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    SLIMEPAY LIMITED PRIVACY POLICY

    Last updated: 14th November 2024

  1. PURPOSE OF THIS PRIVACY POLICY

    1. Slimepay Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website, platform (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
    2. This privacy policy aims to give you information on how Slimepay collects and processes your personal data through your use of our website, platform, including any data you may provide through our website, platform when you use our services.
    3. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
  2. PRIVACY OF CHILDREN

    1. We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Services. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Services, please contact us to request that we delete that child's Personal Information from our Services.
    2. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Services without their permission. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission.
  3. CONTACT DETAILS

    1. If you have any questions about this privacy policy or our privacy practices, please contact us through our email: Slimepayfinancelimited@gmail.com
  4. CHANGES TO THE PRIVACY POLICY

    1. We keep our privacy policy under regular review. This version was last updated on 14 November 2024. Historic versions can be obtained by contacting us.
    2. Subject to applicable law, we may change, amend or review this Privacy Policy at any time to reflect new services or changes in our Policy. All changes made will be posted on this page and where changes will materially affect you, we will notify you of this change by placing a notice online or via mail. If you keep using our Services, you consent to all amendments of this Privacy Policy.
    3. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
  5. THIRD-PARTY LINKS

    1. Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
  6. THE DATA WE COLLECT ABOUT YOU

    Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

    We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

    • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, identity documents, address. When we conduct anti-money laundering and fraud monitoring, prevention and detection activities, we may also receive identity data about you from our business partners, financial service providers, identity verification services, and publicly available sources as necessary to confirm client's identity and prevent fraud.

    • Contact Data includes email address, phone numbers, etc.

    • Financial Data includes bank account, financial statements, history of operations, account statements, messages and documents sent or received with the payment.

    • Transaction Data includes details about payments to and from you and other details of products and services you have purchased, transactions that you have submitted and received, their date, time, amount, currencies used, exchange rate, beneficiary details, details and location of the merchant, device information used to facilitate the payment and the payment instrument used.

    • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website, platform.

    • Profile Data includes transactions made by you, your interests, preferences, feedback and survey responses.

    • Usage Data includes information about how you use our website, platform, products and services.

    • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

    We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website, platform or app feature.

    However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

    We do not purposely collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). However, we may obtain such data by complementary means whenever you supply us with the documents that are required for your identification.

  7. IF YOU FAIL TO PROVIDE PERSONAL DATA

    1. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services or our products). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
  8. HOW IS YOUR PERSONAL DATA COLLECTED?

    We use different methods to collect data from and about you including through:

    • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

      • apply for our products or services;
      • create an account on our website;
      • subscribe to our service or publications;
      • request marketing to be sent to you;
      • enter a competition, promotion or survey; or
      • give us feedback or contact us.
    • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

    • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

      • Technical Data from analytics providers and search information providers.
      • Contact, Financial and Transaction Data from providers of technical, payment and delivery data.
      • Identity and Contact Data from publicly available sources such as fraud prevention agencies, and also Identity verification providers.
  9. HOW WE USE YOUR PERSONAL DATA

    1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
      • Where we need to perform the contract, we are about to enter into or have entered into with you.
      • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
      • Where we need to comply with a legal obligation, such as prevention of money laundering and terrorist financing.
    2. More particularly, the above bases can be outlined as follows:
      • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
      • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
      • Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
    3. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
  10. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

    We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
    To register you as a new customer(a) Identity
    (b) Contact
    (c) Financial
    (a) Performance of a contract with you
    (b) Necessary to comply with a legal obligation
    To respond to your inquiries and fulfil your requests, such as to respond to your questions and comments(a) Identity
    (b) Contact
    (c) Financial
    (d) Transaction
    (a) Performance of a contract with you
    (b) Necessary to comply with a legal obligation
    (c) Necessary for our legitimate interests (to provide good customer service)
    To process and perform your operations including:
    (a) Manage payments, fees and charges
    (b) Execute transactions
    (c) Collect and recover money owed to us
    (a) Identity
    (b) Contact
    (c) Financial
    (d) Transaction
    (e) Marketing and Communications
    (a) Performance of a contract with you
    (b) Necessary for our legitimate interests (to recover debts due to us)
    To manage our relationship with you which will include:
    (a) Notifying you about changes to our terms or privacy policy
    (b) To resolve conflicts, manage litigation, resolve issues, and provide you customer service
    (c) Asking you to leave a review or take a survey
    (a) Identity
    (b) Contact
    (c) Profile
    (d) Marketing and Communications
    (a) Performance of a contract with you
    (b) Necessary to comply with a legal obligation
    (c) Necessary for our legitimate interests (to provide good customer service; to keep our records updated and to study how customers use our products/services)
    To enable you to partake in a prize draw, competition or complete a survey(a) Identity
    (b) Contact
    (c) Profile
    (d) Usage
    (e) Marketing and Communications
    (a) Performance of a contract with you
    (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
    To administer and protect our business and our website, platform and app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity
    (b) Contact
    (c) Technical
    (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
    (b) Necessary to comply with a legal obligation
    To deliver relevant website, platform and app content and advertisements to you and measure or understand the effectiveness of the services we provide to you(a) Identity
    (b) Contact
    (c) Profile
    (d) Usage
    (e) Marketing and Communications
    (f) Technical
    Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
    To use data analytics to improve our website, platform and app, products/services, marketing, customer relationships and experiences(a) Technical
    (b) Usage
    Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website, platform and app updated and relevant, to develop our business and to inform our marketing strategy)
    To make suggestions and recommendations to you about goods or services that may be of interest to you(a) Identity
    (b) Contact
    (c) Technical
    (d) Usage
    (e) Profile
    (f) Marketing and Communications
    Necessary for our legitimate interests (to develop our products/services and grow our business)
  11. MARKETING

    1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established personal data control mechanisms to help you manage your preferences.
    2. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
    3. You will receive marketing communications from us if you have requested information from us or purchased services or products from us and you have not opted out of receiving that marketing.
  12. OPTING OUT

    1. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you and/or by contacting us at any time.
    2. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service we provide to you, product/service experience or other transactions.
  13. COOKIES

    1. Like many other websites, we use cookies to distinguish you from other users and to customize and improve our services. Cookies allow our servers to remember IP addresses, date and time of visits, monitor web traffic and prevent fraudulent activities.
    2. Our cookies never store personal or sensitive information; they simply hold a unique random reference to you so that once you visit the site we can recognize who you are and provide certain content to you.
    3. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website, may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
  14. DISCLOSURES OF YOUR PERSONAL DATA

    1. We may share your personal data with the parties set out below for the purposes described in this Privacy Policy.
    2. Please note that these third parties may have access to your personal data. The reason for such access is that they are performing certain services on our behalf. However, they are obliged not to disclose or use the information for any other purpose apart from that which is assigned to them.
    3. Personal information may be shared with the following third parties:
      • Financial institutions, payment systems with whom we work together to develop or provide a product or service, to execute transactions, to resolve conflicts and to investigate and prevent fraud.
      • Other transaction participants.
      • Other companies that provide services to us. We may share personally identifiable information with other partners who provide services and functions on our behalf.
      • Third parties for our business purposes or as permitted or required by law.
      • With relevant authorities/third parties to investigate violations of any agreements or other legal provisions applicable to our services or to enforce legal rights.
    4. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
  15. DATA SECURITY

    1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
    2. Unfortunately, no method of electronic transmission or storage via the Internet is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your password for your Slimepay account and do not share them with others.
    3. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
  16. DATA RETENTION

    1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
  17. YOUR LEGAL RIGHTS

    1. Under certain circumstances, you have rights under data protection laws in relation to your personal data. They can be summarised as follows:
      • Request access to your personal data.
      • Request correction of the personal data that we hold about you.
      • Request erasure of your personal data.
      • Object to processing of your personal data.
      • Request restriction of processing of your personal data.
      • Request the transfer of your personal data to you or to a third party.
      • Withdraw consent at any time where we are relying on consent to process your personal data.
    2. If you wish to exercise any of the rights set out above, please contact us.
  18. NO FEE USUALLY REQUIRED

    1. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
  19. WHAT WE MAY NEED FROM YOU

    1. 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.
  20. TIME LIMIT TO RESPOND

    1. We try to respond to all legitimate requests within one month. Occasionally it could 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.

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IMPORTANT INFORMATION FOR OPENING A NEW ACCOUNT: Federal regulations require us to obtain and verify identifying information from new account holders to combat money laundering and terrorism financing. When opening an account, you'll need to provide your name, address, date of birth, and government ID number (NIN/BVN). We may request identification documents and validate your information. Accounts are subject to our identity verification processes and may be restricted or closed if verification cannot be completed satisfactorily.

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