Zobo's Privacy Policy

SECTION 1: INTRODUCTION

Zobo Payments Limited ( Zobo Payments Limited or “us” or “we” or “our”) is a limited liability company incorporated under the laws of the United Kingdom with registration number 15627149. Zobo strongly emphasizes safeguarding the privacy of personally identifiable information entrusted to us. This Privacy Policy ("Policy") outlines how we collect and utilize Personal Information provided on the Zobo App (collectively referred to as the "Platform"). Our services include internet-enabled money transfers and all other services provided to you on our behalf through the Platform from time to time (“Services”).

Our Policy clarifies what personal information we gather about you, who we may share it with, and how you can, in specific instances, opt not to share your information with third parties. "Personal Data" means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; It can be anything from a name, address, a photo, an email address, bank details, posts on social networking Platforms, medical information, and other unique identifiers such as but not limited to MAC address, IP address, IMEI number, IMSI number, SIM and others.

We retain the right to modify this Policy at any time. When we make revisions, we will notify you by posting an updated version on our Platform. However, if we intend to make significant changes in how we collect, utilize, or store your personal information, we will give prior notice via email and our Platform. You will then have the opportunity to decide whether we can use or disclose your information under the new terms, either through an "opt-out" process or by terminating your association with us. These changes will become effective no sooner than 30 days after the date of the notifications.

SECTION 2: CONSENT

Please read this Policy very carefully. If you do not wish to be bound by the provisions of this Policy, you should not access our App, Website or sign up for our Services. By using the Platform and by signing up for our Services, you hereby confirm that you have read, understand, and agree to be bound by the Policy.

Additionally, please note that the option to sign up on the Platform is intended solely for persons who are eighteen (18) years of age or older, and any registration by, use of or access to the Services by any person under 18 is unauthorized and in violation of this Policy.

You hereby give us consent to the collection and processing of your Personal Data for the purpose of providing the Services. You hereby certify that all the information provided by you are true and correct and that any misrepresentations or falsity, whether intentional or not, therein will be considered as an act to defraud us and our partners. You authorize us to verify and investigate the above statements/information as may be required, from the references provided and other reasonable sources. For this purpose, you hereby waive your rights on the confidentiality of client information and expressly consent to the processing of any Personal Data and records relating to you that might be obtained from third parties, including government agencies, business associates, and other entities.

If you have any inquiries or concerns regarding this Policy, please feel free to contact us at [email protected].

SECTION 3: INFORMATION WE COLLECT

We may collect, use, and share Personal Data, tax information, including relevant information about you, your transactions, your use of the Services, and your relationship with us. Please note that this information may encompass non-public personal information and any other information you choose to provide to us, such as:

Personal and Financial Information

Information provided by you while using the Service, including your:

Residential address
Email address
Date of birth
Phone number
Social Security Number
Bank account online login information
Bank and credit information
Details of any transaction carried out using the Services
Credit/debit card number
Documents that may include your photograph
In specific cases, information from scanned copies of official identification documents like your Int. Passport, Driver's License e.t.c.

Third-Party Personal Information

Information you supply to enable us to facilitate funds transfers, such as your recipient's full name, physical address, email address, phone number, etc.

Note: we will not contact your recipients unless directed by you or as needed to complete a transaction. This data is solely used to fulfill your requests or for any other specified purposes.

Usage Information

Data related to your usage of the Service, including username and password; transaction history; usage metrics (including usage rates, occurrences of technical errors, diagnostic reports, settings preferences, content and advertising interactions; details of how and with whom you use the Service for money transfers.

Information from Third Parties

Data lawfully obtained from third-party sources, such as identity verification services, electronic database services, credit reporting agencies.

Indirectly Obtained Information

Information indirectly gathered from you, including data about your computer and mobile device hardware and software you employ to access the Service, your IP address and location, browser and device name, type and version, operating system type and version, domain names and the web pages you visit before accessing the Service. This information is used for the operation of the Services, to maintain quality of the Services, and to provide general statistics regarding use of the Platform.

Utilization of Technologies

We employ technologies such as cookies, beacons, tags, and scripts, along with our marketing, analytics, and risk partners or affiliates. These technologies serve the following purposes: analyzing trends, administering the Platform, tracking user movements on the Platform, collecting demographic information about our user base. We may also collect additional information involving your opinion of our products and Services and your preferences regarding other services such as newsletter subscription, preferred routes, and commuting frequency.

We may receive reports based on the utilization of these technologies, both on an individual and aggregated basis.

Automatic Log Information

Similar to most platforms, we automatically gather specific information and store it in log files. This information may encompass: internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data.

We may combine this automatically collected log information with other data we collect to enhance the Services we provide.

Third-Party Advertising

We may collaborate with a third party to manage our advertising on other Platforms. Our third-party partner may utilize technologies like cookies to collect information regarding your activities on this site and other sites to deliver advertising tailored to your browsing activities and interests.

Please note that when you sign up for our services, you may also be required to agree to the privacy policy of our partners. These partner privacy policies detail your choices regarding the use of your personal information and how you can access and update it. Furthermore, this Policy applies if you take part in our surveys and user research projects.

Also note that our Platform may contain links to other resources not owned or controlled by us and as such, we encourage you to review the privacy statements of platforms you choose to link from our Platform so that you can understand how those Platforms collect, use and share your information. Please bear in mind that Zobo is not responsible and will not be liable for the privacy practices or other content of such other resources or third parties.

In most cases, providing your personal information to us is optional, however, if you do not provide certain information to us, you may not be able to use our Services. For example, we need details such as your name, address and bank account details so that you can use our payment services.

SECTION 4: WHY WE COLLECT INFORMATION AND HOW WE USE IT

We collect Personal and Non-Personal information for the following purposes:

To register you and provide the Services to you, to facilitate the processing of your payments on other platforms or websites operated by our users, to communicate with you in connection with our various services and KYC verification processes (including via SMS, messaging applications, or, for users of our Platform, via “push” notifications) or any changes in our Terms and Conditions or this Policy that apply to you.
For the purpose for which you specifically provide the personal information to us, including, to respond to your inquiries, to provide any information that you request, and to provide customer support (including via SMS, messaging applications, as applicable).
To verify/validate your identity (including via SMS or Voice Call, as applicable) and verify your access and control over bank accounts you associate with our Services.
To collect payment for your use of the Services.
To track, improve and personalize our Services, content and advertising.
To improve and maintain performance of the Platform, by ensuring that the content is presented in the most effective manner for you.
To troubleshoot problems with the Platform.
To comply with applicable laws and regulations, such as those relating to "know-your-customer," and anti-money laundering requirements.
To update our records;
To protect us, our customers, employees, partners or property — for instance, to investigate fraud and prevent fraudulent activity, abuse of the services, harassment or other types of unlawful activities involving us or other companies that we do business with, to enforce this Policy, as well as our Terms and Conditions.
To protect you by detecting, investigating, preventing, or tackling illegal activities, fraud, or situations involving potential threats to your rights.
To ensure compliance with our policies, terms, and other applicable laws and regulations.
To respond to inquiries and offer support to you.
To request your feedback and improve your user experience.
To carry out our obligations arising from and exercise our rights under any agreements between you and us.
To allow you to participate in interactive features of our Services, when you choose to do so.
To notify you about changes to our Services or potential new services that we may offer.
To provide you with customer service;
To detect and prevent fraud and other illegal uses of the Platform.
To create an account connection between your Zobo account and a third-party account or platform (such as your online bank account).
To send you marketing notices, service updates, and promotional offers.
To collect survey information that will be used to monitor or improve the use of our Service and overall customer satisfaction.
In any other way that you have specifically consented to.

We will retain your information for as long as your account is active or as needed to provide you Service. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

SECTION 5: HOW WE SHARE INFORMATION WITH OTHERS

We do not share Personal Data with unaffiliated third parties, except as necessary for our legitimate business interest, to provide you with our Services, and/or as required or permitted by law or professional standards and generally to facilitate the running of our business or to provide specific services you have requested. We will only disclose your personal information to third parties as outlined in this Policy. We do not sell or lease the information we collect to third parties for their promotional purposes. These third-party entities are permitted to utilize your personally identifiable information solely for the purpose of providing services to us.

We would only transfer Personal Data to the following categories or situations, when they meet our strict standards on the processing of data and security. We only share Personal Data that is necessary for them to provide their services. Commonly, we may share your Personal Data in the following instances:

Third-Party Service Providers

We engage third-party service providers who are under contract with Zobo to assist us in our business operations and improve our products. These operations include transaction processing, customer service, fraud prevention and detection, marketing, market research, and validation of information provided. These third parties are strictly prohibited from using your information for their independent business purposes.

Business Transfers

In the event of the sale, acquisition, or merger of some or all of our assets, your Personal Data may become part of the transferred assets. We will notify you in such a circumstance, along with any choices you may have regarding your personal information, by posting a notice on our Platform.

Audits

Disclosures of Personal Data may also be needed for data privacy, financial or security audits and/or to investigate or respond to a complaint or security threat.

Legal and Regulatory Requirements

We may disclose your information to regulators, law enforcement, government officials, or other third parties, but only in connection with formal requests, subpoenas, court orders, or similar legal procedures. This disclosure will occur when we have a good faith belief that it is necessary to comply with the law, prevent physical harm or financial loss, report suspected illegal activity, or investigate violations of our user Agreement.

Consent and Account Linking

We may share your information with other third parties if you provide your consent or direction. This may involve authorizing an account linking with a third-party service, account, and/or platform. An "account linking" is a connection you enable between your Zobo account and a non-Zobo account, payment instrument, or platform that you legally control or own. When such a connection is authorized, Zobo and the third party will directly exchange your personal information and other relevant data.

Access to Financial Information

If you connect your Zobo account to other banking or similar accounts, directly or through a third-party service provider, we may have access to your account balance and transactional information. This includes purchases and funds transfers. Information obtained through account connections will be used in compliance with this privacy policy.

Third-Party Privacy Practices

Information shared with a third party based on an account connection will be managed and disclosed in accordance with the third party's privacy practices. Prior to authorizing an account connection, you should review the privacy notice of any third party gaining access to your personal information as part of the account connection.

SECTION 6: YOUR PRIVACY RIGHTS

This Policy describes your privacy rights regarding our collection, use, storage, sharing and protection of your Personal Data. It applies to our Platform, App and all other related applications, services, tools and physical contact with us regardless of how you access or use them.

Subject to applicable laws, you have the following rights:

right to request from us access to and rectification or erasure of your Personal Data;
right to restrict processing or object to processing of your Personal Data;
right to data portability;
right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
right to lodge a complaint with the relevant authority.

In the event that you wish to: (i) access your Personal Data processed by us in accordance with this Privacy Policy, or (ii) ask any questions at all regarding our use of your Personal Data, or (iii) rectify your Personal Data processed by us in accordance with this Privacy Statement (iv) restrict or object to processing of your Personal Data (v) withdraw your consent to our processing of your Personal Data or (vi) request for data portability , please reach out to us at [email protected]. We will respond to your request to access within a reasonable timeframe.

We carefully analyze what types of Personal Data we need to provide our Services, and we try to limit the Personal Data we collect to only what we

SECTION 7: CUSTOMER OBLIGATIONS

You agree to inform us promptly, and in any event, within 7 (seven) days, in writing if there are any changes to Customer Information supplied to us from time to time, and to respond promptly to any request from us.

Where:

you fail to promptly provide Customer Information that we reasonably requested, or
you withhold or withdraw any consents that we may need in order to process, transfer, or disclose Customer Information for the purposes set out in this Policy (except for purposes connected with marketing or promoting products and services to you), or
we have suspicions regarding Financial Crime or an associated risk.

we may:

be unable to provide new, or continue to provide all or part of the, Services to you and reserve the right to terminate our relationship with you;
take actions necessary for us to meet our compliance obligations; and/or
block, transfer, or close your account(s) where permitted under applicable laws.

In addition, if you fail to supply promptly your Tax Information and accompanying statements, waivers, and consents, as may be requested, then we may make our own judgment with respect to your status, including whether you are reportable to a Tax Authority, and may require us or other persons to withhold amounts as may be legally required by any Tax Authority and paying such amounts to the appropriate Tax Authority.

You agree that we shall not be liable for any loss or damage arising from or incidental to our use, collection, processing, and sharing of customer information, and any action we have taken in relation to this section.

SECTION 8: RETAINING YOUR PERSONAL DATA

We retain your Personal Data for as long as your account is active and therefore open; this allows you to continue accessing our content, products and Services.

If you become inactive, we will retain your Personal Data only for the period within which it is reasonably needed and may delete elements of your Personal Data associated with your account.

Where we do not need to keep all of your Personal Data in full, we may obfuscate or aggregate it, for example, web activity logs and survey responses. This is to ensure that we do not retain your Personal Data for any longer than is necessary.

It is sometimes necessary for us to keep your Personal Data for longer periods of time to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal information, we consider (amongst other things):

obligations and/or retention periods imposed on us by applicable laws and/or our regulators
the amount, nature, and sensitivity of the personal information
the potential risk of harm from unauthorized use or disclosure of your personal information, and
the purposes for which we process your personal information and whether we can achieve those purposes through other means.

SECTION 9: LAWFUL BASIS FOR PROCESSING

We only process Personal Data where we have a lawful basis for doing so, such as the following:

User consent – This is where you have given us explicit permission to process Personal Data for a given purpose. For example, if you create a user account on our App or Platform.
Contractual necessity – This is where we have to process Personal Data to meet our contractual obligations to you.
Legal obligation – This is where we have to process Personal Data in order to comply with the law.
Protection of vital interests – This is where we are constrained to process your Personal Data in order to protect your interests or those of another person, such as to prevent identity theft.
Public interest – This is where there is an overriding public interest or we have been vested with an official public mandate to take certain action in the interest of the public.
Legitimate/Commercial Interest – This means our interest in conducting and managing our Services to enable us to give you the best service or product and the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted to by law.

SECTION 10: HOW DO WE SECURE AND STORE PERSONAL DATA?

We employ all reasonable efforts to keep your Personal Data secure by taking appropriate technical and organizational measures against its unauthorized or unlawful processing and against its accidental loss, destruction or damage. We store and process your Personal Data on our computers in Nigeria. When we need to transfer your Personal Data to another country, we would take reasonable steps to ensure that such country has an adequate data protection law. You hereby consent to the transfer of your Personal Data to countries which may not be on the white list specified by the Data Protection Act where such transfers become expedient for us. We protect your Personal Data using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls.

However, no data transmission over the internet or wireless network can be completely secured or guaranteed. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our Platforms; any transmission is at your own risk. Therefore, whilst we strive to protect your Personal Data, using strict procedures and security features, you acknowledge that:

there are security and privacy limitations of the internet which are beyond our control;
the security, integrity, and privacy of any and all information and data exchanged between you and us cannot be 100% guaranteed; and
any such information and data may be viewed or tampered with in transit by a third party, despite our best efforts.

SECTION 11: DATA BREACH

In the event we become aware that the security of our Services have been compromised or users’ Personal Data have been disclosed to unrelated third parties as a result of an external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach. When we do, we will post a notice on our Platform and App (if possible) and/or send you an email.

SECTION 12: OPT-OUT & UNSUBSCRIBE

We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. You may opt-out of receiving any or all communications from Zobo by contacting us at [email protected]. you may also opt-out of receiving emails about our special offers by using the unsubscribe link provided in the email, or by contacting us as noted above.

SECTION 13: WHAT HAPPENS WHEN YOU PROVIDE US WITH INFORMATION ABOUT OTHERS?

If you provide us with Personal Data about another individual, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protection laws in relation to such disclosure. Insofar as required by applicable data protection laws, you must ensure that you have provided the required notices and have obtained the individual’s explicit consent to provide us with the information and that you explain to them how we collect, use, disclose and retain their Personal Data or direct them to read our Privacy Policy.

If you choose to participate in our Refer a Friend program, you acknowledge that you have the right and are duly authorized to provide us with your friend’s personal information.

SECTION 14: DELETION OF ACCOUNT

Upon your request for deletion of your account, we will process the request and delete your account along with all of your records and information regarding your identification and transactions. In accordance with applicable laws or regulations and, to the extent not prohibited under applicable law, we will retain your records in accordance with our internal policies and procedures for purposes of prevention of fraudulent activities, risk management, defense against claims and security.

For general enquiries regarding this Privacy Policy, or to make a request or complain about how we process Personal Data, you may contact us at [email protected].