Updated 30th November 2020
- Personal Information we may collect from you when you visit this Platform or when you avail yourself of the services provided on this Platform,
- how we use and secure such Personal Information,
- The choices you have regarding our use of your personal information,
- Your ability to review, correct and object to the use of such Personal Information, in accordance with the Nigeria Data Protection Regulations, 2019, its subsequent amendments and other regulations regulating the collection and processing of personal data in Nigeria.
- Access (if any) of third parties to personal data and purpose of access.
What Information is collected from you?
- In general, you can visit the Platform without telling us who you are or revealing any Personal Information. For each visitor to the Platform, our Web server automatically recognizes only the customer’s domain name, but not the e-mail address (where possible).
- We may track the Internet Domain Address from which people visit us and analyze this data for trends and statistics, but individual users will remain anonymous, unless you voluntarily tell us who you are.
- There may be times, such as when you subscribe to any of the services rendered on this Platform, register to receive marketing information, or participate in competitions, undertake user reviews/ratings, contests or promotions, etc., at which we may ask you to provide certain information about yourself such as your name, address, mobile number, email address, birth date, gender, occupation, personal interests and other ancillary information relating to your person. The decision to provide such information is completely your own choice but if you choose not to provide this information we request, you will be unable to take advantage of our offerings and will not be granted access to the Services we render on this Platform.
- We may also obtain some information through or from cookies or other similar technologies; or the device used to connect to our Platform. This information includes IP address, mobile network, browser and version, unique device identifiers and time zone settings; website visited before you visited our Platform. You may change your cookie settings on your device if you are concerned about us accessing them.
- We may ask you to give testimonials attesting to the quality of the services rendered on the Platform and we will publicize such testimonials on the Platform as a form of customer accreditation to reel in other customers.
- Should you login to our Platform through your social media accounts viz Twitter, Instagram, Facebook or any other third party application media, that may be developed in the future, we may receive information about you or your social media network through your account and may store and use the information received from your account. However, we shall do this with strict regard to your right to privacy and the extant laws; and we shall not use this information other than for purposes incidental to the contractual relationship that exists between us and for the improvement of the services we render to you.
- In line with international best practices, we do not store your card details. We have adopted a payment process which is in full compliance with the Payment Card Industry Data Security Standard (PCI DSS). Payments on our Platform are made via Paystack; a PCI DSS certified payment platform with bank level security to ensure your transactions and financial information are always safe and secure.
How do we use your Personal Information?
- You agree that our platform is simply a one stop shop for all your financial needs (whether as a guest or registered user) that are provided by our financial service providers (“service providers”).
- In view of the foregoing, the information you provide to us on our Platform, including your Device Identifiers and Personal Information, Business Information and Usage Information, will be shared with our service providers for the purpose of rendering financial management and advisory services to you.
- We use the information you provide us to customize your experience on the Platform or to serve you specific content or ads that are relevant or personalized to you.
- If at any time you wish to unsubscribe to our contact list/mailing system or promotional advertisement, please let us know by sending us an email at email@example.com
- We may also use aggregate information and statistics for the purposes of monitoring Website usage in order to help us develop the Platform and our Services and may provide such aggregate information to third parties. These statistics will not include information that can be used to identify any individual.
- We gather this Personal Information to allow us process your registration, process any requests or payments you may make; and to also administer your contractual relationship with us. We also collect the Personal Information in order to grant you access to our Services, monitor your usage of our Platform and Services, and/or participation in online activities including reviews, testimonials or competitions, if any.
- From time to time we may provide your Personal Information to our customer service agencies or customer service unit, for research and analysis purposes so that we can monitor and improve the Platform, online experience and our services to you. We may contact you by email, telephone or through any of the social media platforms, to ask you for your feedback and comments on our services.
- The information we collect are also used to communicate with you about your account or transactions with us or our service providers and to also send you information or request feedback about features on our website and applications or changes to our policies;
- The information we obtain are also useful in aiding investigations and attending to your complaints or enquiries within reasonable time.
How can you Access and Amend your Information?
- You are able to access a broad range of information about your account and your interactions with the Platform for the purpose of viewing and, in certain cases, updating your Information. Examples of information you can access easily on the Platform include:
- Personally identifiable information (including name, e-mail, password, communications and personalized advertising preferences);
- Payment settings and
- e-mail notification settings.
- You can opt-out of receiving future marketing communications from us at any time by adjusting your customer communication preferences, through the unsubscribe link within the email communication. For marketing via your mobile application, you will need to adjust your notifications settings in the general section of your mobile.
- You may disable Cookies by changing the settings on your browser. If you disable Cookies, it will affect how our Platform works and you may not be able to access or use certain areas of our Platform or its full functionality. For example, performance cookies collect information about how you use our Platform, for instance, which pages you visit most often, which allows us to provide you with targeted and relevant choices that enhance your Marketplace experience.
- We may retain a copy of your Information for compliance reasons. When you update Information, we may retain a copy of the prior version for our records.
- You shall have the right to rectify inaccurate personal data and update data concerning you and any such rectification and update of your personal data shall be communicated to our service providers, unless it proves impossible or involves disproportionate effort.
- In the event that some of your personal data are incomplete, you shall have the right to have such incomplete personal data completed, including by means of providing a supplementary statement.
Third Party Access
- We will not disclose any Personal Information to third parties unless:
- the disclosure is required or authorized by law, or
- you have consented to our disclosing your Personal Information, or
- for other purposes (relating to the primary purpose for collecting that information, including the processing of your personal data or Personal Information by our agents or data processors) that is reasonably expected including the sale or disposal of any part of our business or rights.
- We may also collect, and our third-party providers of advertisements and content may collect certain user information such as information relating to computer location, URL and IP address and domains, your browser type, the pages of our Platform that were viewed during your visit, the advertisements you clicked on, and any search terms that you entered on our Platform.
- We may contract with third party companies, sub-contractors, agents or other persons to provide certain services including debit card processing, data management, web development, promotional services and such other ancillary services for the fulfilment of our obligation to you as our customer. We shall be entitled to provide our them with the information needed for them to perform these services. We also ask them to confirm that their privacy practices are consistent with ours.
- If we are requested at any time by the police or any other regulatory, investigatory or government authority to provide your Personal Information and/or other user information, we are entitled to do so in compliance with the law.
- At Evesting, we enlist the services of payment service providers in order to enable you make payments on/through the Platform. We may share your information with these payment service providers. You therefore authorize us to share your identity and banking information with our payment service providers in respect of our Services. We shall not be liable for any default, negligence or breach that may arise from the processing of your payment through the payment service providers.
How you give your consent?
- You agree that you do not object to us or our Service Providers, contacting you for statistical or survey purposes, to improve this Platform and its services to you. You consent to such contact whether by telephone, email or in writing.
What happens when Evesting Technologies Limited expands; forms an alliance or sells its business?
- If all or part of our business is sold, (whether by sale of shares or assets) or integrated with another business, your details and Personal Information may be disclosed to our adviser and any prospective purchaser or purchasers and their advisers and will be passed on to the new owners of the business. We’ll notify you (via a message to the email address associated with your account) of any such deal and outline your choices in that event.
- Following completion of any such sale or transfer, your Personal Information shall be disclosed and transferred to such new owner or third party.
How we protect your data.
- This Platform is committed to online security. We maintain security measures to protect sensitive data on our Platform and to prevent unauthorized access of customer information transmitted to servers.
- We cannot however guarantee the security of any data sent over the internet but we have put in place appropriate physical, electronic and managerial procedures to protect, secure and safeguard personal data and information collected on or through our Platform, which measures are reviewed from time to time. Some of the unique measures include but are not limited to the following;
- We always use industry-standard encryption technologies when transferring and receiving customer’s data exchanged on our Platform. We have put appropriate security measures in place in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from you on our Platform.
- We ensure that handshakes (requests and responses) between user devices/browsers and our servers take place over a Secure Socket Layer (SSL/HTTPS) to keep out any middleman attack.
- We scrutinize and sanitize every request to our servers to prevent common security exploitations such as Query Injections and Script Injections.
- We sign every resource-mutating request to our servers with unique security tokens to prevent security breaches such as Cross-Site Resource Forgery (CSRF) and Session Hijacks.
- Every sensitive data collected from our users are hashed and/or encrypted on our servers with AES-256 and AES-128 encryption. All encrypted data are also signed using a message authentication code (MAC) so that their underlying values cannot be modified once encrypted.
- Unfortunately, however, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot guarantee or warrant the security of any Personal Information you transmit to or from our Platform, and you do so at your own risk. Once we receive your transmission, we will do our best to protect its security on our systems.
- All our employees are briefed on the importance of personal data, security and confidentiality of information obtained. They are also trained on practical aspects of the Nigeria Data Protection Regulation, 2019.
- In respect of detection and investigation of breaches where they occur, we have in place relevant controls which should alert us to a breach of security. We endeavor to investigate every notified breach of security.
- The personal data and information held by us are currently stored on a relevant technology system, mass email programme data base, individual account contact manager’s systems together with the training booking spreadsheet, invoicing spreadsheet, Excel spreadsheets and paper form.
- We do not hold any of your Debit card details on this Platform. Such information would be securely passed on to the electronic payment system provider or processor for authorization by your bank.
- We have implemented internet security technology to ensure that it is safe for you to avail yourself of the services on this Platform. We are constantly updating our technology to provide you with the maximum practicable level of security.
What are your Data Protection rights?
Your right to your data privacy as a data subject (whether as a guest or registered user) is as enshrined in the Nigeria Data Protection Rules, 2019 with all the applicable exceptions as stated therein. They include:
- Right to request that the data collected by us on this Platform be made available to you in an electronic format or that it should be sent to a third party (Kindly note that we reserve the right to decline such request where they are manifestly unfounded or excessive, in particular because of their repetitive character).
- Right to obtain from the Data processor restriction of processing.
- Right to transfer data from one data controller to another.
- Right to request that we delete your personal data without delay and we shall delete same where one of the following grounds applies:
- the personal data are no longer necessary in relation to the purposes for which they were collected or processed;
- You withdraw consent on which the processing is based;
- You object to the processing and there are no overriding legitimate grounds for the processing;
- the personal data have been unlawfully processed; and
- the personal data have to be erased for compliance with a legal obligation in Nigeria.
What are your remedies in case of breach?
In case of a breach or complaints about the handling of your personal information, you may lodge a complaint with us via email to firstname.lastname@example.org and we will ensure to resolve your complaints in the shortest possible time.
How long do we store your personal data/information for?
We retain your information for as long as necessary for the purpose(s) for which it was collected and not longer than 7years from the date of collection. The period of data storage is also subject to legal, regulatory, administrative and operational requirements.