WA Shop Privacy Policy
This Privacy Policy effective from 10 October 2024
This Privacy Policy was last updated on 10 October 2024
Welcome to WA Shop! This Privacy Policy is issued by PalmPay Limited, its parent, successors, assignees and affiliates ("PalmPay", "we", "our", or "us") and constitute our commitment to protecting and respecting your privacy. We will use this Privacy Policy to help you understand our collection, use, storage and sharing of personal information, as well as your rights. Unless otherwise agreed, the definitions used in these Privacy Policy have the same meaning as those in the Terms of Use of WA Shop.
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO ENSURE THAT YOU UNDERSTAND EACH PROVISION. BY VISITING OR USING WA SHOP, YOU ARE SIGNIFYING THAT YOU HAVE READ AND UNDERSTOOD THE TERMS OF THIS PRIVACY POLICY, AND AGREE TO BE BOUND BY IT AND ALL FUTURE MODIFICATIONS TO THIS PRIVACY POLICY, AS WELL AS TO THE COLLECTION AND USE OF YOUR INFORMATION AS SET OUT IN THIS PRIVACY POLICY.
What the Privacy Policy is Designed to Describe
- Definition
- What personal data we collect
- How we use your personal data and why
- Marketing communication preferences
- Who we share your personal data with
- What information is stored and for how long
- How we protect your personal data
- Your rights relating to personal data
- Information of Children
- Changes to this Privacy Policy
- How to contact us
- Applicable Law
1. Definition
This Privacy Policy is intended to meet our obligations under the “Nigerian Data Protection Act" or NDPA, a legal framework that sets guidelines for the protection and processing of personal information of individuals within Nigeria or residing outside Nigeria but of Nigerian descent.
Agreement – the Terms of Use entered into between buyer and sellers on the one part and PalmPay on the other part, for the use of the WA Shop.
Customer - means a buyer and sellers.
Customer Representative – natural person representing the Customer (which includes a representative of a potential, current or former Customer, as the case may be).
Data Controller – a legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
Data Processor – a legal person, public authority, agency, or other body which processes personal data on behalf of a Data Controller.
Data Subject – a natural person or individual about whom we have Personal Data, including Customer Representatives, buyer and sellers, Visitors and other natural persons whose Personal Data we may process.
Purchase Agreement – a legally binding contract under which a seller transfers or agrees to transfer ownership of goods to a buyer in exchange for money. .
Seller - means an individual or entity who sells goods on WA Shop.
Service - the service provided by PalmPay under the Agreement for the use of WA Shop.
Personal Data or Personal Information - shall have the meaning stipulated by the NDPA and shall include any information relating to an identifiable natural person, which includes the Customer Information or information that enables us to identify you personally.
Buyer – means an individual or entity who buys goods on WA Shop,
Visitor – is any person visiting the WA Shop.
Users - includes a Seller, Buyer and/or Visitor (individually and collectively, “Users”, “you” or “your”).
2. What Personal Data We Collect.
2.1 We will/may collect personal data about you:
-when you register and/or use our Services or open an account on WA Shop;
-when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
-when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails, including when you interact with our customer service agents;
-when you use our electronic services, or interact with us via our application or use Services on WA Shop. This includes, without limitation, through cookies which we may deploy when you interact with us on WA Shop;
-when you grant permissions on your device to share information with us on WA Shop;
-when you link your WA shop account with your social media or other external account or use other social media features, in accordance with the provider’s policies;
-when you initiate, process and or complete a purchase on WA Shop
-when you provide us with feedback or complaints;
-when you submit your personal data to us for any reason
2.2 We may collect personal data about you from you, our affiliates, third parties, and from other sources, including without limitation business partners (such as logistics or payment service providers), credit bureaus or scoring agencies, marketing services providers or partners, referral or loyalty programs, other users of our Services or publicly available or governmental sources of data.
2.3 The personal data that WA Shop may collect includes but is not limited to:
a. Users & Customer Representatives
We process the data of individual Users and Customer Representatives’ of entities when we onboard new Customers, enter into the Agreement, provide the Service and for other lawful reasons. The Personal Data of the User and Customer Representative we collect and process for the provision of the Service are:
Identity Information | such as name, job title, position, contact information of the User or Customer Representative |
KYC Information | First name, surname, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, selfie picture, live photographs or videos, facial ID, identification document number, copies of ID documents, biometric data or other forms of identification. |
Marketing and Communications Data | Your preferences in receiving marketing from us and our third parties and your communication preferences. If you correspond with us by email or messaging through the Services, we may retain the content of such messages and our responses. |
Device Data | The contact application on your device and your contacts’ information such as their name, mobile number, or email address contained therein. Details of your handset/device, unique device identifiers (IMEI or serial number), information about the SIM card, mobile network, operating system and browser settings. |
Technical Data | Security credentials (username and PIN/password) 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 this application or website or use our services. |
b. Visitors and other users
i. Cookies
A cookie is a string of information that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns.
PalmPay uses cookies to help PalmPay identify and track Visitors, their usage of WA Shop,and access preferences. Visitors who do not wish to have cookies placed on their computers should set their browsers or application to refuse cookies before using WA Shop or decline the option of using cookies when they visit for the first time. Our Services may not function property without the aid of cookies.
ii. Analytics
We may use analytics technologies, like Google Analytics, to help improve and simplify WA Shop, including the design and service. These tools track aggregated information about your usage of WA Shop, provide performance measurements and allow better reporting on failures.
2.4 If you sign up to be a user of WA Shop using your social media account (“Social Media Account”), link your WA Shop account to your Social Media Account or use any WA Shop social media features, we may access information about you which you have voluntarily provided to your Social Media Account provider in accordance with such provider's policies, and we will manage and use any such personal data in accordance with this Policy at all times.
2.5 If you do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying us in writing. Note, however, that opting out or withdrawing your consent for us to collect, use or process your personal data may affect your use of the Services. For example, opting out of the collection of location information will cause its location based features to be disabled.
3. How we use your personal data and Why
3.1 Basis for data processing
This Privacy Policy is intended to meet our obligations under the “Nigerian Data Protection Act" or NDPA.
In respect of each of the purposes for which we use your Personal Data, the NDPA requires us to ensure that we have a legal basis for that use. The legal basis depends on the Services you use and how you use them. This means we collect and use your Personal Data where we need it to provide the Services to you, including to operate the Services, to comply with a legal or regulatory obligation, to provide customer support and personalized features and to protect the safety and security of the Services.
We also process your Personal Data based on our legitimate interests, provided that these interests are not overridden by your data protection rights. These legitimate interests include activities such as transaction processing, identity verification, conducting research and development, marketing and promoting our services, and protecting our legal rights and interests.
We may also rely on your consent as a legal basis for using your Personal Data where we have expressly sought it for a specific purpose. If we do rely on your consent to a use of your Personal Data, you have the right to withdraw your consent at any time (but this will not affect any processing that has already taken place prior to the withdrawal of your consent).
3.2 Compliance with Laws:
We collect and store personal information about you to comply with the relevant financial regulations.
Apart from the circumstance of complying with a Court Order, Arbitral Panel, Tribunal, Regulatory Directive or Order or any other legal or regulatory obligation, we do not disclose information about identifiable individuals to other parties, but we may provide them with anonymous aggregate information, such as the number of people of a certain age or sex who have performed certain transactions of a certain amount within a particular timeframe, for example.
Where we use a 3rd party service, with your consent, we may share your information in order to offer the service or improve the experience of that service. When you use such a service for the first time, you will need to review and agree to their terms and conditions, privacy policy and other related agreements where applicable.
In order to provide the Service to you as well as comply with applicable laws, we may verify, compare and validate the personal information you provide to us with the relevant government authorities.
3.3 Provision of the Service
We collect and process Personal Data for the purpose of providing the Service and preventing fraud. The Personal Data will be used to assist us in delivering the Service that you signed up for; allow us to understand how Services are being used by you; protect you and your account; improve our Services and communicate new services and offers to you.
We do not use this data for any other purpose. The information is processed in a manner that is secure and in compliance with applicable laws and regulations concerning Personal Data.
4. Marketing Communication Preferences
If you would like us to stop sending marketing messages or modify your email preferences at any time, please follow any of these procedures:
- Follow the opt-out messages sent in any of the emails;
- Go through the notification switch off process in the settings on your application
- Contact us at anytime using the contact details in How to Contact Us.
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us for processing for legitimate service-related purposes.
5. Who we share your personal data with
We may share your personal data with third parties as described in the table below. We consider this information to be a vital part of our relationship with you.
Recipients | Why we share it |
Our Affiliates | Our affiliates may access your Personal Data to help us develop, maintain and provide our Services and help manage our customer relationships (including providing customer support, customer liaison, fund advisory services, etc). |
Service Providers | Our service providers provide us support for our Services, including, for example, website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, auto-deduct services, analysis, identity verification, background and compliance reviews, fund administration, banking services, and other services for us, which may require them to access or use Personal Data about you. |
Professional Advisers | Our lawyers, accountants, bankers, auditors and insurers may need to review your personal data to provide consultancy, compliance, banking, legal, insurance, accounting and similar services. |
Legal and Taxing Authorities, Regulators and Participants in Judicial Proceedings | PalmPay may disclose your Personal Data if we believe it is reasonably necessary to comply with a law, regulation, order, subpoena, rule of a self-regulatory organization or audit or to protect the safety of any person, to address fraud, security or technical issues, or to protect our legal rights, interests and the interests of others, such as, for example, in connection with the acquisition, merger or sale of securities or a business (e.g. due diligence). |
Advertisers | Certain users of the Services may have access to your Personal Data for the purpose of enabling them to interact with you and more effectively offer opportunities through the Site that are targeted towards your background and preferences. We may also allow third-parties, including ad servers or ad networks, to serve advertisements on WA Shop and such third parties may be provided with access to your Personal Data to provide advertising tailored to your interests. |
Researchers | Anonymised data may be shared for the purpose of research and to enhance the public understanding of patterns and trends in the markets served by or Services. This is provided to third parties under confidentiality obligations such as, for example, academics or contractors for research purposes. |
API Users | A limited number of partners have API access to portions of the Site. Examples of the most common API uses are OAuth and AML/accreditation verification of potential investors. |
Third Party SDK | Our APP connects to the software development kit (SDK) of some of our third party service providers and in such event your Personal Data may be collected or accessible by these service providers. SDK used by us includes without limitation, bugly, appsflyer and google. We ensure that these service providers take extensive security measures with high level encryption in order to protect your Personal Information against loss, misuse or alteration. |
In addition, the Personal Data you choose to add to your profile, such as your customer name and account number, may be visible to other Users or any other person for the purpose of transaction processing or Service promotions and activities which you participate in. While you may request that your information be shared only with a select group of people, we cannot guarantee that it will not be accessed by others or that those with access will handle it appropriately. If you prefer to keep your information private, we recommend not sharing it on WA Shop. Please be aware that while some of your activities as a User may not be directly visible to others, certain information or behaviours might still be inferred by other Users on the WA shop.
In addition, our advisers, Top level employees and lead investors may have access to your Personal Data to help them evaluate, invite and communicate with you as a User. If you are a User, your information will generally be available, and they may have access to your Personal Data to assist them in discovering, evaluating and tracking communications.
As we develop our business, we may buy or sell businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, we may also transfer your Personal Data as part of the transferred assets without your consent or notice to you.
We may also share non personal data (such as anonymous usage data, data referring/exit pages and URLs, platform types, number clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services or conduct independent research based on such anonymous usage data.
If you request that we remove your Personal Data as described in Your Rights Relating to Your Personal Data, we will convey that request to any third-party with whom we have shared your data. We are not, however, responsible for revising or removing your Personal Data obtained by any third party who has previously been provided with your information by us in accordance with this policy or any third party to whom you have provided such information (whether by sharing your login and password, or otherwise).
We will also use this data to process payments and comply with legal and regulatory obligations.
6. What information is stored and for how long
6.1 Where your personal information is stored
WA shop is entirely committed to protecting the information we collect from you. We maintain appropriate administrative, technical and physical safeguards (i.e. firewalls, data encryption, competent security guards, etc). These processes are in place to prevent accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use of your information. We are also certified by the International Organization for Standardization (ISO) on information security management (ISO/IEC 27001).
To achieve the purpose stated in this Privacy Policy,WA shop may transfer your personal data to a country on the ‘white-list’ which is deemed to have adequate data protection laws under the NDPR Implementation Framework 2020. Where WA shop transfers your personal data to countries outside the ‘white-list’, we shall ensure that informed consent is obtained from you and other relevant provisions of the NDPA are complied with, to guarantee that your personal data is adequately protected.
We are required to retain the details of transactions or payments you make via WA Shop after the transaction is completed. We will store these transactions for the required period stipulated under the financial data protection regulations of your jurisdiction.
6.2 How long we store your Personal Data
We will retain your information for as long as your account is active, or it is reasonably needed for the purposes set out in How We Use Your Personal Data and Why unless you request that we remove your Personal Data as described in Your Rights Relating to Personal Data. We will only retain your Personal Data for so long as we reasonably need to use it for these purposes unless a longer retention period is required by law (for example for regulatory purposes). This may include keeping your Personal Data after you have deactivated your account for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
7. Your rights relating to personal data
7.1 You have the rights under this Privacy Policy to:
-Request access to your personal data:This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
-Request correction of the personal data that we hold about you: This enables you to have any incorrect or incomplete information about you corrected.
-Request erasure of your personal data: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 you object to us processing it (see below).
-Object to processing of your Personal Data.This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your situation, which makes you want to object to processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
-Request the restriction of processing of your Personal Data.This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
-Request the transfer of your Personal Data.We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
-Withdraw consent.This right only exists where we are relying on consent to process your Personal Data ("Consent Withdrawal"). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
7.2 How to Exercise Your Personal Rights
If you wish to exercise any of the rights above, please contact us using the details in “How to 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.
8. Information of Children
The Services are not intended for children under the age of 18. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 18 nor is any part of WA Shop or the Service directed to children under the age of 18. As a parent or legal guardian, please do not allow such children under your care to submit personal data to WA Shop. In the event that personal data of a child under the age of 18 in your care is disclosed to WA Shop, you hereby consent to the processing of the child’s personal data and accept and agree to be bound by this Policy on behalf of such child. We will close any accounts used exclusively by such children and will remove and/or delete any personal data we believe was submitted without parental consent by any child under the age of 18.
9. Changes to this Privacy Policy
PalmPay may change its Privacy Policy from time to time, and at PalmPay's sole discretion. We will notify you when changes have been made. By continuing to use WA Shop after the change, you agree to accept the new policy.
10. How to contact us
We ensure that our day-to-day processes comply with this Privacy Policy. If you have any questions about our practices or this Privacy Policy, please contact us.
To contact us please send an email to legal@palmpay-inc.com
11. Applicable Law
This Privacy Policy shall be governed and construed in accordance with the relevant laws of the Federal Republic of Nigeria.