This Privacy Policy (“Policy”) has been put together to explain to you what we do with the personal information that you provide to us when you use SnapCash, a peer-to-peer lending solution (“Solution”, “platform” or “SnapCash”) developed by Sterling Bank (“we”, “us”, “our” and/or “ours”) incorporated under the laws of the Federal Republic of Nigeria with its registered office at Sterling Towers, 20 Marina, Lagos.
The reference to ‘you’ or ‘your’, means you, any authorised person that use your account, anyone who initiates, conducts or conclude a transaction using your SnapCash account.
By continuing to visit, access or use the Platform either on the web or via the mobile app, you accept and consent to the provisions described in this Policy.
A. Information we may collect from you
We may collect and process the following data about you.
1. Information you give us about you (Submitted information):
We gather information from you for a number of reasons. We may need you to provide your Personal Information/Data such as your name, contact details, identification, work and residential addresses, gender, positions held, forms submitted, Bank Verification Number (BVN), payment details and other enquiry details which would enhance your service experience. Your Personal Data we collect, fall into various categories, such as:
a. We collect information from your address book or contact list, if you explicitly permit us to access such information. These include the phone number of persons who use our services and other contacts who do not use our service. Your contact list information is required for us to provide you with seamless value-added services through the Platform; for instance, airtime purchase for beneficiaries on your contact list. We may also access your gallery information for images or photos, where you wish to personalize your SnapCash profile.
b. This includes information on any bank accounts you use, debit card numbers, financial history, information you provide to deliver payment initiation services and account information services regarding accounts you hold with other providers.
c. We may also collect information that your browser sends whenever you visit our website or banking applications or when you access the Solution or any of our services by or through a mobile device (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit and the time spent on those pages amongst other diagnostic data. When you access the Service by or through a mobile device or use the mobile app, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic dat
d. We may hold information about you which includes without limitation to health, criminal conviction information or biometric information used to uniquely identify you, (for example your fingerprint, facial recognition or voice recording). We will only hold this data when we need to for the purposes of the product or services we provide to you, where we are required to process the data for a public interest purpose, or where we have a legal obligation or your consent to do so
e. We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.
Session Cookies: We use Session Cookies to operate our Service. Session cookies will expire at the end of your browser session and allow us to link your actions during that browser session.
Preference Cookies: We use Preference Cookies to remember your preferences and actions, across multiple sites.
Security Cookies: We use Security Cookies for security purposes.
Information from social networks or online accounts: This includes Information from any social media profiles or any accounts that you share with us.
This information may include your name, address, e-mail address and phone number, the Device's phone number, age, username, password and other registration information, financial and credit information (including your mobile money account details, bank account details, and bank verification number, where applicable), personal description and photograph.
2. To the extent permissible under applicable law, we may use your information for the following legitimate actions:
a. Determine your eligibility for our other products and services
b. Verify your identity when you access your account information
c. Administer your accounts or other products and services that we or our partners/affiliates may provide to you
d. Respond to your requests and communicate with you
e. For understanding your financial needs
f. Prevention of crime, fraud, money laundering or terrorism financing activities
g. Managing our risks
h. Reviewing your credit or loan eligibility
i. For marketing the products and services of Sterling, related entities and affiliates
j. Process transactions, design products and profile customers
k. Notify you about changes to our Services
l. Allow you to participate in interactive features of our services when you choose to do so
m. Provide customer care and support and for internal operations
n. Process your information for audit, statistical or research purposes
o. Monitor our conversation with you when we speak on the telephone
p. Recover any debts that you may owe the Bank
q. Carry out analysis to evaluate and improve our business
r. Monitor the usage of our Services
s. Detect, prevent and address technical issues
t. Prevent fraud and enhance security of your account or our service platform
u. Comply with and enforcing applicable legal and regulatory requirements
v. Provide you with tailored content and marketing messages
w. For other purposes required by law or regulation
B. How do we share your information?
We may share the information about you and your dealings with us, to the extent permitted by law, with the following:
1. Sterling Branches and subsidiaries
2. Legal/Regulatory Authorities
3. Professional Advisers: Auditors/Legal Advisers
4. Credit Agencies
5. Correspondent Banks
6. External Auditors
7. Strategic partners/service providers – for the purpose of providing our services
C. How we secure your information
We have implemented appropriate organizational and technical measures to keep your Personal Information/Data confidential and secure.
Although we have taken measures to secure and keep your information confidential, because the security of your data is important to us, please be aware that no method of transmission over the Internet can guarantee 100% security.
D. How long we keep your information.
We retain your Information for as long as the purpose for which the information was collected continues.
Please note that regulations may require Sterling to retain your personal data for a specified period even after the end of your banking relationship with us.
E. Your Rights
You have certain rights in relation to the personal data we collect:
1. A right to access your personal data
2. A right to rectify/update your information in our possession
3. A right to request the erasure of personal data
4. A right to withdraw your consent to processing of personal data
5. Right to object to processing of personal data
6. Request that your personal data be made available to you
7. Request that your information be erased
F. Privacy of minors
We do not knowingly collect names, email addresses, or any other personally identifiable information from children through the internet or on the Platform.
G. Third Party Websites
Our website, related websites and mobile applications may have links to or from other websites that are not operated by us.
H. Service Providers
We may employ third party companies and individuals to facilitate our services on the SnapCash Platform.
I. Changes to this Policy
This Privacy Policy is effective as of the date stated above and will remain in effect except with respect to any changes in its provisions.
Based on the changing nature of privacy laws, user needs and our business, we may modify this Privacy Policy from time to time.
J. Account Deletion
You can delete your account from within the app or you can send an email to support@snapcash.ng.
If you would like to delete your SnapCash account and associated personal data by email, please send an email to support@snapcash.ng with the subject line “Account Deletion Request”.
Please note that certain information may be retained where required to satisfy legal, regulatory, internal compliance or fraud prevention obligations.
Contact
If you have any questions about this Privacy Policy, please contact us at hello@snapcash.ng or call +234 201 700 4271.