HOW YOU MAY GIVE YOUR CONSENT

Please note that the terms of this Privacy Policy apply to your usage or continued usage of our services and regulate the acceptance, collection, storage, use, transfer, sharing or other forms of processing of your information as described herein and in our Terms and Conditions and by your checking the acceptance box on the sign up page of the application, you consent to the application of the terms of this Privacy Policy and Terms and Conditions to your usage of our services.

STATEMENT OF COMPLIANCE WITH DATA PROTECTION PRINCIPLES

Your personal data is stored securely on our server and we take steps to ensure the security of your data by implementing physical, electronic, and procedural safeguards in order to protect the information, including storage of the information on secured servers protected by secured networks to which access is limited to a few authorized employees and personnel. Your data is stored for the period you are subscribed to our service and if you elect to deactivate your account, we delete your data from our server.

INFORMATION AVAILABLE TO US

When you install, access or use our app, we may process the following categories of information for the purposes described below.

INFORMATION YOU GIVE TO US

• Account and user profile: We accept your name, phone number and email address to create your user account and profile. You may also choose to provide additional information for your user profile such as photo and address.
• Address book: If you have granted consent, by responding to the explicit popup request for consent that comes up when you attempt to pick a phone number from your address book, we access the contacts in your address book. By granting such access, you confirm that you are authorized to share the information in your address book with us.
• The contact number you choose from your address book is collected to process your service request and will be shared with third-party service providers to complete the processing of your initiated service request.
• Photos: If you have granted consent, by responding to the explicit popup request for consent that comes up when you attempt to upload a profile photo or take identity verification photo, we securely store such images on our servers. By granting such access, you confirm that you are authorized to share the image with us.
• Customer support: When you contact us about your experience of using our services, we will use the information you have provided to respond to and resolve issues, for example, when you contact us via email support.

INFORMATION WE GET WHEN YOU USE OUR SERVICES

Device and connection information: We collect your device information and unique identifiers so that you can connect to and use our services. Device information means device settings, operating system, IP address, and screen resolution.

We need access to device information to:

• Monitor our systems to ensure that they are working as intended;
• Identify and resolve any problems and bugs that may only impact one type of manufacturer or device type;
• For security and fraud detection by identifying unusual usage patterns;
• Understand whether you have turned on notifications and location so that we can comply with your choices.

• Unique identifiers are a number of characters used to identify a device. Some are permanent and others can be reset at any time by users on their devices. We use unique identifiers for various purposes including remembering your preferences, detecting fraud, security, customizing services or analysing device related issues.
• Location information: If you have granted, by responding to the explicit popup request for consent that comes up when you attempt to use a location dependent feature, we may collect information about your precise device location using GPS to enable user features. You can also control whether to share your location in your device settings at any time (Android devices, Apple devices).
• Order information: When you register for paid services, we will collect your payment information and payment receipts, including from third parties processing such payments. This enables us to keep record of our transactions with you.

THIRD PARTY INFORMATION

We receive information about you from third-parties when you register for services or update your profile information using third party services such as social media accounts.

You may also use our services in connection with third-party services. In order for the services to interoperate with such third-party services we may receive information from them about you or we may share your information with them. For example, you may log in to our services using third party services or create an account on a third-party platform by using our services to pre-populate your information to register with them or you may connect your user profile with third-party services. By logging in to our app using third party services or creating an account on a third-party platform using our app or otherwise connecting your user profile on our app with third-party services, you agree that we may: (a) collect, accept, use and retain the information provided by these third-party services in accordance with this Privacy Policy, and (b) supplement your user information if, for example, you choose to create your account or update your profile information by using Facebook, Google or Microsoft. Such third parties only share such information with your prior consent and based on their privacy terms. We never store any passwords created for third-party services. Your use of third-party services is governed by the terms and privacy policies of such services.

THIRD PARTY INFORMATION

We use the information to provide, operate, maintain, support, improve, understand, market and personalize our services for you in the following ways.

THIRD PARTY INFORMATION

Club Members Some information including usage information and other information that may arise from your interaction with BonusPay app, cannot be used to identify you, whether in combination with other information or otherwise and will not constitute personal information for the purposes of this policy.

Discount Partners A business may create a profile to make its business information (including business or trading name, phone number, email, address, business hours and social media handles) publicly available to users of the BonusPay app. Such information will not constitute personal information for the purposes of this policy and the Discount Partner Terms shall apply.

HOW WE USE PERSONAL INFORMATION

We use the information to provide, operate, maintain, support, improve, understand, market and personalize our services for you in the following ways.

• Claim discount from our discount partners.
• Purchase airtime and data.
• Make bill payments.
• Create a virtual account.
• Fund and withdraw from your secure wallet.
• Providing customer support, responding to your queries, investigating and resolving issues related to the services.
• Understanding how our users use our services.
• Analyzing and using the information to evaluate and improve our services, business and operations.
• Developing or providing services to third parties or to improve third party services.
• Researching, developing and testing new services and features.

Safety and security: We use your information to comply with applicable laws, identity verification, verify user accounts and activity, ensure service functionality, safety and data accuracy, investigate suspicious activity and enforce our agreements, perform troubleshooting activities, and prevent fraud, security breaches, circumvention of the intended use of our services, our Terms and Conditions, this Privacy Policy and restricted, prohibited or illegal activities.

Third party services: With your consent, we enable you to use and share your information to use our services in connection with other third-party services. For example, use payment services. If you use a third-party service via a link in our services, you may be providing information directly to such third party. In such cases the terms and privacy policies of the third-party service will apply to your use of their services.

Third party service providers: With your consent, we enable you to use and share your information to use our services in connection with other third-party services. For example, use payment services. If you use a third-party service via a link in our services, you may be providing information directly to such third party. In such cases the terms and privacy policies of the third-party service will apply to your use of their services.

Statistical data: We use aggregated information for statistical and analytical purposes. We may share such data with third parties. We do not consider personal information to include information that has been de-identified, made anonymous or aggregated so that it can no longer be used to identify a specific person, directly, or in combination with other information or means that are reasonably likely to be available to us. We may provide measurement and analytics services (using such information) in order to assist businesses to better understand the effectiveness of their user interactions on our services, engagement, and the distribution of their products and services.

USER RIGHTS AND ACCESS

Access and Correction: You have the right to request access to the personal information we hold about you and to request corrections if the information is inaccurate or incomplete. You can do this through your account settings or by contacting us at support@bonuspay.io.

Data Portability: You have the right to request a copy of your personal data in a structured, commonly used, and machine-readable format and to request that we transfer this data to another service provider where technically feasible.

HOW WE ENABLE INFORMATION SHARING

We enable information sharing to provide, operate, maintain, support, improve, understand or personalize our services, in the following ways:

Third party services: With your consent, we enable you to use and share your information to use third party services. For example, use of payment services and identity verification using BVN. In such cases the terms and privacy policies of the third-party will apply to such information and your use of their services.

Third party service providers: We use trusted third-party service providers to support our services and business. When we share information with such third parties, we require them to take appropriate organizational and technical measures to protect your information and observe applicable laws.

Law and safety: We may disclose your information if we believe such action is necessary to:

• Comply with applicable laws, government requests, or legal processes served on us;
• Protect and defend our rights and property, including the rights and property of our employees and contractors (including enforcing our agreements, policies, and Terms and Conditions);
• Protect the safety and security of our users and third parties or the public (including preventing fraud, security breaches, or the use of our services for illegal or restricted purposes);
• Enforce compliance with laws or regulations, including anti-money laundering regulations and “know your customer” requirements.

Safety and security: We use your information to comply with applicable laws, verify user accounts and activity, ensure service functionality, safety, and data accuracy, investigate suspicious activity, enforce our agreements, perform troubleshooting activities, and prevent fraud, security breaches, circumvention of the intended use of our services, our Terms and Conditions, this Privacy Policy, and restricted, prohibited, or illegal activities.

Acquisitions and transfer: We may disclose and transfer your information or our obligations and rights under this Privacy Policy to any of our affiliates or successors, and to any third party in connection with a proposed or actual corporate restructuring, who proposes to acquire all or part of business or operations, whether such acquisition is by way of investment, merger, restructuring, sale of capital or assets, by operation of law, or otherwise.

HOW WE ENABLE INFORMATION SHARING

We process your data under the following legal bases:

Consent: When you have given explicit consent for us to process your data for specific purposes, such as marketing communications or location data.

Contract: When processing your data is necessary for the performance of a contract, such as providing services you have requested.

Legal Obligation: When we are required to process your data to comply with a legal obligation, such as anti-money laundering regulations.

Legitimate Interests: When processing your data is necessary for our legitimate interests, such as improving our services, provided it does not override your rights and freedoms.

DATA RETENTION

BonusPay will retain your information for as long as you maintain a user profile in the services. You may at any time choose to deactivate your account and delete your user profile and information via Account Deletion. If you delete your account, your profile information will no longer be visible to others in the services, and we delete from our servers any of your information that we do not need to provide our services. However, deactivating your account will not delete information that you have shared with others. We will retain your information for the period necessary to fulfill the purposes outlined in our Privacy Policy unless a longer retention period is required or permitted by law.

SECURITY AND TRANSFER OF INFORMATION

The services require by their very nature that your information may be transferred to other users and third parties across the globe for effective provisioning of the services. BonusPay may use cloud-based services and subcontract storage or processing of your information to third parties located in countries other than your home country in order to provide the services, such as India and the USA. Information emanating from one country may for example, be transferred to and processed in another country.

We take all reasonable precautions to protect personal information from misuse, loss and unauthorized access, including by requiring transferees of information located in other countries to comply with contractual data protection requirements.

We have implemented physical, electronic, and procedural safeguards in order to protect the information, including that the information will be stored on secured servers and protected by secured networks to which access is limited to a few authorized employees and personnel. Data exchange between the BonusPay app and processing servers are encrypted. However, no method of transmission over the internet or method of electronic storage is 100% secure. In case of any breach, your remedy will be as per the Terms and Conditions . You acknowledge and agree that BonusPay may transfer your information as described above for purposes consistent with this policy.

INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries other than your own. We implement appropriate safeguards, including standard contractual clauses, to ensure that your data remains protected according to applicable data protection laws.

BREACH NOTIFICATION

In the unlikely event of a data breach, we are committed to notifying you as soon as possible. We will take appropriate steps to mitigate any potential harm and will comply with applicable laws regarding breach notifications.

COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to collect information about your interactions with our app and website. This information is used to personalize your experience, analyze usage patterns, and provide relevant advertisements. You can manage your cookie preferences through your browser settings.

THIRD-PARTY LINKS

Our app may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you use.

OPT-OUT OPTIONS

You have the right to opt out of certain types of data processing, including marketing communications and third-party data sharing. You can manage your preferences in your account settings or by contacting us directly.

ACCESSING AND CONTROLLING YOUR INFORMATION CHILDREN’S PRIVACY

We do not intentionally or knowingly collect or solicit information from children under the relevant age of consent under the laws of their respective jurisdictions or knowingly allow such persons to register for the services. The services are not directed at children and is only intended to be used by individuals who have attained the relevant age of consent under the laws of their respective jurisdictions.

If you believe that we might have information from or about a child under the relevant age of consent, please contact us support@bonuspay.io. We will promptly review the information and take appropriate action as required under applicable law.

CHANGES TO THIS PRIVACY POLICY

BonusPay may at any time change this Privacy Policy. BonusPay will notify users of such changes by push notice or via in-app notification or by other means. If you object to any changes, you may deactivate your account and cease using the services. Your continued use of the services after BonusPay has communicated changes to this Privacy Policy, will mean that the collection, use, sharing and processing of your personal information is subject to the new Privacy Policy. We may from time to time set out more detailed information on how we process your personal information in relation to particular services in supplemental Privacy Notices which shall be incorporated into and form part of this Privacy Policy.

CONTACT INFORMATION FOR DATA PROTECTION OFFICER (DPO)

If you have any questions or concerns about your privacy or data protection, please contact our Data Protection Officer at dataprotection@bonuspay.io or by writing to us at:

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to modify this Privacy Policy at any time. Any changes will be effective immediately upon posting, and we will notify you of significant changes through our app or other communication methods.