PRIVACY POLICY

1. This privacy policy (the “Policy”) together with our Terms and Conditions as set out on the EASYBUY mobile application (the “App”) and any additional terms and conditions apply to your use of the App and any of the services provided by Transsnet Financial Nigeria Limited (“Transsnet”, “we” or “us”) using our App.

2. This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The Policy also describes your rights regarding our collection, use, storage, sharing, and protection of your personal information.

3. By clicking on the button labelled “Sign Up” below and proceeding to use the App or access any of the Services (as defined below), on the App, you confirm that you have read, understood and accept the terms of this Policy as set out hereunder. You also expressly consent to the collection, use, storage, processing and disclosure of your personal information in the manner set out in this Policy and the Terms and Conditions.

4. We may amend this Policy at any time by publishing the amended terms on the App. All amended terms shall automatically become effective on the day that they are published on the App. Additionally, we may notify you of such amendments via the App’s inbuilt messaging platform.

5. For the purposes of this Policy, the term “Services” shall be defined as any form of services or products that Transsnet may offer you via the App and which you may from time to time subscribe to.

6. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

A. Personal information

(i) Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include anonymous information that does not refer to a specific user.

(ii) We may collect and process the following types of personal information in order to provide you with access to our App and the Services:

 personal data such as name, age, email address, phone number, physical contact information, personal description, photograph, username, password, other registration information and (depending on the service used) sometimes financial information, such as Bank Verification Number, credit card or bank account numbers;

 transactional information based on your activities on the App (such as products or service purchased, content you generate or that relates to your account), billing, and other information you may have provided in connection with your orders;

 personal information you provide to us through information pages, correspondence, chats, complaints, customer service channels, or provided to us from other social applications or services;

 additional personal information we ask you to submit as part of our verification process (for example, we may ask you to send us an identification document or utility bill to verify your address, or to answer additional questions online to help us verify your identity);

 other supplemental information obtained from third parties such as demographic and navigation data, credit check information, and additional information about you from a credit bureau, as permitted by law;

 information from your interaction with our App, services, content and advertising, including, but not limited to, device ID, device type, unique device identifiers; geo-location information, computer, operating system and connection information, statistics on page views, IP address and standard web log information;

 information stored on your device, including contact lists, call logs, SMS logs, Facebook friends, contact lists from other social media accounts, photos, videos or other digital content;

 details of any of your visits to the App; including, but not limited to, traffic data, location data, weblogs and other communication data.

(iii) This information may be provided or collected by:

 filling in forms on the App;

 corresponding with us (for example, by e-mail or chat);

 registering to use the App;

 subscribing to any of our Services;

 sharing data via the App’s social media functions;

 entering a competition, promotion or survey;

 reporting an issue with the App or our Services.

B. Tracking and cookies

(i) We may use mobile tracking technologies and/or cookies to distinguish you from other users of the App. This helps us to improve the user experience on the App.

(ii) While you are free to decline our cookies if your browser permits, please note that doing so may interfere with your use of some of our Services.

(iii) Please also note that:

 certain features are available only through the use of cookies;

 we use cookies to help identify you and maintain your signed-in status;

 most cookies are "session cookies" meaning that they are automatically deleted from your hard drive at the end of a session;

 you may encounter cookies from third parties, which are cookies from our service providers, that we have allowed on our App that assist us with various aspects of our App operations and services;

 you may also encounter cookies from third parties on certain pages of the App that we do not control and have not authorised (for example, if you view a web page created by another user, there may be a cookie placed by that web page).

C. Use of your information

(i) Our primary purpose in collecting personal information is to provide you with access to our App and our Services, and provide you with a smooth and efficient experience. You agree that we may use your personal information to:

 calculate your credit limit and decide the amount that Transsnet may provide to you as a loan;

 provide you with access to the App, the Services and any customer support that you may request;

 resolve complaints and disputes, collect fees, and troubleshoot problems;

 prevent, detect, and investigate prohibited or illegal activities, and enforce our Terms and Conditions;

 customise, measure, and improve our contents, advertising and Services;

 inform you about our Services, deliver targeted marketing, service updates, and promotional offers based on your communication preferences;

 compare information for accuracy, and verify it with third parties;

 contact you using the telephone numbers you have provided as authorised by our Terms and Conditions;

 provide you with other services requested by you as described when we collect the information.

(ii) We may associate any category of information with any other category of information and may treat the combined information as personal information in accordance with this Policy for as long as it is combined.

D. Disclosure of your information

(i) We may disclose personal information in order to respond to legal or regulatory requests, enforce our policies, or protect anyone's rights, property, or safety. Such information will be disclosed in accordance with applicable laws and regulations.

(ii) We may disclose your personal information to any member of our group (which means our subsidiaries, affiliates, our holding company and its subsidiaries) in order to provide joint content and services (for example, customer support), to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about their products, services, sites, applications, tools and communications. These entities may use this information to send you marketing communications and you may unsubscribe from their mailing list.

(iii) We may also disclose your personal information:

 to other business entities, should we plan to merge with or be acquired by that business entity in which case personal data held by Transsnet about its customers may be one of the transferred assets. Should such a combination occur, we will endeavour to minimise the changes to this Policy, however, we will notify you if there are changes to our privacy policy as a result of such acquisition, merger or combination;

 to third parties in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

 to law enforcement agencies, governmental agencies, or other authorised third parties if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; (for example, a request relating to a civil or criminal investigation or alleged illegal activity or any other activity that may expose you or Transsnet to legal liability);

 to third parties in order to enforce our Terms and Conditions and other agreements or to investigate potential breaches; or for the purpose of publishing statistics relating to the use of the App, in which case all information will be aggregated and made anonymous;

 to third parties to whom you explicitly ask us to send your information (or about whom we explicitly notify you and obtain your consent before sending your information to such third parties;

 to credit bureaus. We may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be reflected in your credit report.

(iv) Save in compliance with an order of a Court, an Arbitral Panel, a Tribunal, an investigatory panel, or any other legal or regulatory obligation, we do not disclose information about identifiable individuals to other parties, but we may provide them with anonymous or aggregate information about our users.

E. Storage of your information

(i) The data that we collect from you may be transferred to, and stored at, a destination outside Nigeria. It may also be processed by staff operating outside Nigeria, who work for us or for one of our suppliers. These staff members may be engaged in the fulfillment of your requests on the App or the provision of Services to you. By submitting your personal data, you agree to the collection, transfer, storage or processing of your personal data in the manner set out above. We will take all steps reasonably necessary to ensure that your data is treated, stored and processed securely and in accordance with this Policy.

(ii) Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the App; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

(iii) We expect that the personal information that you provide to us is accurate and up to date, and we will provide you with the opportunity to update your information through your account profile settings. We retain information as long as it is necessary and relevant for our operations. In addition, we may retain personal information from closed accounts to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms and Conditions and take other actions permitted by law.

F. Your rights

(i) We will use your data for the purposes of compiling statistics relating to our user base and may disclose such information to any third party for such purposes, provided that such information will always be anonymous.

(ii) Should we wish to use your personal information for marketing purposes, we will inform you prior to such use. You shall be entitled to prevent such usage by informing us, within 3 days of being informed of the proposed use, that you do not wish to disclose such information in this manner. You can also exercise this right at any time by contacting us at email: easybuy.service.ng@transsnet.com. This does not, however, preclude us from using your information as part of anonymous or aggregate information for our marketing purposes.

G. Third Parties

Except as otherwise expressly included in this Policy, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to other users of our App or other sites throughout the internet, different rules may apply to their use or disclosure of the information you provide to them. Transsnet does not control the privacy policies of third parties and will not be liable for any illegal use of your personal information by such third parties. You are, however, subject to the privacy policies of those third parties where applicable. We encourage you to ask questions before you disclose your personal information to others.

H. Consent

By downloading the App and accepting our Terms and Conditions and our privacy policy, you confirm to us that we may collect, use, process, share or transmit your personal information for any of the above purposes.

I. Changes to privacy policy

Any changes we may make to this Policy in the future will be posted on this page and, where appropriate, notified to you when you next log onto the App. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Services. In any event, by continuing to use the App and any of our Services after the posting of any changes, you confirm your continuing acceptance of this Policy together with such changes, and your consent to the terms set out therein.

J. Enquiries

Questions, comments and requests regarding this Policy should be addressed to email: easybuy.service.ng@transsnet.com