1. Introduction

We respect your privacy and are committed to protecting your personal data and any personal information you share with us when you visit our website or that we obtain about you in the course of your engagement with us. We are in tune with international best practices in this regard and are strongly committed to ensuring that our privacy policies comply with these standards.

               Generally, we ensure that our processing of any personal information provided is in compliance with all data protection regulations applicable to us including but not limited to the Nigerian Data Protection Regulation 2019 (NDPR) and the NDPR Implementation Framework (NDPR IF). 

               Thus, as further discussed herein, you can contact us at anytime to: request access to information that we have about you, correct any information we have about you; and or/delete information that we have about you. If you have additional questions about our data collection or storage, please contact us at [email protected]

This privacy policy will explain the following:

• Who we are?
• What data we may collect about you?
• How do we collect your data?
• How we will utilise the data we collect about you?
• How do we store your data?
• What are your data protection rights?
• Changes to our privacy policy?
• How to contact us

2. Who we are?

CashEx Inc is a financial technology company offering technology services to our users through our mobile application and our website. Our registered address is at 11 Temple St, Boston, MA 02114.

For the purpose of data protection legislation, we are the data controller for the personal data processed. 

Mentions of “us” and “we” mean CashEx and “you” means anyone using this service.

3. What data we may collect about you? 

Due to the nature of our operations, when you sign up to use our services or platforms, we may typically require different forms of personal data or information. By providing us with this information, you enable us to provide you with our products and services (see our Terms of Use). 

For clarity, personal data, or personal information, means any information, whether sensitive or non-sensitive about an individual from which that person can be identified. It does not include data where the identity has been removed or the data subject has been classified as anonymous. 

In handling your personal data, we are principally guided by the NDPR, the NDPR IF and other international best practice privacy laws regarding the use, storage, and processing of the data. 

In compliance with the above referenced laws and best practices, 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, gender and IP address].
• Financial Data including banking information, credit or debit card information and any other associated data with which you could be identified. 
• Contact Data includes email address and telephone numbers.
• Technical and usage data about if and how you access or use our website. We collect this data by using cookies on our website. A cookie is a small file placed on your computer’s hard drive. It enables us to recognize your computer as you view different pages on our website, allowing us to give you a better website experience. Cookies allow us to store your preferences to present content and functions that are specific to you.
• Profile Data includes [your username and password, your interests, preferences, feedback, and survey responses].
• Usage Data includes [information about how you use our website, products and services].
• Communications Data includes [your preferences in receiving sensitization updates from us and our third parties and your communication preferences].
• Photos or videos provided in the course of using our products and services. 

We do not collect any sensitive data under the definition of sensitive data as provided by the NDPR. For the avoidance of doubt, “Sensitive Personal Data” means Data relating to religious or other beliefs, sexual tendencies, health, race, ethnicity, political views, trades union membership, criminal records, or any other sensitive personal information. 

4. How do we collect your data?

Most of the data we collect are directly provided by you. Such data is typically collected through any of the following means:

• Sign up to use of products and services. 
• When you contact us by telephone, email, website etc. 

5. How do we utilise your data?

We collect your data to enable us efficiently provide our services and we will only use your personal data when the law allows us to in furtherance of our services. Most commonly, we will use your personal data in the following circumstances:

• Where we have your consent to do so by signing up to access our products and services.  
• Where we have your consent to do so and by virtue of our interactions your personal data is required in performing an In-House data analysis function. 
• 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 are required to use your personal data in discharging a legal obligation, whether imposed by law, statute, or a competent court of law.

• We also use your contact details to communicate with you by email, sms and telephone if you live in the Nigeria or overseas. Any subsequent information you provide to the helpline will also be recorded to continue to provide you with a tailored service and engagement.
• We may also use the data collected to contact you to gauge your interest in taking part in our market research. In each message, you will be given the opportunity to unsubscribe from further communications.
• We will use anonymised data about you to deliver tailored messages on third party platforms, including social media – like Facebook, Instagram, Twitter, Snapchat and Google search. Such anonymised data will also be used to identify and reachout to people that are similar to you.

In addition, we could also share data provided by our customers with our Technical and Financial Partners (as defined in our Terms of Use). Rest assured that such data shared would be treated with similar standards as set out in this policy.

6. How do we store your data? 

We ensure that the best data security measures are put in place to guarantee the protection of any data we may have collected about you. We take severe steps to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties on a strict need to know basis. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. 

Your personal data, supplied for the purposes of this service, will be stored in our customer relationship management system for 5 years unless you exercise your right to be forgotten or it is no longer necessary for the purposes for which it is being processed, following which all your will be deleted.

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.

7. Why our use of your personal data is lawful

In order for our use of your personal data to be lawful, we need to meet one (or more) conditions in the data protection legislation. You have requested to receive this service and therefore, together with this privacy notice (about the use of your personal data), you have agreed to your data being used to deliver our products and services. 

8. What are your data protection rights?

We would like to make sure you are fully aware of all your data protection rights. Every user of our service is entitled to the following:

• The right to access – You have the right to request from us copies of your personal data. 
• The right to rectification. – You have the right to request that we correct any information you believe may be inaccurate. You also have the right to request that we complete information you believe may be incomplete.
• The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
• The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
• The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request to exercise any of these rights, we will endeavor to respond to such request within a reasonable time. Occasionally, it could take us longer 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.

We may also 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.

Please contact us at [email protected] and enter Data Protection as a reference regarding any of the rights listed above.

9. Change in Privacy Policy 

We may need to update this privacy notice periodically, so we recommend that you revisit this information from time to time. We keep our privacy policy under constant review. This version was last updated on 5th September, 2022. 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 the course of your relationship with us. 

If you feel something is not addressed in this Privacy Policy or have further questions, please contact on Data Protection Officer at [email protected]. 

10. Right to lodge a complaint

If you are unhappy with our use of your personal data, please let us know by contacting [email protected].

11. How to contact us 

If you have any queries or questions in relation to our privacy policy, the data we hold on you, or you would like to exercise any of your data protection rights, please do not hesitate to contact us via any of the following:

Email: [email protected]

Website: www.cashex.ai