This Privacy Policy (“Policy”) explains what personal information Nibox Payment Systems Limited (“Company” “we”, “us”) collects, how we use and store it and your choices regarding the collection and use of information, in each case, in connection with Bills.ng, our digital platform created for the settlement of essential bills in Nigeria (“Product”). By accessing or using any of the foregoing, you confirm that you have read, understand, and agree to our collection, storage, use and disclosure of your personal information as described in this Policy.

You are not under any legal obligation to submit your personal data to us. However, you may not be able to explore all aspects of the Product where you choose not to submit personal data to us.

This Policy does not apply to any products, services, websites, links or any other content that is offered within the Product by third parties. You are advised to check the terms of use, privacy policies of such third parties.

How We Collect Your Information

A.  Information you provide us directly or indirectly

When you access, sign up or register to use the Product, your data is collected electronically. We may ask for certain information such as your name, e-mail address, phone number, pictures, and any other necessary information. We also collect your data manually when you complete our product registration form(s) in registering to use the Product. Similar data are also collected if you visit our physical locations for inquiries or business relationships. You can also voluntarily connect other third-party accounts, and we may use information from those accounts to improve your experience, in line with any applicable privacy policy. We may also collect information you provide in content you post, publish, submit, upload, transmit, or otherwise make available, such as information, photos, images, music, videos, information, comments, questions, messages, works of authorship and other content or information, as well as associated metadata (“User Content”). If you sign up for our mailing list, we may use this information to operate, maintain and provide to you the features and functionality of our service.

B.  Analytics information

To measure our traffic and usage trends, we may directly collect analytics data, or use third-party analytics tools to collect information including the web pages you visit, your browser add-ons, your browser’s width and height, and other information that assists us in improving the Product.

C.  Third Party Information

If you access the Product through a third-party connection or log-in, we may receive information from you from the third party. This information would include, but may not be limited to, information that you have made public with the third-party, or have permitted the third party to share with us. At any point in time, you may always review or adjust your privacy settings on third-party websites and services before linking or connecting to the Product.

D.  Metadata

We may collect metadata associated with User Content. This makes your data more searchable and more interactive. Users can add metadata to their User Content including keywords posted with a photo or video, including names, geographical or location information, comments, or other data. The metadata may be accessible to others if you share the User Content with others or on third party social media sites.

E.  Cookies

We use cookies to identify you, customise and improve our services. Cookies are small text files that enable us to tag your device and recognise it on our website and software. While your browser may automatically accept cookies, some can be modified to decline cookies or alert you when a website wants to place a cookie on your computer. If you do choose to disable cookies, it may limit your ability to use our website. Cookies allow our servers to remember IP addresses, date and time of visits, monitor web traffic and prevent fraudulent activities.

F.  Log file information

When you use the Product, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, landing pages, pages viewed, IP address, browser type and URLs, number of clicks and how you interact with links on our website and other such information.

G.  Device Information

We may collect information about your device when you use the Product, and this is called a ‘device identifier’. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device. A device identifier may convey information to us about how you browse and use the Product. Some features of the Product may not function properly if use or availability of device identifiers is impaired or disabled.

H.  Location data

Location data may convey to us information about how you use the Product. When you access the Product by or through a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates or similar information regarding the location of your mobile device.

I.  Adverts

We may permit third party online advertising networks to collect information about your use of the Product over time so that they may play or display adverts that may be relevant to your interests on other websites or services. Typically, these third party ad servers or ad networks use cookies and other tracking technology to compile information about your browser’s or device’s visits and usage patterns on the Product and on other sites around the web, to send you adverts, to measure the effectiveness of their adverts and to personalize the advertising content.

Generally, we use or may use the data collected through cookies, log files, device identifiers and location data to: (a) provide custom, personalized content and information, including advertising on other websites or services; (b) provide and monitor the effectiveness of the Product; (c) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (d) provide assistance and support; (e) protect users security; and (f) diagnose or fix technology problems.

Use of Information We Collect and Store

The information we collect is used to provide users of the Product with a secure, smooth, efficient, and customized experience. We are also committed to providing and improving your experience, and may process or store your information in any country in which the Company, or its affiliates or service providers maintain facilities. We also collect personal information to improve the Product, to measure the performance of the Product and improve its content and layout; manage and protect our information technology infrastructure; provide targeted marketing and advertising, provide service update notices, and deliver promotional offers based on your communication preferences.

We care about your security, and will use commercially reasonable safeguards to preserve the integrity and security of all information collected for you. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorization controls. We have also taken additional measures by ensuring our system complies with industry information security standards. However, we cannot guarantee that information provided to us may not be accessed, disclosed, altered, or destroyed.

The Company may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union, California USA or other regions with laws governing data collection and use that may differ from Nigeria, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to any country in which the Company or its subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Policy.

How Long Do We Keep Your Personal Information

We will hold your personal information on our systems for as long as is necessary to fulfill the purpose for which it was collected or to comply with applicable legal, regulatory, accounting, or internal policy requirements. When we no longer need to use your information and there is no need for us to keep it, we will either remove it from our systems or depersonalise it so that we can’t identify you.

Disclosing Your Personal Information

Any information or content that you voluntarily disclose may be available to other users and to the public, as controlled by any applicable privacy settings. We may disclose your personal information with third parties including our affiliates, employees, officers, service providers, agents and subcontractors as may be reasonably necessary for the purposes set out in this Policy. We will only share or disclose your personal information on one of the following conditions:

• Your consent has been obtained. The Company shall bear no liability for any breach which may occur from such authorisation by you;
• To pursue our legitimate business interests, provided that such processing does not override your data subject rights.
• For the purpose of providing the Product to you, we may share your information with third-party business consultants and service providers. These parties will be given limited access to your information as is reasonably necessary.
• The disclosure is necessary for reason of public interest, and to detect, prevent or otherwise address fraud, security or technical issues;
• The disclosure is to satisfy any applicable law, regulation, contractual obligation, legal process or enforceable governmental request (whether in your jurisdiction or elsewhere);
• The disclosure is for the establishment, exercise or defence of legal claims;
• The disclosure is necessary in order to protect your vital interests or other persons, where you are physically or legally incapable of giving consent

The Company will take all necessary steps to ensure that Personal Information is transmitted in a safe and secure manner. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In the case of a merger, acquisition, bankruptcy, dissolution, reorganisation or similar transaction or proceeding that involves the transfer of information described in this Policy, we would share your information with a party involved in such a process.

Information About Children

For the avoidance of doubt, we will not knowingly collect or solicit personal information from anyone under the age of 18. The Product is not to be used by children under 18 or under the age at which you can provide consent to data processing under the laws of your country.

International Data Transfers

As a global service provider, the Product will operate internationally, and we may transfer information collected from across international borders for processing and storage purposes. However, the information will only be processed as required by law or in accordance with this Policy.

Data Protection Rights and Your Choices Regarding Your Information

Subject to applicable laws, and subject to any limitations and exceptions provided by law, users who have personal information held by us are entitled to the following rights:

A.  Right to request for and access any personal information collected and stored.

B.  Right to object or request for restriction with respect to the personal information;

C.  Right to request rectification and modification of the personal information which we keep;

D.  Right to request that the Company transfers data collected to another organisation or directly to them, subject to certain conditions;

E.  Right to request for deletion of your data or by closing your account; and

F.  Right to object to, and to request that the Company restricts the processing of your information.

Changes To This Policy

We reserve the right to update, amend or change this Policy at any time as required by law or technology. If the Company makes any changes to this Policy that materially affects the Company’s practices with regard to the personal data the Company previously collected from the you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our website. Your use of the Product after those changes become effective means that you accepted the revised Policy. The Company will seek your prior consent to any material changes, if and where this is required by applicable data protection laws.

Links to other websites and services

Kindly be informed that when you use a link from our website or application, our Privacy Policy does not apply to third-party websites or services. Your interaction on any third-party website is subject to the parties’ own privacy policy. It is important that you agree that we are not responsible and we do not exercise control over any third-parties which you authorise to access your User Content, and by accessing a third party website, you do so at your own risk.

Users in The European Economic Area (EEA)

For the purposes of the General Data Protection Regulation (2016/679) (“GDPR”), including any subordinate or implementing legislation, the Company is acting as a processor/service provider, and the you are acting as the controller/business (as applicable).

For the purposes of the General Data Protection Regulation (2016/679) (“GDPR”), including any subordinate or implementing legislation, the Company is acting as a processor/service provider, and the you are acting as the controller/business (as applicable).

A.  Contractual Necessity: processing of User Content is necessary to enter into a contract with you, to perform our contractual obligations to you under the Terms of Use, to provide the Product, to respond to your requests, or to provide you with customer support;

B.  Legitimate Interest: we have a legitimate interest to process your personal data;

C.  Legal Obligation: processing of your personal data is necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or

D.  Consent: processing of your personal data is done with your consent.

You have certain rights with respect to your personal data, including the following:

A.  You may ask whether the Company holds your personal data and request copies of such personal data and information about how it is processed;

B.  You may request that inaccurate personal data is corrected;

C.  You may request the deletion of certain personal data;

D.  You may request that we cease or restrict the processing of Personal Data;

When you consent to us processing your personal data for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.

In certain circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, however, in those circumstances, we will still respond to notify you of such a decision.

In certain circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, however, in those circumstances, we will still respond to notify you of such a decision.

Contacting Us

If you have any questions or complaints about this Policy, you can contact us at support@nibox.ng or by filling the contact us form on our website Bills.ng.