This Privacy Policy (“Policy”) has been put together to explain to you how we collect, use, store, share, transfer and otherwise process the personal information that you provide to us or that we collect 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.
This Policy is intended to comply with the Nigeria Data Protection Act 2023 and other applicable data protection laws and regulations in Nigeria.
The reference to “you” or “your” means you, any authorised person that uses your account, and anyone who initiates, conducts or concludes a transaction using your SnapCash account.
This Policy applies to your use of the Platform on the web and mobile application. By visiting, accessing or using the Platform, you acknowledge that your personal data will be processed in accordance with this Policy and applicable law. Where consent is required by law for any specific processing activity, we will obtain such consent separately.
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 falls 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 data.
d. We may hold sensitive personal data about you, including, where applicable and lawful, biometric information used to uniquely identify you, such as your fingerprint, facial recognition or voice recording, and other sensitive personal data processed in connection with the products or services we provide to you. We will only process such data where permitted by applicable law, including where processing is necessary for the establishment, exercise or defence of legal claims, for reasons of substantial public interest, to comply with a legal obligation, to protect your vital interests, or with your explicit consent where required.
e. We use cookies and similar tracking technologies to track activity on our Service and hold certain information. Cookies are files with small amounts 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:
Depending on the purpose, we process your personal data on the basis of your consent, performance of a contract with you, compliance with a legal obligation, protection of your vital interests, performance of a task carried out in the public interest, or our legitimate interests where such interests do not override your fundamental rights and freedoms.
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 where permitted by law
j. Process transactions, design products and improve our services
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 enforce 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, affiliates and subsidiaries
2. Legal and regulatory authorities
3. Professional advisers: auditors and legal advisers
4. Credit agencies
5. Correspondent banks
6. External auditors
7. Strategic partners and service providers for the purpose of providing our services
8. Other persons or entities where we have your consent or where disclosure is otherwise permitted or required by law
Where your personal data is transferred outside Nigeria, we will ensure that such transfer is carried out in accordance with applicable law and subject to appropriate safeguards or other lawful transfer mechanisms.
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.
Where required by applicable law, we will notify the relevant regulator and affected data subjects of personal data breaches within the time and in the manner prescribed by law.
D. How long we keep your information.
We retain your Information for as long as the purpose for which the information was collected continues and for such additional period as may be required to comply with applicable legal, regulatory, tax, accounting, internal compliance, dispute resolution, enforcement, audit or reporting obligations.
The applicable retention period will depend on the nature of the data, the product or service involved, and the legal or regulatory obligations that apply to us.
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 as provided by the Nigeria Data Protection Act 2023 and other applicable laws, subject to applicable limitations and exceptions.
1. A right to request information about and access to your personal data
2. A right to rectify or update your information in our possession
3. A right to request the erasure of personal data in appropriate circumstances
4. A right to withdraw your consent to processing of personal data where consent is the lawful basis
5. A right to object to processing of personal data in certain circumstances, including direct marketing
6. A right to request restriction of processing in appropriate circumstances
7. A right to request that your personal data be made available to you in a structured, commonly used electronic format and, where technically feasible, request that such data be sent to a third party
8. A right, where applicable, not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects on you, except as permitted by law
9. A right to lodge a complaint with the Nigeria Data Protection Commission
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 except as permitted by applicable law.
We do not allow children under the age legally permitted to consent under applicable law to open accounts or use services without the consent of a parent or legal guardian where such consent is required.
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. These third parties may process personal data on our behalf only for the purpose of providing services to us and subject to appropriate confidentiality and security obligations.
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. Any changes will be posted on our website, on the Platform, or otherwise communicated as required by law.
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, audit, dispute resolution or fraud prevention obligations.
Contact
If you have any questions about this Privacy Policy, want to exercise your data protection rights, or wish to make a privacy-related complaint, please contact us at hello@snapcash.ng or call +234 201 700 4271.
You also have the right to lodge a complaint with the Nigeria Data Protection Commission.