Consent

When you use Foxpay (via any of our digital platforms) and sign-up on any of our platforms or visit any of our offices for official or non-official purposes, you accept the terms described within this privacy policy.

What Personal Data do we collect?

We collect Personal Data about you when you use the services offered on our website and digital platform, including the following:

  • Sign-up information: When you register to use the services offered on our digital platform, we will collect Personal Data that is necessary to onboard you such as your full name, email address, and mobile phone number. We may require you to provide additional personal details as you use our services, participate in our social media promotions or surveys, and when you contact us to report a problem.
  • Transaction data: When you use our digital platform to send and receive money, make purchases from merchants, and pay bills, we collect information about the transaction, as well as other information associated with the transaction such as the amount sent or received, the amount paid for products or services, merchant information, including information about your device and geolocation.
  • Participant Personal Data: When you use our services, we collect Personal Data about the other participants associated with the transaction. We collect Personal Data such as name and financial account information about the participant who is receiving money from you or sending money to you.
  • Data from other sources: When you contact us to report a complaint about our services, we may collect information from other sources, such as our social media platforms However, we will only ask for information required to help us be of service to you.
  • Other information via support: We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.

Note: We do not collect the information of minors

If you are under the age of 18, you are not eligible to use the service offered on our digital platform.

How Long Do We Keep Personal Data?

We keep Personal Data for at least seven (7) days for our business purposes and to fulfill our legal or regulatory obligations. We may keep these Personal Data for longer periods if it is in our legitimate business interests and required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Policy.

What do we do with your Personal Data?

We collect your personal data to provide you with an efficient and secure customer experience. This information are processed to:

  • Technical:
    • Authenticate your access to an account.
    • Communicate with you about your account.
    • Manage risk, fraud, and abuse of our services and protect you from fraud by verifying your identity.
    • Comply with our obligations and enforce the terms of our services, including complying with all applicable laws and regulations.
    • Trail information breaches and remediate such identified breaches.
    • Resolve disputes and troubleshoot problems.
  • Marketing and Communications:
    • Market FoxPay products and services to you.
    • Use cookies to provide a targeted display, feature, service, or offers to you.

We will not send unsolicited marketing communications to you by SMS or email if you have not opted in to receive them.
Additionally, you can withdraw your consent at any time free of charge.

Sharing your Personal Data

We may share your Personal Data or other information about you with others for the following reasons:

  • Partners and Affiliates:
    • We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with services, verify your identity, assist in processing transactions, send you advertisements for our products and services, or provide customer support.
    • We may share Personal Data with other financial institutions that we have partnered with to only offer FoxPay-related services unless you have given consent for other uses. We may also share Personal Data to process transactions and keep your financial information up to date.
    • With other parties to transactions when you use the services, such as other users and their service providers. This includes other users you are sending or receiving funds from and their service providers. The information might include:
      • Personal Data and account information necessary to facilitate the transaction.
      • Personal Data to help the other participant(s) resolve disputes, detect and prevent fraud.
  • Professional Advisers and Compliance:
    • We may share information about you with other parties for Foxpay’s business purposes or as permitted or required by law, including:
      • To law enforcement authorities or other government officials, or other third parties pursuant to a court order or other legal process or requirement applicable to FoxPay or Foxpay’s corporate family.
      • If we need to do so to comply with a law, legal process, or regulations.
      • If we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.
      • To protect the vital interests of a person.
      • With credit agencies and data processors for credit reference checks and anti-fraud and compliance purposes.
      • To investigate violations of or enforce a user agreement or other legal terms applicable to any service.
      • To protect our property, services, and legal rights.
      • To facilitate a purchase or sale of all or part of Foxpay’s business.
      • To companies that we plan to merge with or be acquired by.
      • To support our audit, compliance, and corporate governance functions.
    • With your consent: We also will share your Personal Data and other information with your consent or direction.

How We Use Cookies

Cookies are small files placed on your device’s browser that enables the website to identify your device as you view different pages. Like most interactive websites, our website uses cookies to enable the tracking of your activity for the duration of a session. Our website uses only encrypted session cookies which are erased either after a predefined timeout period or once the user logs out of the platform and closes the browser. Session cookies do not collect information from your device. They will typically store data in the form of a session identification that does not personally identify you. Certain aspects of our website are only available through the use of cookies, so your use of our website may be limited or not possible if you choose to disable or decline cookies.

What Are Your Rights?

Requests to Access, Rectify or Erase.

  • Access Request:
    • This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Rectification Request:
    • This enables you to have any incorrect or incomplete information about you corrected.
  • Erasure Request:
    • This enables you to ask us to delete or remove Personal Data where there is no legal reason for us continuing to process it or if you object to us processing it if:
      • Your Personal Data have been unlawfully processed.
      • Your Personal Data are no longer necessary for the purpose(s) they were collected for.
      • Your Personal Data must be erased to comply with a regulation.
      • You withdraw your consent for the processing of the Personal Data (and if this is the only basis on which we are processing your Personal Data).
      • You object to processing that is based on our legitimate interests, provided there are no overriding legitimate grounds for continued processing, or
      • You object to processing for direct marketing purposes.
    • If we have made the Personal Data concerned public, we will also take reasonable steps to inform other data controllers processing the data so they can seek to erase links to or copies of your Personal Data. We may refuse to act on your request to erase your Personal Data if the processing of your Personal Data is necessary:
      • To exercise our right of freedom of expression and information.
      • To comply with the Nigeria Data Protection Regulation (NDPR) and relevant Nigerian laws.
      • For the performance of a task carried out in the public interest or to exercise official authority vested in us.
      • To establish, exercise, or defend legal claims.

In these cases, we can restrict the processing instead of erasing your Personal Data if requested to do so by you.

Requests to Object:

You have the right to object at any time to the processing of your Personal Data if we process it based on our legitimate interests. This includes any so-called “profiling”. Our privacy notice informs you when we rely on legitimate interests to process your Personal Data. In these cases, we will stop processing your Personal Data unless we can demonstrate compelling legitimate reasons for continuing the processing. We may reject your request if the processing of your Personal Data is needed to establish, exercise, or defend legal claims. You have the right to object at any time if we process your Personal Data for direct marketing purposes. You may also object at any time to profiling supporting our direct marketing. In such cases, we will stop processing your Personal Data when we receive your objection.

Requests to Restrict:

You have the right to ask us to restrict the processing of your Personal Data if:

  • You contest the accuracy of your Personal Data and we are in the process of verifying the Personal Data we hold.
  • The processing is unlawful and you do not want us to erase your Personal Data.
  • We no longer need your Personal Data for the original purpose(s) of processing, but you need them to establish, exercise, or defend legal claims and you do not want us to delete the Personal Data as a result, or
  • You have objected to processing carried out because of our legitimate interests while we verify if our legitimate grounds override yours.

If processing is restricted, we may process your Personal Data (excepting for storage purposes), only:

  • If you have given us your consent.
  • For establishing, exercising or defending legal claims.
  • For protecting the rights of another natural or legal person, or
  • For reasons of important public interest as defined under the NDPR and relevant Nigerian laws.

Once processing is restricted following your request, we will inform you before we lift the restriction.

Requests for Portability:

If our processing is performed by computer and is necessary to fulfill a contract with you, or is based on your consent, you have the right to:

  • Receive any Personal Data you have provided to us in a structured, commonly used, and machine-readable electronic format.
  • Send your Personal Data to another organization or have us do so for you if it is technically feasible for us to do so.

If your request relates to a set of Personal Data that also concerns other individuals, the fact that you request that we port this data as described above does not preclude those individuals from exercising their own rights regarding their Personal Data.

Even if you request the portability of your Personal Data, you retain your right to also request their erasure.

Requests to Object to Automated Decisions:

Generally, you have the right to object to any decision producing a legal effect concerning you or which otherwise significantly affects you if this is based solely on the automated processing of your Personal Data. This includes automated decisions based on profiling.

We may refuse your request if the decision in question is:

  • Necessary to enter into a contract with you, or for the performance of your contract with us.
  • Permitted by regulations, or
  • Based on your explicit consent.

We will only make decisions relying solely on automated processing that involve your sensitive Personal Data if you have given your explicit consent or the processing is necessary for reasons of substantial public interest, based on the NDPR and relevant laws.

How to exercise your personal rights?

If you wish to exercise any of the rights above, please contact us using the details in contact us.

You will not have to pay a fee to access your personal data (or to exercise any right), however, we may charge a reasonable fee for consent withdrawal if your request is clearly unfounded, repetitive, or excessive. In the event of these circumstances, we may refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights).

This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

How Do We Protect Your Personal Data?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our premises, CCTV cameras for public safety and quality control as well as information access authorization controls.

While we are dedicated to securing our systems and services, you are responsible for securing and maintaining the privacy of your password(s) and account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.

We have a duty to self-report personal data breaches to the National Information Technology Development Agency (NITDA) within 72 hours of knowledge of such breach. We will inform you of any breaches which may affect your Personal Data.

Remedies for Violation and Time-frame for Remedy

In the event of a violation of this policy, our Data Protection Officer shall within 7 days redress the violation. Where the violation pertains to the disclosure of your Personal Data without your consent, such information shall be retracted immediately, and confirmation of the retraction sent to you within 48 hours of the redress.

Governing Law

This Privacy Policy is made according to the Nigeria Data Protection Regulation (2019) or any other relevant Nigerian laws, regulations, or international conventions applicable to Nigeria.

Changes to our Privacy Policy

This privacy policy is reviewed periodically and when there is any substantial change to business or regulatory requirements. At the minimum, we shall review this annually and communicate via our communication channels such as our Website, Social Media Accounts etc.

Contact Us

If you have any general questions or concerns about this Privacy Policy or the way in which we handle your Personal Data, kindly contact us via the details below:

FOXPAY TRUST INTEGRATED LIMITED

Office: 20C Akin Ogunlewe Rd. Victoria Island, Lagos, Nigeria.
Email: info@foxpay.ng

Declaration

I have read all the terms and conditions within this Notice and hereby agree/ disagree to the use of my personal data for the above-mentioned purposes.

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