KliQr Technologies (“KliQr”, “we”, “us”, “our” “Company”), recognizes your privacy rights as guaranteed under the 1999 Constitution of the Federal Republic of Nigeria (as amended); the Nigerian Data Protection Regulation 2019 issued by the National Information Technology Development Agency (NITDA), and the privacy provisions in other relevant laws applicable to our business in Nigeria. Thus, it is important to us as a law-abiding and transparency driven organisation that your Personal Data is managed, processed, and protected in accordance with the provisions of the applicable laws. In the course of our business and/or your engagement with us and third parties through our Platforms (this includes but are not limited to our website (www.kliqr.com), digital platforms, mobile applications, physical operations/offices, amongst others), we may process your Personal Data, subject however to the terms of this Policy. This Policy therefore explains our privacy practices with respect to how we process your Personal Data and describes your rights as a user of any of our services and Platforms.
Accordingly, we have developed this Policy for you to understand how we collect, use, communicate, disclose, and otherwise make use of Personal Data. We have outlined our Policy below.
This Policy applies to KliQr Services and Products only. We do not exercise control over the sites displayed or linked from within our various Services. These other sites may place their own cookies, plug-ins or other files on your computer or mobile device, collect data or solicit personal information from you. KliQr does not control these third-party websites and we are not responsible for their privacy statements. Please consult such third parties’ privacy statements.
4. CHANGE AND AMENDMENT OF THE POLICY
We may change this Policy from time to time. If we make changes to this Policy, we will notify you by revising the date at the top of this Policy, and in some cases, we may provide you with additional notice (such as by adding a statement to the homepages of our website or mobile application or by sending you an email notification). We encourage you to review the Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.
For this Policy:
Data/Information means any information relating to you, including your name, identification number, location data, online identifier address, photo, email address, pins, passwords, licenses, bank details, posts on our Platforms, religion, date of birth, health, race/tribe, nationality, ethnicity, political views, trades union membership, criminal records, medical information, and other unique identifiers such as but not limited to Media Access Control (MAC) address, Internet Protocol (IP) address, International Mobile Equipment Identity (IMEI) number, Bank Verification Number (BVN), International Mobile Subscriber Identity (IMSI) number, Subscriber Identification Module (SIM) and others. It also includes factors specific to your physical, physiological, genetic, mental, economic, cultural, or social identity.
Process/Processing means any operation or set of operations which is performed on your Personal Data or sets of Personal Data, whether by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
Products/Services means the KliQr consumer application, KliQr’s Month-in-View (MiV), KliQr’s Data Value Realisation (DVR) Microservices and KliQr’s Transaction Categorisation and Month in View APIs.
We kindly request that you carefully read through this Policy and click on the ‘Agree’ icon below, if you consent to the terms of this Policy, particularly with respect to the processing of your Personal Data. That notwithstanding, if you proceed to use any of our Platforms, Products, or Services, it will be deemed that you have provided your express consent to the terms of this Policy.
You must be at least 18 years old to use our Services or any of our platforms. Individuals under the age of 18, or applicable age of maturity, may utilize our platforms Services only with involvement of a parent or legal guardian, under such person’s account. Regardless, all Data which we may process shall be in accordance with this Policy and other applicable laws.
8. PERSONAL INFORMATION WE MAY COLLECT ABOUT YOU
Depending on our platforms you are engaging with or the Services we are providing to you at a time, we may collect, use, process, store, or transfer personal information such as:
Identity Data: Information such as, your full name(s), your Government-issued identity number, bank verification number (BVN) and your date of birth. This data is to enable us to verify your identity to offer our Services to you.
Contact Data: This is the data that is needed to reach out to you, such as your contact address, email address, telephone number, details of the device you use and billing details.
Identification documents: (such as your passport or any Government-issued identity card), a photograph (if applicable) and any other registration information you may provide to prove you are eligible to use our Services.
Log/Technical information: When you access our platforms, our servers automatically record information that your browser sends whenever you visit a website, links you have clicked on, length of visit on certain pages, unique device identifier, log-in information, location, and other device details.
Financial Data: Information, such as personal account number, account balance and other information provided by financial institutions or merchants when we act on their behalf.
Transactional Data: These are information relating to account balances and payment/transaction history or any transaction and/or payments during the ordinary use of our Products or Services.
Marketing and Communications Data: This includes both a record of your decision to subscribe or to withdraw from receiving marketing materials from us or from our third parties.
Third Parties: We may also receive your information from third parties such as relatives, guardians, financial institutions, vendors, and service providers etc.
Records of your discussions with us if we contact you and if you contact us.
We may also collect, store, use and transfer non-personal information or anonymized data such as statistical or demographic data.
Social Media: We also receive Information through your engagements with us on social media sites (e.g., Facebook, Instagram, LinkedIn, Twitter, WhatsApp). This includes but are not limited to your replies to our posts, your comments, enquiries, messages to us, etc
As a principle, we do not collect any special categories of Personal Information. If we do collect special categories of Personal Information, we will ensure compliance with applicable law.
9. INFORMATION THAT WE COLLECT FROM WEBSITE VISITORS
We do not collect your Personal Information when you visit the website. However, to monitor and improve our website and Services we may collect non-personally identifiable information. We will not share or disclose this information with third parties except as a necessary part of providing our website and Services. We may use the information to target advertisements to you.
10. INFORMATION THAT WE COLLECT FROM TEST USERS
When you test our Services using the “Demo” part of our website, we collect both non- personally identifiable information and personally identifiable information. Information we collect include your IP address, information about your computer, and other standard web log information to monitor the test transactions. We also collect and store your email address.
11. HOW WE GET YOUR PERSONAL INFORMATION AND WHY WE HAVE IT
The Personal Information we have about you is directly made available to us when you:
- Sign up for a KliQr Account;
- Use any of our Services or Products;
- Contact our customer support team;
- Fill our online forms;
- Contact us;
12. THE LAWFUL BASIS WE RELY ON FOR PROCESSING YOUR PERSONAL INFORMATION ARE:
The Personal Information we have about you is directly made available to us when you:
- Your Consent: Where you agree to us collecting your Personal Information by using our Services.
- We have a Contractual obligation: Without your Personal Information, we cannot provide our Services to you.
- We have a legal obligation: To ensure we are fully compliant with all applicable financial legislations such as Anti-Money Laundering and Counter Terrorist Financing Laws and other applicable laws, we must collect and store your Personal Information. We protect against fraud by checking your identity with your Personal Information.
13. WHY WE MAY USE YOUR PERSONAL INFORMATION
We may use your Personal Information we collect to:
Create and manage any accounts you may have with us, verify your identity, provide our Services, and respond to your inquiries;
Protect against and prevent fraud, security issues, unauthorized transactions, claims and other liabilities;
Provide, administer and communicate with you about Products, Services, offers, programs and promotions of KliQr, financial institutions, merchants, and partners;
Execute our contractual obligations to you;
Measure the performance of our Services and improve their content and layout;
Manage and protect our information technology infrastructure;
Enable on-demand Services by digitizing and standardizing the reporting of Know Your Customers data;
Evaluate and improve our business, including developing new Products and Services;
To target advertisements, newsletter and Service updates;
As necessary to establish, exercise and defend legal rights;
As may be required by applicable laws and regulations, including for compliance with Know Your Customers and risk assessment, and sanctions screening requirements, or as requested by any judicial process, law enforcement or governmental agency having or claiming jurisdiction over KliQr or KliQr’s affiliates;
To use data analytics to improve our website, Products or Services, and user experiences.
For other purposes for which we provide specific notice at the time of collection.
14. DATA SECURITY AND RETENTION
The security of your Personal Information is important to us. We are committed to
protecting the information we collect. We maintain administrative, technical, and
physical controls designed to protect the Personal Information you provide, or we collect
against loss or theft, as well as against any unauthorized access, risk of loss, disclosure,
copying, misuse, or modification.
Other security measures include but not limited to, secure servers, firewall, data encryption and granting access only to employees to fulfil their job responsibilities.
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 to ensure that the confidentiality of your Personal Information is protected and maintained. Transmitting information online is not entirely secure. As such, we cannot guarantee that all information provided online is secure. We would take all reasonable steps to ensure that your Personal Information is secured and well protected.
We will only retain Personal Information on our servers for as long as is reasonably necessary if 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 Information, we do so in compliance with limitation periods under the applicable law.
15. DISCLOSING YOUR PERSONAL INFORMATION
We may disclose or share your Personal Information with third parties which include our
affiliates, employees, officers, service providers, agents, suppliers, sub-contractors as may be
reasonably necessary for the purposes set out in this Policy.
We only share personal information with external third parties in the following limited circumstances:
We have your consent. We require opt-in consent for the sharing of any sensitive personal information;
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 this Policy and any other appropriate confidentiality and security measures;
We believe in good faith that access, use, preservation or disclosure of such information is reasonably necessary to:
- satisfy any applicable law, regulation, legal process, or enforceable Governmental request;
- detect, prevent, or otherwise address fraud, security or technical issues, or
- protect against imminent harm to the rights, property, or safety of KliQr, its users or the public as required or permitted by law.
We may process your Personal Information 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.
17. 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 signing into your Account or contacting us.
Right to request that KliQr erase your Personal Information. You have the right to ask us to erase 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 are where the applicable law requires KliQr to retain a historical archive or where we retain a core set of your Personal Information 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 that 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.
Right to object to processing: You have the right to object to the processing of your Personal Information in certain circumstances. Please note that where you object to us processing your Personal Information, we might be unable to provide the Services to you.
The website of NITDA and/or the NDPR 2019 has a wealth of useful information in respect of your rights and remedies over your Personal Information. If you wish to exercise your rights, you may write to us at firstname.lastname@example.org.
The basis of us processing your Personal Information is your consent. You also have the choice at any time to withdraw consent which you have provided.
You also have a choice to deactivate your Account at any time. You may contact us should you wish to deactivate your Account at any time via the Contact Us segment below or send us an email at email@example.com.
If you wish to exercise any of the rights set above, please contact us at firstname.lastname@example.org Where we are unsure of your identity, we might ask you for proof of your identity for security reasons before dealing your request.
If you download or use our software, such as a stand-alone software product, an app, or a browser plugin, you agree that from time to time, the software may download and install upgrades, updates, and additional features from us to improve, enhance, and further develop the software.
20. PERIOD OF STORAGE
We retain your information for as long as necessary for the purpose(s) for which it was collected. The period of data storage is also subject to legal, regulatory, administrative, and operational requirements. In the minimum, Personal Information obtained through this Platform may be stored for as long as five (5) years.
21. ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS
22. CROSS BORDER TRANSFERS OF PERSONAL INFORMATION
KliQr is based in Nigeria and the information we collect is governed by the Nigerian laws. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to Nigeria and other countries which may not have the same data protection laws as Nigeria, but whenever we transfer or transmit your Personal Information internationally, we will ensure or take reasonable steps to ensure your Personal Information is handled securely in line with the applicable data protection laws and standard contractual clauses.
We will only transfer your Personal Information if one of the following conditions are met:
- If we have received your consent to do;
- If the transfer is necessary for the performance of a contract between us or if it’s necessary for the implementation of pre-contractual measures taken at your request;
- If the transfer is necessary to conclude a contract between us and a third party in your interest;
- If the transfer is necessary by reason of public interest;
- Where necessary for the establishment, exercise or defense of legal claims;
- If the transfer is necessary to protect your vital interest as a data subject or where you are physically or legally incapable of giving consent.
In providing you with the Services, we may rely on third-party servers located in foreign jurisdictions from time to time, which as a result, may require the transfer or maintenance of your personally identifiable information on computers or servers in foreign jurisdictions. We will endeavour to ensure that such foreign jurisdictions have data protection legislation that is no less than the existing data protection regulations in force in Nigeria and your personally identifiable information is treated in a safe and secure manner.
If you violate the letter or spirit of this Policy, or otherwise create risk or possible legal exposure for us or attempt to violate the privacy rights of KliQr and its other users, we reserve the right to restrict your access to our Platforms. We will notify you if we are constrained to take such decision.
24. DISPUTE RESOLUTION
We are dedicated to ensuring that you are satisfied with our management of your Information. However, in the unlikely event that you have a complaint, please contact us via the details below, stating your name and details of your complaint. Upon receipt of your complaint, we will endeavor to contact you within 10 working days with a view to amicably resolving such dispute within the shortest possible time. The foregoing notwithstanding, all disputes arising from this policy shall first be resolved by negotiation. However, if parties fail to resolve the disputes amicably by such mutual consultations, parties shall further attempt to resolve the dispute by mediation. And when these methods fail, parties have the right to seek out other means of dispute resolution.
25. CONTACT US
If you have questions or concerns regarding this Privacy Statement, our security practices, or our information processing practices please contact us:
Phone: +234 8106 397 244