PETTYSAVE MICROFINANCE BANK PRIVACY POLICY
INTRODUCTION
This privacy policy ("Privacy Policy") explains how personal information of our users ("Users") is collected, used, and stored by Pettysave Microfinance Bank Limited ("we," "us," and "our")
Pettysave Microfinance Bank Nigeria Limited (hereinafter referred to as "the Bank") values your Personal Data and we are committed to protecting your privacy whenever you interact with us. This privacy policy is designed to provide information regarding our privacy practices, particularly regarding how we collect, process, retain, share, and protect your Personal Data when you visit our website, premises or use our digital platforms (collectively, "the Platform" or "Services") as well as your rights as a data subject, in full compliance with the provisions of the Nigeria Data Protection Act 2023 and other applicable data protection regulations.
This privacy policy contains important information for you. It explains:
- who we are;
- our website;
- what personal information we collect about you;
- how, when, and why we collect, store, use, and share your personal data;
- how we keep your personal data secure;
- for how long we keep your personal data;
- your rights in relation to your personal data;
- how to contact us or the relevant supervisory authorities should you have a complaint.
In this policy, please note the use of the following terms:
- personal data has the meaning given to it by the Nigeria Data Protection Act, 2023 (NDPA) and means any information relating to an identified or identifiable individual (known as a data subject);
- processing means any operation or actions performed on personal data; for example, collection, recording, organization, structuring, storing, altering, deleting, or otherwise using personal data.
- we, us, and our refer to Pettysave Microfinance Bank;
- you and your refers to the person who is accessing our website, whose data is processed, or interacting with us through other means.
LAWFUL BASIS FOR USE OF YOUR PERSONAL INFORMATION
We may process your Personal Information under any of the bases provided below as recognized by data protection laws:
Consent:
By using our Services, you consent to the terms of this Privacy Policy, as to allow us to utilise your data to serve you more accurately. By accessing our Services and voluntarily providing us with the requested Personal Information, you consent to the collection and use of the information in accordance with this Privacy Policy. Your consent can be withdrawn at any time by sending a request to that effect to this e-mail: info@pettysavemfb.com or calling 09138124277.
Contractual obligations:
We may process your Personal Information to fulfill our contractual obligations such as providing our Services to you or to take necessary actions at your request before providing our Services to you. This enables us to provide you with the Services you request. When you enter into a contract with us, such as subscribing to our Services or engaging in a business agreement, we need to use your Personal Information to carry out our commitments. This includes processing information such as your name, contact details, and any other data necessary to deliver the agreed-upon Services or products. Without this data, we would be unable to complete transactions or manage our contractual relationship effectively.
Legal obligations:
We may also process your Personal Information to fulfill our legal obligations mandated by Nigerian law. This includes sharing financial information for tax reporting and accounting and using employment data to comply with labour laws, payroll requirements, and health and safety regulations. We may also process Personal Information to adhere to legal requests, court orders, and regulatory requirements.
Legitimate Interest:
We may also process your Personal Information on the grounds of legitimate interest such as fraud investigation and prevention, to safeguard our IT systems, and for user-tailored marketing. We may process personal data on this basis as long as same is not in contravention of the other lawful bases, fundamental rights, or freedoms of our users or where users would not have a reasonable expectation that the personal data would be processed in the manner envisaged.
Vital Interest:
We may process your Personal information if necessary to protect your vital interests or the interests of another natural person, where the data subject is physically or legally incapable of giving consent such as in the event of a claim for any amounts in the account of a deceased User by the User's next-of-kin.
Public Interest:
We may process your Personal Information if necessary to perform an obligation in the public interest or by virtue of an official authority bestowed on us.
These lawful bases may be extended to cover any additional grounds for the processing of personal data as may be recognized by data protection laws in force from time to time.
COLLECTING AND USING YOUR PERSONAL DATA
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally, identifiable information may include, but is not limited to:
Email address, First name and last name, Phone number, Address, State, Province, ZIP/Postal code, Bank Verification Number (BVN), National Identification Number (NIN), Photograph, Date of Birth)
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 as necessary to offer and provide the service you request. Depending on the service you choose, in line with regulatory requirements for Know Your Customer (KYC) purposes, we may require that you provide us with your name, age, gender, facial photo, residential address, utility bill, email address, and mobile number to create an account. We will also require your NIN and/or your BVN in line with regulation and in furtherance of our KYC computation processes. We may also require you to provide additional, necessary personal details as you use our services.
- Transaction information: When you use our digital platform to send and receive money, make purchases from merchants, pay bills, deposit & withdraw cash, we collect information about the transaction, as well as other associated information as necessary to offer and fulfill the service (like transaction receipt, account statement) that we are obliged to; such as the amount sent or received, the amount paid for products or services, merchant information – including information about your device and geolocation.
- 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.
Information Collected while Using the Application
We collect and process the contact details from your device solely for the purposes of credit assessment and fraud detection. We only collect the metadata necessary to fulfill these specific purposes. This data collection is conducted in strict compliance with the Nigeria Data Protection Regulation (NDPR) and the General Data Protection Regulation (GDPR) where applicable.
We ensure transparency in our practices by informing users about the data we collect, the reasons for its collection, and how it will be used. Explicit consent is obtained from users before any contact information is collected. We also conduct regular reviews and updates of our privacy practices to ensure ongoing compliance and the protection of your data. Additionally, we implement robust security measures to safeguard the contact information we collect against unauthorized access or misuse.
Device Permissions
For Personal Data access Depending on the User's specific device, we may request certain permissions that allow it to access the User's device Data as described above.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including monitoring the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
- To contact You: by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You with news, special offers, and general information about other services, and events which we offer that are similar to those that you have already used or enquired about unless You have opted not to receive such information.
Once you unsubscribe or object, We will stop sending further 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 and free of charge.
Retention of Your Personal Data
We retain Personal Data in an identifiable format only for as long as required for our business purposes, with specific reference to the service rendered to you, and to fulfill our legal or regulatory obligations. Subject to applicable law, which might, from time to time, oblige us to retain your Personal Data for a certain period of time, we will retain your Personal Data for as long as necessary to fulfill the purposes we collect it for, including the purposes of satisfying any legal, accounting, or reporting obligations.
Children's Privacy
Our Services are not directed, or intended to be attractive, to children under the age of eighteen (18). We do not knowingly collect Personal Information from children under the age of eighteen (18). If you are under the age of eighteen (18), do not use our Services or submit any information to us.
Links to Third-Party Websites
When you use our Services, you may be directed to other websites that are beyond our control. We may also allow third-party websites or applications to link to our Services. We are not responsible for the privacy practices of any third parties or the content of linked websites, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties and websites. This Privacy Policy only applies to our Services.
Your Rights
You have rights under data protection laws in relation to your personal data. These include rights to:
- Request access to your personal data (commonly known as a "data subject 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.
- Request correction of the personal data that we hold about you This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy
- Where our use of the data is unlawful but you do not want us to erase it
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
- Right to data portability
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 at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent we may not be able to provide certain products or services to you. We will advise you if this is the case at such time when you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us @ info@pettysavemfb.com
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 several requests. In this case, we will notify you and keep you updated.
How Do We Protect Your Personal Data?
We are committed to ensuring that your information is secure. To prevent unauthorized access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online. Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. You also play a role in protecting your Personal Information. Please safeguard your email address, username and password for your Pettysave account, and do not share them with others.
Remedies for Violation and Time-frame for Remedy
In the unlikely event of violation of any of your rights as a data subject, our Data Protection Officer shall within 30 days of our notice of the said violation, address the issue and redress the violation as practicable as possible. The available remedies include but not limited to correction or deletion of your data, grant of access to your data, due information on the processing of your data, restriction on further processing and other applicable remedies as the relevant laws prescribe.
Changes to this Privacy Policy
Subject to applicable law, we may revise this Privacy Policy at any time and in our sole discretion. When we revise this Privacy Policy, we will post the revised version via our Services and will update the date at the top of this Privacy Policy. The revised Privacy Policy will be effective upon posting via our Services, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing or using our Services. If you do not agree to the terms of this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access and use of our Services. Except as otherwise expressly stated by us, your access and use of our Services is subject to the version of this Privacy Policy in effect at the time of access or use.
Contact Us
If you have any questions about this Privacy Policy, You can contact us:
- By email: info@pettysavemfb.com
- By Call: 09138124277
- By visiting this page on our website: www.pettysavemfb.com