us to take the necessary steps towards ensuring the security of your personal Information or account.

Updates to This Policy

We reserve the right to periodically update and modify the terms of our Privacy Policy without notice. Changes to this Privacy Policy will take effect on the last updated date.

Update History

Management Use Only