DEFINITION OF TERMS
For the purpose of this Policy:
Personal Data: means any information relating to you, including your name, identification number, location data, online identifier address, photo, email address, pins, passwords, bank details, posts on our Platforms, religion, date of birth, health, race/tribe, nationality, ethnicity, political views, trade union membership, criminal records, medical information, and other unique identifiers such as but not limited to MAC address, IP address, IMEI number, Bank Verification Number, IMSI number, SIM and others. It also includes factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.
Process/Processing: means any operation or set of operations which is performed on your Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Consent: We kindly request that you carefully read through this Policy and click on the ‘Agree’ icon below, if you consent to the terms of this Policy, particularly with respect to the processing of your Personal Data. That notwithstanding, if you proceed to use any of our Platforms and services, it will deemed that you have provided your express consent to the terms of this Policy.
Age: You must be at least 18 years old to use our services or any of our Platforms. Individuals under the age of 18, or applicable age of maturity, may utilize our Platforms services only with involvement of a parent or legal guardian, under such person’s account. Regardless, all Personal Data which we may process shall be in accordance with this Policy and other applicable laws.
COLLECTION OF PERSONAL DATA
In the course of your engagement with us or with third parties through our Platforms, we may collect your Personal Data and non-Personal Data in the following ways:
ACCESSING YOUR PERSONAL DATA
When accessing our Platforms, we may collect Personal Data about you and your interactions with the Services to which we undertake to keep secure and confidential.
When you download or use our mobile applications, or access one of our mobile optimized sites, we may receive Personal Data about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices allow you to control or disable location services in the device's setting's menu. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or the manufacture of your particular device.
USING YOUR PERSONAL DATA
In the course of your engagements with us or through our Platforms, we collect Personal Data for various legal reasons, largely to enable us to personalize your experience and to provide a more efficient service to you. Some of the reasons we collect Personal Data are to:
LAWFUL BASIS FOR PROCESSING
We can only use your Personal Data if we have a lawful basis for doing so. We consider that the lawful basis for processing your Personal Data are as follows:
STORAGE AND PROTECTION OF YOUR PERSONAL DATA
We protect your Personal Data using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, unauthorised disclosure and alteration. Some of our safeguards include firewall protection, Virtual Private Network (VPN) protection, encryption of data, authorization keys for authorised access and strong passwords. Access to our various platforms is restricted to authorized users only. Your Personal Data is also stored on our secure servers as well as secure physical locations and cloud infrastructure (where applicable). Please be aware that, despite our best efforts, no security measures are perfect or impenetrable.
We will take all necessary measures to ensure that your Personal Data is safe, however, you are also required to ensure that access codes, PINs, passwords, usernames, and all other information or hints that may enable third party access to your accounts on our Platforms are secure. We therefore strongly advise you to keep such information secure and confidential. If you use a third party’s device (laptops, phones, public internet, etc.) to access your account, kindly ensure that you always log out. Kindly note however that certain devices are programmed to save passwords or usernames, as such, we advise that you use third party devices with extreme caution. If you believe that an unauthorized person has accessed your information, please contact us immediately.
PROCESSING YOUR PERSONAL DATA
In order to execute our obligations to you or process your transactions, we may be required to process your Personal Data, such as your name, account number, account ID, contact details, shipping and billing address, or other information needed to complete the transaction. We also work with third parties, including financial institutions, vendors, service providers, who at one point or the other facilitate transactions executed on our Platforms. For completeness, in the course of your engagement with us or use of our services and Platforms, we may share your Personal Data with different stakeholders, including but not limited to Financial institutions; service providers; Credit bureaus and collection agencies to report account or credit information; Treepz’s subsidiaries and affiliates; Regulatory or judicial authorities; or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Treepz . Please note that the aforementioned parties may be within or outside Nigeria.
We may also process your Personal Data when we believe, in our sole discretion, that the disclosure of your Personal Data is necessary to comply with applicable laws and judicial/regulatory orders; conduct investigations; manage existing or imminent risks, prevent fraud, crime or financial loss, or for public safety or to report suspected illegal activity or to investigate violations of our Terms and Conditions.
In all cases, we will ensure that your Personal Data is safe, and notify the receiving party of the confidential nature of your Personal Data, particularly the need to maintain the confidentiality of same and prevent unlawful or unauthorised usage.
YOUR RIGHTS AS A DATA SUBJECT
You have the following rights regarding your Personal Data collected by us:
DISCLOSURES OF PERSONAL DATA
We may share your Personal Data with:
Other unaffiliated third parties, for the following purposes:
CROSS BORDER TRANSFERS OF PERSONAL INFORMATION
If you download or use our software, such as a stand-alone software product, an app, or a browser plugin, you agree that from time to time, the software may download and install upgrades, updates and additional features from us in order to improve, enhance, and further develop the software. We may utilise your Personal Data to internally evaluate our software.
PERIOD OF STORAGE
We retain your Personal Data for as long as necessary for the purpose(s) for which it was collected. The period of data storage is also subject to legal, regulatory, administrative and operational requirements.
Please note that this Policy does not apply to Information that is already in the public domain through no fault of ours.
DATA BREACH / VIOLATION
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data, we reserve the right to restrict your access to our Platforms and shall within 72 (Seventy-Two) hours of having knowledge of such breach report the details of the breach to NITDA.
Furthermore, where we ascertain that such breach is detrimental to your rights and freedoms in relation to your Personal Data, we shall having knowledge of the occurrence of such breach take steps to inform you of the breach incident, the risk to your rights and freedoms resulting from such breach and any course of action to remedy said breach.
We are dedicated to ensuring that you are satisfied with our management of your Personal Data. However, in the unlikely event that you have a complaint, please contact us via the details below, stating your name and details of your complaint. Upon receipt of your complaint we will endeavor to contact you within 3 (three) working days with a view to amicably resolving such dispute within the shortest possible time. The foregoing notwithstanding, all disputes arising from this policy shall first be resolved by negotiation. However, if parties fail to resolve the disputes amicably by such mutual consultations, parties shall further attempt to resolve the dispute by mediation.
If you have questions regarding your data privacy rights or would like to submit a related data privacy right request, kindly contact us via the information below:
2, Opeyemisi Bamidele Street,
Off Freedom Way, Lekki,
Phone number: 08171000085 (Lagos), 08171100552 (Abuja)
Please allow up to 1 (One) month for requests to be processed. The Company reserves the right to charge a reasonable fee to process excessive or repeated requests.
We may amend or revise this Policy at any time by posting a revised version on our website. Notice of the amendment shall be posted on our website and the revised version will be effective from the date of publication. Kindly, note that your continued use of our Platform after the publication of the revised version constitutes your acceptance of our amended terms of the Policy.