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Privacy Policy

Introduction

DesolaNEO Limited (“Desola”) gives highest regard to your privacy and protecting your personal data is of utmost importance. We place a high priority on data security and we make sure we have appropriate measures in place to prevent your personal data from unauthorized use and access. This Privacy Policy sets out how we collect and process your personal data.
The purpose of this privacy policy is to explain to customers what types of information we will collect and how that information is used. In most cases, we collect this information to ensure network integrity and that we continue to provide you with the best possible service that suits your needs. In some cases, we are required by law to collect personal information about customers. Except where the law requires otherwise, we undertake to protect the confidentiality of such data.
References in this Privacy Policy and on our website and Mobile Application to “we”, “our” or “us” are references to DesolaNeo Limited (“Desola”). References to “you” and “your” means each natural or legal person who interacts with us, uses our website or the products and services we provide.
Confidentiality
DesolaNeo Limited respects customer privacy and the privacy of those accessing our Mobile Application and website. We undertake to protect the confidentiality of our customers and users including all personal information supplied while contracting with us for services. We undertake not to sell your personal information to third parties for commercial or marketing purposes.
We keep our Privacy Policy under regular review. This version was last updated in [May 2024].

Information we collect and process about you

1.Desola may collect certain personal information about our Mobile Application customers and visitors to websites hosted by us. Such information will include both identifiable personal data, as well as non-identifiable personal information. Identifiable personal information will be collected when you sign a contract for service with us or use our Mobile Application or website. Non-identifiable information may also be gathered automatically when you visit our website via cookies.

2.It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.

3.You may give us information about you when you register for an account through our Mobile Application or by communicating with us by phone, email or otherwise. This may include data that we receive when you create a profile on our App. This also includes information you provide when you subscribe to our services, provide us with feedback, participate in surveys, refer our services and when you report a problem with our application. The information you give us may include your name, address, email address, phone numbers, date of birth, identity documents, NIN, BVN number, your personal picture and username (or similar identifier). It may include data relating to the transactions you have carried out on our app, such as details about payments and receipts. If you engage with us on our social media channels, then this may also include your social media contact details.

4.Information we collect about you when you communicate with us by phone, email, post, in person or otherwise, and when you use our products and services. We collect engagement metric information such as information about how and when you contacted us, and how you responded to communications from us and about how and when you use our products and services. It could include your preferences in relation to whether or not you want to receive marketing from us and our third-party partners, your communication preferences as well as your notification preferences.

5.Information we receive from other sources. We may receive further information about you if you use any of the services we provide. We work closely with third parties (including, for example, business partners, service providers, identity verification providers) and may receive information about you from them. We may combine information we receive from these other sources with information you give to us and information we collect about you.

6.We keep records of financial transactions executed on our Mobile Application. We keep data related to payments, receipts and returns executed via our payment channels as well as 3rd party channels.

7.We may request to send you push notifications regarding your account, your transactions on the Application or any other matter. If you wish to opt-out from receiving these types of communications, you may turn them off in the application.

Limitations to our ability to provide our services

8.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.

9.Where certain personal data are required by our 3rd party partners, we may not be able to provide the services required if you fail to provide the data when requested. The product or service provider does not have permission to use these data for any other purpose other than the purpose for which it is requested including marketing

Purposes and legal basis for using your personal data

10.Where you have requested that we provide a specific product or service to you, or you otherwise make use of those products or services, we will process your personal data to perform our contract with you and provide that product or service.
11.We also use the personal data we hold about you to pursue our legitimate interests in providing and marketing our products and services to you, improving our website, services and interactions with you and other users of our products and services in the following ways:

I. administer your account and relationship with us and to, communicate with you by telephone, mail, email, text (SMS) message, instant messaging or other electronic means;
II. verify your identity as part of our identity authentication process and to prevent, detect and prosecute fraud and crime and comply with legal or regulatory requirements.
III. provide you with information about the products and services that you request from us.
IV. provide you with information about other products and services we offer that are like those that you have already purchased or enquired about.
V. provide you with information about products or services we feel may interest you.
VI. notify you about changes to our services.
VII. ensure that content from our website is presented in the most effective manner for you and your device.
VIII. aggregate it on an anonymous basis with other data for data analytical and reporting purposes.
IX. to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
X. to improve the service we offer you and to try and ensure that you get the best from our app.
XI. to allow you to participate in interactive features of our service, when you choose to do so;
XII. as part of our efforts to keep our app safe and secure.
XIII. for training and quality purposes.
XIV. to check any instructions you give to us and for the purposes of investigating any complaint you may make, or as evidence in any dispute or anticipated disputes between you and us.
XV. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
XVI. In some cases we may also use the personal data we hold about you to comply with our legal obligations.

Who your data can be disclosed to

12. Disclosure of your data to others may be necessary to ensure the smooth provision to you of the products, services and information you request. Your data may be disclosed to the other entities as described below.

13. We may share your personal information with employees involved in accounts opening process, registration, customer service, transactions team, reconciliation, and audit teams as well as other employees that might require access to your data to perform their duties and to make it possible to offer our services to you. All employees with some sort
of access to your data are adequately trained to be aware of their responsibilities. We
will put security measures in place to ensure access to your data is only on a need to access basis.

14.We may share your information with selected third parties including:

I. Providers of banking, payments, and other related services.
II. Fraud prevention agencies, to prevent crime and trace those responsible.
III. Identity verification providers, to comply with legal or regulatory requirements.
IV. Analytics and search engine providers that assist us in the improvement and optimization of our App.
V. IT and software providers who supply us with our IT infrastructure for the provision of our services and administering our business (including our internal and external communications) and who also help us manage our customer and contact databases, customer relationships and marketing.
VI. Customer information can be used to prevent crime and trace those responsible. We may share your personal information with fraud prevention agencies as required by law. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information.

Sharing your data with 3rd parties and partners

15. We collect and share aggregated user data with business partners, sponsors or other third parties for transaction purposes or contract entered into by the user on our Mobile Application or Website. These business partners and affiliated companies do not have any independent right to share this information.

16. We review all our relationships with third parties carefully so that we can be sure as possible that their practices match our own commitments to you relating to privacy and security. We also comply with the Data Protection Legislation in our dealings with these third parties to ensure that your information is appropriately protected.

17. 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.

Your legal rights

18.You have the right to request a copy of the personal data that we hold, request that we correct personal data if it is inaccurate, request that we erase or block your personal data, and object to our processing of your personal data. These rights are limited in some situations. For example, if we have a legal requirement or compelling legitimate ground, we may continue to process your data even where you request its deletion.

19.If you would like to exercise any of these rights, please contact us on [email protected]. You may have to pay a fee to access your personal data. We may charge a reasonable fee if the request received is repetitive or excessive.

20.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 several requests. In this case, we will notify you and keep you updated.

Reservation of Rights

21.Desola reserves the right to disclose information about customers where required in good faith, to do so by law or to exercise our legal rights or defend ourselves against legal claims.

22.Desola further reserves the right to share information with law enforcement to investigate or prevent illegal activities being committed over our network.

23.We reserve our rights to disclose your personal information where you have given us explicit legal written consent to do so.

24.Desola reserves the right to monitor user and network traffic for site security purposes and prevent any unauthorized attempts to tamper with our site or cause damage to our property.

25.Desola reserves the right to make changes to this privacy policy or update it.

Changes to our Privacy Policy
26.Any changes we may make to our Privacy Policy in the future will be communicated through our Mobile Application, website and, where we consider it appropriate, notified to you by email. Customers and site visitors bear the responsibility to ensure that they have read the changes or updates.

Contact
27.Questions, comments, and requests regarding this Privacy Policy should be addressed to [email protected]. Details of how to contact us can also be found on our mobile application and website.


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