Privacy Policy

PAYCENTRE LTD DATA PRIVACY AND PROTECTION POLICY

Personal Data

According to the Nigeria Data Protection Regulation (NDPR) framework, personal data is defined as: “Any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who 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”.

We Value Your Privacy

At E-Settlement Nigeria Ltd. (hereinafter called “ESL” or E-Settlement), we treat your personal information as private and confidential. We are dedicated to protecting your privacy and providing you with the highest level of security at any point of interaction with us. This Privacy Policy describes what personal data of yours we collect, the reason for which we collect it, what we do with your data, parties whom we may share your data with and how we seek to protect your data.

This policy (together with our Terms and Conditions) sets out the basis on which any personal data we collect from you, or that you provide to us, will be used by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By continuing to visit our website (www.e-settlementgroup.com) and other ESL customer touchpoints, you accept and consent to the practices described in this policy.

We also act in accordance with laws applicable to financial institutions in Nigeria as well as the Central Bank of Nigeria’s Regulations on Agency Banking and other partners that may act as data controllers in certain circumstances such as processing payment transactions.

Who Is Responsible for Your Personal Information?

E-Settlement LTD is your data controller and is responsible for processing your personal information described in this Privacy Policy. ESL uses the personally identifiable information you provide to communicate with you in response to your enquiries, to provide the services you request, and to manage your account. Any personally identifiable information gathered by ESL will be used for these purposes only. We will not disclose or divulge such data outside of ESL, other than to third party or providers that assist us in providing the services. ESL does not share, sell, rent or trade personally identifiable information with third parties for their promotional purposes.

How will E-Settlement LTD use the personal data it collects about me?

E-Settlement LTD will process (collect, store and use) the information you provide in a manner compatible with the Nigeria Data Protection Regulation (NDPR). We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services. We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary, but we depend on you to update or correct their personal information whenever necessary. We may be required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed

practices. Personal data may be held in addition to these periods depending on individual business needs. The collection and use of personal data by E-Settlement LTD is guided by certain principles. These principles state that personal data should:

• Be processed fairly, lawfully and in a transparent manner.

• Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with such purposes.

• Be adequate, relevant and limited to what is necessary to fulfil the purpose of processing.

• Be accurate and where necessary, up-to-date. In the event data is inaccurate, steps should be taken to rectify or erase such data.

• not be kept for longer than necessary for the purpose of processing.

• be processed in accordance with the data subject’s rights.

• be kept safe from unauthorized processing, and accidental loss, damage or destruction using adequate technical and organizational measures.

Any personal information provided by you to E-Settlement LTD will be used with your consent, or under the following underlisted instances:

i. Situations where processing of personal data is required for the fulfilment of a contractual obligation.

ii. Situations where processing of personal data is required for compliance with legal and/or regulatory requirements.

iii. Situations where processing is required to protect your vital interest or that of any other natural person.

iv. Situations where processing is required for an activity to be carried in significant public interest.

v. Situations where processing is required for legitimate interests of E-Settlement LTD or a third party given that it does not conflict with the requirements for the protection of your personal data.

Your personal information is used in:

• Updating and enhancing the records of E-Settlement LTD

• Executing your instructions.

• Establishing your identity and assessing applications for our products and services

• Pricing and designing our products and services

• Administering our products and services

• Managing our relationship with you

• Managing our risks

• Identifying and investigating illegal activity (i.e.), such as fraud

• Contacting you, for example in instances where we suspect fraud on your account or when there is need to tell you about recent occurrences or some event(s) of significance.

• Conducting and improving our businesses and improving your experience with us

• Preventing money laundering or terrorism financing activities.

• Complying with our legal obligations and assisting government and law enforcement agencies or regulators/supervisors

• Identifying and informing you about other products or services that we think may be of interest to you.

• Processing your job application if you apply for a job with us.

We may also collect, use and exchange your information in other ways permitted by law.

Will E-Settlement LTD share my personal data with anyone else?

ESL only shares personal information with other companies or individuals in the following limited circumstances:

1. We have your consent. We require consent for the sharing of any sensitive personal information

2. We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with the General Data Protection Regulation and the Nigeria Data Protection Regulation and any other appropriate confidentiality and security measures. When they no longer need your data to fulfil this service, they will dispose of the details in line with ESL procedures.

3. We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of E-Settlement LTD, its users or the public as required or permitted by law.

Information We Share

We may share the information about you and your dealings with us, to the extent permitted by law, with the following:

• E-Settlement Branch offices and Subsidiaries

• Regulators/Supervisors, Government Agencies/courts - It may be necessary by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence for us to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.;

• External Auditors;

• Our authorized members of staff;

• Credit Agencies;

• Correspondent banks;

• E-Settlement’s strategic partners/service providers – for the purpose of improving and providing our products and services to you. Your Personal information will not be shared with third parties for their marketing purposes.

We may also disclose information about you provided that such disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

Information about our customers and their usage of our website is not shared with third parties for their marketing purposes. We do not disclose any information about any user’s usage of our web site except in specific cases, and we do not share information with any unaffiliated third parties for marketing purposes unless you expressly give us permission to do so.

Information We Collect and Use

We collect information about you from a variety of sources, such as: website visits, applications, identification documents, curriculum vitae, transaction records/logs, interactions with relationship managers, and other third parties (Billers, payment gateways, other financial institutions…) and other written or electronic communication reflecting information such as your name, address, passport details, identification numbers, biometric information, telephone number, occupation, assets, income and any other information we deem necessary.

We may use your transactional account history including your agency banking account balance, payment records, and application usage. We may also use information received from third parties such as family, solicitors, friends or employers, website/ social media pages made public by you, government agencies, regulators, supervisory or credit agencies.

We may also collect other information such as video footages of you whenever you step into any of our offices, telephone conversations when you call any of our contact center lines, geographic information of any of our agent locations when you use our POS devices.

Non- Personal Information Collected by us

In order to achieve our goal of providing you with the best service, we sometimes collect certain information during your visits to perform certain tasks such as grant you access to some parts of our web site or conduct research on your behavior on our site in order to improve our services. We will not disclose your information to any person outside our organization except as described in this Privacy Policy.

Cookies are small text files stored on your computer or mobile devices. Cookies have many uses, such as memorizing your preferences to tailor your experiences while on a website. It analyzes website traffic. ESL uses cookies to improve your experience on our website. We would like to let you know a few things about our cookies:

• Some cookies are essential to access certain areas of this site;

• We use analytics cookies to help us understand how you use our site in order to know what content is most useful to you.

Kindly refer to our cookie policy for more information on cookies.

Log information

When you access E-Settlement services, our servers automatically record information that your browser sends whenever you visit a website.

User communications

When you send email or other communications to us, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.

Automated Processing

We sometimes use automated systems and software to help us reach decisions about you, for example, to carry out security, fraud and money laundering checks, or to process your data when you apply for some of our products and services.

This type of processing is carried out under lawful basis and you can contact us to request that automated processing be reviewed by a human being if you detect any inaccuracies in your personal data.

Third-Party Sites and Services

Our products and services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details is governed by their privacy practices and E-Settlement LTD will not be liable for any breach of confidentiality or privacy of your information on such sites. We encourage you to learn about the privacy practices of those third parties.

Promotional Messages

E-Settlement LTD may sometimes contact you with products or services that we think may be of interest to you. If you don’t want to receive such promotional materials from us, you can opt out at any time by sending an email to contact@esettlementgroup.comesettlementgroup.com

Social Media Platforms

E-Settlement may interact with registered users of various social media platforms, including Facebook, Twitter, Google+, LinkedIn and Instagram. Please note that any content you post to such social media platforms (e.g., pictures, information or opinions), as well as any personal information that you otherwise make available to users (e.g., your profile) is subject to the applicable social media platform’s terms of use and privacy policies. We recommend that you review this information carefully in order to better understand your rights and obligations with regard to such content.

Maintaining Accurate Information

Keeping your account information accurate and up to date is very important. You have access to your account information, which includes your contact information, account balances, transactions and similar information through various means, such as account statements, SMS alerts, Social Media Banking and Internet Banking.

If you discover any inaccuracies in your personal information, please promptly notify us, via our branch offices or Contact Centre, and provide the required documentary evidence, to enable us to implement the necessary updates or changes.

How We Protect Your Information

We take appropriate technical and organizational measures to prevent loss, unauthorized access, misuse, modification or disclosure of information under our control. This may include the use of encryption, access controls and other forms of security to ensure that your data is protected. We require all parties including our staff and third-parties processing data on our behalf to comply with relevant policies and guidelines to ensure confidentiality and that information is protected in use, when stored and during transmission. Our security controls and processes are also regularly updated to meet and exceed industry standards.

Where we have provided you (or where you have chosen) a password which grants you access to specific areas on our site, you are responsible for keeping this password confidential. We request that you do not to share your password or other authentication details (e.g., token generated codes) with anyone.

Where We Store Your Information

All Personal Information you provide to us is stored on our secure servers as well as secure physical locations and cloud infrastructure (where applicable). The data that we collect from you may be transferred to and stored at a destination outside Nigeria. Whenever your information is transferred to another location, we will take all necessary steps to ensure that your data is handled securely and in accordance with this privacy policy.

How Long We Store Your Information

We retain your data for as long as is necessary for the purpose(s) that it was collected. Storage of your data is also determined by legal, regulatory, administrative or operational requirements. We only retain information that allows us comply with legal and regulatory requests for certain data, meet business and audit requirements, respond to complaints and queries, or address disputes or claims that may arise.

Data which is not retained is securely destroyed when it is identified that is no longer needed for the purposes for which it was collected.

Your Rights

You have certain rights available to you, these include

• The right to access your personal information held by us. Your right of access can be exercised by sending an email to contact@esettlementgroup.comesettlementgroup.com

• The right to rectify inaccurate or incomplete information.

• withdraw consent for processing in cases where consent has previously been given.

• restrict or object to processing of your personal data. We might continue to process your data if there are valid legal or operational reasons

You also have the right to:

• Request that your personal data be made available to you in a common electronic format and/or request that such data be sent to a third party.

• Request that your information be erased. Please note that we might continue to retain such data if there are valid legal, regulatory or operational reasons.

• In accordance with the NDPR policy, you may decline, withdraw or limit any information you provide to us, in which case we may not be able to provide all of our services to you. If you do not agree with our Privacy Notice and Data Protection Policy (“the policy”) you may discontinue the use of our solution and services. Your continued use of our services signifies your consent to and acceptance of this Policy. This Policy becomes effective subject to the notice of the amendment you received from us whether or not you studied it.

Under what circumstances will E-Settlement LTD contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions.

Moreover, the information you provide will be subject to rigorous measures and procedures to minimize

the risk of unauthorized access or disclosure.

Privacy of Children

E-Settlement’s Policy contains the following disclosure statement for children:

"E-Settlement Group respects the privacy of children. We do not knowingly collect names, email

addresses or any other personally identifiable information from children. We do not knowingly market

to children nor do we allow children under 18 to open online accounts."

Applicability of this Policy

E-Settlement group refers to E-Settlement Nigeria LTD and its subsidiaries.

E-Settlement LTD subsidiaries include the following:

• PayCentreAfrica

• CashEnvoy

• PayPad

Policy Changes

This policy may be revised on an ad-hoc basis to reflect the legal, regulatory and operating environment

and such revised versions will automatically become applicable to you. We will post any revisions we

make to our Privacy and protection Policy on this page and such revised policy becomes effective as at

the time it is posted. We also encourage you to check this page from time to time for updates to this

policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed

to dpo@esettlementgroup.com

To contact our Data Protection Officer, kindly address your request to “The Data Protection Officer” at

13, Hughes Avenue, Alagomeji, Yaba, Lagos, Nigeria or call us on +234-1-700-6213.

This privacy policy was last updated on 8th April, 2021