Introduction

This Privacy Policy (this “Policy”) describes how and when Alerzo Limited (together with our successors, affiliates and assignees, “Alerzo”, “we” “us” or “our”) may collect, use, secure and share information collected in connection with our mobile application, websites, contents, products and any related services (collectively referred to as “the Services”), and your choices regarding that information. “You” and “your” mean the person who uses or accesses the Services. This Policy applies when you access our Services via our website, or our mobile application (collectively, the Website or the “Platform”). Please read this Policy carefully, as we may update it from time to time by posting a new version on the Website with an updated date. Your continued use of our Services after the effective date will be an acknowledgement of our updated Policy.

1. Collection of Personal Data

We may collect various types of data, including data you provide or make available to us directly, information collected from your devices (including web and mobile). Some of this data may be considered “personal information” or “personal data under the applicable privacy or data protection laws.

Information You Provide

You may provide information directly to us when you:

  • Use or access the Services, including when you create an account. You provide us with the varied personal information, such as: Phone Number, Home Address, First Name, Surname, Gender, Date of Birth, Email Address, Picture, Bank Account Details, Bank Verification Number (BVN).

  • Communicate with us or contact us for customer or technical support. When 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:

    a) Phone Number you’re calling from and information you give us during the call.

    b) Email Address you use and the contents of your email (and any attachments).

    c) Public details from your social media profile (like Instagram or Twitter), if you reach out to us via these platforms and the contents of your messages or posts to us.

  • Participate in Alerzo offers, contests or special events;

  • Subscribe to newsletters or signup to hear about current or upcoming products; and/or

  • Complete surveys offered by us or on our behalf.

Information Collected Using Cookies and Similar Technologies

We and our partners may use cookies, beacons, software development kits, mobile analytics software, and/or similar technologies for several purposes, including to authenticate users, prevent fraud, preferences

and settings, analyze advertising and messaging campaigns, analyze traffic and trends, personalize content (including ads), and otherwise provide the Services. These technologies may collect information about your use of our Services, mobile network, IP address, operating system, Device ID, pages you view, links you tap and other actions taken in connection with our Services.

Depending on the choices and settings available on the browser(s) you use, you may be able to disable cookies in your browser settings, but this could affect the availability and functionality of our Services.

    Google Analytics

    On our Website, we also may utilize Google Analytics, a web analysis provided by Google, to better understand your use of our Services. Google Analytics collects information such as, how often users visit the Websites, what pages they visit and what other sites they used prior to visiting. Google uses the data collected to track and examine the use of the Websites, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the Website to contextualize and personalize the ads of its own advertising network. Google’s ability to use and share information collected by Google Analytics about your visits to the Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

    Google offers an opt-out mechanism for the web, available here.

        2. How We May Use Your Personal Information

        We collect and use your personal information for a number of business and commercial purposes, including to:

        • Fulfil your requests for our Services on the Website;
        • Understand your needs, and communicate to you regarding all upgrades or changes to our products and services, and improving the products and services on our Platform;
        • We may collect and use your personal information to respond to legitimate claims or address any reasonable belief that you have violated the rights of any third party or any of the terms or policies that govern your use of the Website or any of the Alerzo products and services;
        • Understand how you interact with our Service and personalize the product experience and content (including advertising and messaging campaigns)
        • Administer contests, surveys and notify contest winners and award prizes;
        • Investigate or address claims or disputes relating to your use of the Service
        • Maintain the safety, security and integrity of our Services, for example authenticating users and providing account security and fraud detection
        • target advertisements, newsletter and service updates to you
        • As necessary to establish, exercise and defend legal rights
        • To use data analytics to improve our Website, products or services, and user experiences.
        • Perform internal operations necessary to develop, provide, maintain and improve our Services, including troubleshooting, providing customer and technical support, and conducting data analysis, testing and research
        • Comply with all applicable laws, regulations and government requests, including Customer Due Diligence, Anti-Money Laundering and Anti-Terrorism Financing requirements, Know Your Customer principles and other relevant legal/regulatory requirements

        3. Why We Collect Your Information

        We understand that the Nigerian Data Protection Act 2023 provides that we need to have a lawful basis for processing your personal information. At least one of the following must apply: contractual or legal duty, legitimate interest, public interest, vital individual interest or consent.

          Your Consent:We require your consent to market and communicate our products and services. However, you can always unsubscribe from receiving our marketing content.

            Contractual Obligation:We collect certain information from you to fulfil the contract we have with you, or to enter into a contract with you. We use this data to:

            • Give you the services we agreed to in line with our terms and conditions.
            • Send you messages about your account and other services you use if you get in touch, or we need to tell you about something.
            • Exercise our rights under the contracts we’ve entered into with you and resolve complaints and other issues.

            Legal Obligation:It’s our legal duty to ensure that we are fully compliant with all applicable laws and regulations, including financial legislations such as: Anti-Money Laundering and Counter Terrorist Financing Laws. Further to our legal duty, we must collect and store certain personal information from you. Also, to protect against fraud we check your identity with your personal information.

              Legitimate Interest:Processing may be done further to the legitimate interest of Alerzo, such as in safeguarding our assets, however, this will not be processed contrary to your rights and freedoms.

                4. Data Security

                The Security of your personal data is important to Alerzo. We are committed to protecting the information we collect. We maintain administrative, technical and physical controls designed to protect the personal data you provide, and we protect against loss or theft, as well as against any unauthorized access, risk of loss, disclosure, copying, misuse or modification.

                Our other security measures include but are not limited to, secure servers, firewall, data encryption and granting access only to employees in order to fulfil their job responsibilities.

                Our Website uses Secure Sockets Layer/Transport Layer Security (SSL/TLS) to ensure secure transmission of your personal data. You should see the padlock symbol in your URL address bar once you access our Website. The URL address also starts with https:// depicting a secure webpage.

                Where you use a password for any of your accounts, please ensure you do not share this with anyone, and the password is always kept confidential.

                We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of your personal data is protected and maintained. While transmitting information comes with certain risks, we would take all reasonable steps to ensure that your personal data is secured and well protected.

                Alerzo has put in place procedures to deal with suspected personal data breaches. We will also notify you and the relevant regulator of a breach, where we are required to do so. If you believe that your privacy has been breached or compromised, please contact us via email: dpo@alerzo.com.

                  5. Disclosure, Processing & Retention

                  Alerzo will not disclose any of your personal information to anyone else, except:

                  a. To its employees, independent contractors, subsidiaries, affiliates, consultants, business associates, service providers, suppliers and agents, acting on its behalf for any of the identified purposes;

                  b. It has reason to believe that disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with Alerzo’s rights or property, other users of our Services, Website, other Alerzo products or services, or anyone else that could be harmed by such activities;

                  c. In the event of business transfers which may occur when we sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets; and

                  d. To respond to judicial processes and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law.

                  We will only retain personal data on our servers for as long as is reasonably necessary, in so far as we are providing Services to you. Where you close your account, your information is stored on our servers to the extent necessary to comply with regulatory obligations and for the purpose of fraud monitoring, detection and prevention. Where we retain your personal data, we do so in compliance with limitation periods under the applicable law.

                    6. Marketing

                    We may process your Personal Data in order to contact you or send you marketing content and communication about our products, services or surveys. You may exercise your right to object to such contact from us or opt out from the marketing content. Please note however that if you opt-out of marketing content, we may still send you messages relating to transactions and our Services related to our ongoing business relationship.

                    We may ask you for permission to send notifications to you. Our Services will still work if you do not grant us consent to send you notifications.

                      7. Accuracy of Personal Information

                      We will use commercially reasonable efforts to maintain the accuracy of your personal information. You may also update us of any changes to your personal information from time to time by contacting us.

                      We may verify personal information provided by you with the help of trusted third parties. We may also request you to provide copies of documents related to your personal information for the purpose of verifying your personal information.

                      It is important that the personal data Alerzo holds about you is accurate and current. Please keep us informed of any changes to your personal data during the course of your relationship with us.

                        8. Your Data Protection Rights and Choices

                        Based on your location and applicable laws, below are the rights you have as a user in relation to your Personal Information:

                        • Right to be informed
                        • Right to request access or copies to your personal information by contacting us
                        • Right to request that Alerzo delete your personal information. You have the right to ask us to delete your personal information. Please note that this is a limited right which applies where the data is no longer required, or the processing has no legal justification. The exceptions to this right is where the applicable law requires Alerzo to retain a historical archive or where we retain a core set of your personal data to ensure we do not inadvertently contact you in future where you object to your data being used for marketing purposes
                        • Right to correct or rectify any personal information that you provide which may be incorrect, out of date or inaccurate. You also have the right to ask us to complete information you think is incomplete.
                        • Right to object to the processing of your personal information for marketing purposes. You have a right to ask us not to contact you for marketing purposes by adjusting your notification preference on the settings page or by opting out via the unsubscribe link in marketing emails we send you. Please note that where you object to us processing your personal information, we might be unable to provide the Services to you.

                        In addition to the rights described above, if we have collected and processed your personal data with your consent, you may withdraw that consent in the manner described when you provided consent.

                        If you wish to exercise any of the rights set above, please contact us using the contact information provided in the Contact Us segment below. Where we are unsure of your identity, we might ask you for proof of your identity for security reasons before dealing with your request.

                        9. Minor

                        We do not knowingly collect or process personal data from anyone under the age of 18, nor do we knowingly allow such individuals to use our Services. If you believe we might have any personal information from or about a child under this age. Please contact us using the details provided on the last page. If we learn that we have inadvertently gathered such information, we will delete it.

                          10. Notification Of A Personal Data Breach

                          In the event that a personal data breach has occurred impacting your Personal Data held with Alerzo that is likely to result in a high risk to your rights and freedoms, we shall immediately notify you of the breach in plain and clear language. We shall also notify the Data Protection Authority of such personal data breach within 72 (seventy-two) hours of becoming aware of the breach.

                            11. Updates To Our Privacy Policy

                            This Policy will be reviewed, when necessary, but at least annually. If we make any material changes, we’ll add a note to this page.

                              12. Contact Us

                              If you have questions or concerns about this Policy or how we process your personal data, you can contact our Data Protection Officer by:

                              • Sending a message via the app
                              • Emailing us at dpo@alerzo.com
                              • Writing to us at 39 Adeola Odeku, Victoria Island or Alerzo Place, Ring-Road

                              Last updated on the 5th March 2024.