This Privacy Policy explains how personal information is collected, used, stored and with whom AFRICA FINTECH LIMITED, ('AFL', 'we,' 'us,' and 'our') share that information. You don’t have to share any information with us, but to access and use the services available on our website and the 9japay mobile application (the “Platforms”), we’ll need some information from you. This Policy also contains information about when we share your personal information with third parties (such as third party service providers and our affiliates).
Last updated: 26th April 2023
This Privacy Policy applies generally to the business of AFL and serves to set out our approach to personal data, inclusive of personal data of our customers ('Users'). This Privacy Policy applies to the use of the Platforms, other online services and or any related services, sales, marketing, promotional or events, and social media activities (collectively, our 'Services'). This Privacy Policy forms part of our general Terms of Use.
This Privacy Policy applies to your use of our Services regardless of means of access. You may access or use our Services through a desktop, laptop, mobile phone, tablet, or other consumer electronic device (each, a 'Device'). This Privacy Policy also applies to offline interactions with AFL.
By accessing or using our Services, you agree to this Privacy Policy.
Protecting your privacy is very important to us. Please review our Privacy Policy in order to better understand our commitment to maintaining your privacy and protecting your data, as well as our use and disclosure of your information. If you receive information about another User through the Services, you must keep the information confidential. You may not disclose or distribute an AFL User’s information to a third party or use the information for marketing or other purposes without that User’s express consent.
We collect and use any information you supply when you interact with any of our Services touch points. As a User, we will also ask you to create a profile and account login information for your 9jaPay account. To enable you carry out financial transactions, we will ask you to provide more information in order to open a bank account with 9jaPay Microfinance Bank. In the process, you will share details like your name, mobile phone number, BVN, ID, address and a picture. When you provide your mobile phone number, we may ask for your consent to receive text messages relating to our Services on that number. Additionally, we may request explicit permission to see other information like your address book, location, photos and data from your camera.
Other information you give on the Platforms may include:
In our KYC (Know Your Customer) process, we run checks on the ID information you supply during signup. We may collect your Personal Information from a User where your Personal Information is filled in a Next-of-Kin form.
If you contact us via other means than the in-app chat, we collect the following information so we can answer your questions or take action.
We (or our service providers acting on our behalf) may collect information about your use of our Services. This information may include Personal Information as well as statistical information that does not identify you ('Analytics'). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy.
We maintain (and require service providers to maintain) generally accepted, reasonable, and appropriate standards to protect your personal information, both during transmission and once it is received. For example, we employ physical access controls, encryption, Internet firewalls, intrusion detection and network monitoring depending on the nature of the information and the scope of processing. In deciding what is reasonable and appropriate, we take into account the risks involved and the nature of the information. However, no security procedures or protocols are ever guaranteed to be 100% secure. In the event that we are required by law to inform you of a breach of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
If you have any questions about the security of your personal information, you can contact us at [email protected].
In line with the Nigerian Data Protection Regulation and the UK Global Data Protection Regulation, we are mandated to have a lawful basis for using your personal information. At least one of the following must apply: contractual or legal duty, legitimate interest, public interest, vital individual interest or consent.
We collect certain data from you to fulfil the contract we have with you or to enter into a contract with you. We use this data to:
We have to ensure we aren’t breaking any laws by preventing illegal activities like money laundering and fraud. To do this, we need your data to
In some instances, we need to use the data you supply us for legitimate interests. This means we’re using your data for a reason which is in your interest, in accordance with applicable laws and doesn't override your privacy, interests or fundamental rights and freedoms.
For certain information, we’ll ask for your consent. We’ll ask for your consent to:
We will only hold your personal information on AFL’s systems for as long as is necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. You however have the right to request deletion of your personal information subject to any overriding legal or compliance requirements.
If you do not want to receive marketing email communications from us, you can opt-out by clicking on the “unsubscribe” link located at the bottom of our marketing emails or you may send a request to [email protected].
Right to Correct or Update Your Information: You may request that we correct or update any inaccurate or incomplete personal information by contacting [email protected]. 9jaPay account holders may update or change their account information at any time by editing their profile or organization record or by contacting [email protected] for more detailed instructions.
Your personal information rights are not absolute: Access to your rights under the applicable laws may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would infringe another’s privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other legitimate reasons.
Right not to provide consent or to withdraw consent: We may seek to rely on your consent in order to process certain personal information. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
Right of access and/or portability: You have the right to access the personal information that we hold about you and, in some limited circumstances, have that data provided to you so that you can provide or port that data to another provider.
Right of erasure: In certain circumstances, you have the right to the erasure of personal information that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected).
Right to object to processing: You have the right to request that we stop processing your personal information and/or stop sending you marketing communications.
Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal information.
Right to restrict processing: ou have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is not accurate or lawfully held).
Right to lodge a complaint to your local Data Protection Authority: You have the right to lodge a complaint with your national Data Protection Authority or equivalent regulatory body.
To assert your privacy rights, please email [email protected]. Please note that to protect your privacy and security, we must be able to verify your identity before we can process your request to exercise any of the privacy rights that you may be entitled to under the applicable laws. We may conduct the verification process by email or phone, and we may ask you to provide information such as your name, contact information, and any additional relevant information based on your relationship with us. You may also use an authorized agent to submit a request to opt out on your behalf if you provide the authorized agent signed written permission to do so.
We do not knowingly collect any personal information from children under the age of 18. If you are under the age of 18, please do not use or submit any personal information through our Website or mobile applications. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Platforms without parental permission. If you have reasons to believe that a child under the age of 18 has provided personal information to us through the Platforms, please contact us at [email protected], and we will use commercially reasonable efforts to delete that information.
The information below applies to our website and mobile applications.
Cookies and other similar technologies help to make our services better to use by doing things like recognizing when you’ve signed in, analyzing how you use our services so we can make them more useful and valuable to you as well as giving you a more personalized experience.
When you interact with our online services, we obtain certain information using automated technologies, such as cookies, web server logs, web beacons and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag, or clear GIF, is a tiny graphic image that may be used in our websites or emails.
We use these automated technologies to collect your device information, internet activity information, and inferences as described above. These technologies help us to:
We set some of these automated technologies ourselves, but others are set by third parties who deliver services on our behalf. Some of these technologies may also be set by third parties that help us advertise our products and services to you as informed by your interests, based on information collected from your activity on the web, including but not limited to, browsing or purchasing products on or through our websites or on third party websites or your activity on mobile sites and applications. This advertising approach is called interest-based advertising or “targeted advertising.”
Your browser can alert you when cookies are placed on your device, and how you can stop or disable them via your browser settings.
Please note, however, that without cookies all of the features of our online services may not work properly. If you use a mobile device, you can manage how your device and browser share certain device data by changing the privacy and security settings on your mobile device.
Within mobile applications, you may also go to your device settings and select “Limit Ad Tracking” (for iOS devices), or “Opt out of Interest-Based Ads” (for Android devices), which will allow you to limit our use of information collected from or about your mobile device (such as precise location data) for the purposes of serving online behavioral advertising to you.
We may transfer and access your personal information from around the world, including from other countries in which we have our operations.
We will protect your personal information in accordance with this Policy wherever it is processed and will take appropriate contractual or other steps required to protect the relevant personal information in accordance with applicable laws. We contractually obligate recipients of your personal information to agree to at least the same level of privacy safeguards as required under applicable data protection laws.
We’re extremely committed to respecting and protecting your information. If you have questions regarding your data privacy rights or would like to submit a related data privacy rights request, please contact us by:
Subject to applicable laws, we may revise this Privacy Policy at any time and in our sole discretion. When we revise this Privacy Policy, we will post the revised version on the Platforms and will update the date at the top of this Privacy Policy. We advise you to check this page often. The revised Privacy Policy will be effective upon posting via the Platforms, unless otherwise set forth therein or as otherwise required by applicable laws. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing or using our Services. If you do not agree to the terms of this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access and use of our Services. Except as otherwise expressly stated by us, your access and use of our Services are subject to the version of this Privacy Policy in effect at the time of access or use.
