Lifteller Privacy Notice
LIFTELLER SOCIAL MEDIA LIMITED
PRIVACY NOTICE
At Lifteller we consider your privacy as paramount and are thus committed to protecting and respecting your privacy. We are committed to being transparent about how we collect, process, share, and manage data about you (our customers and other natural persons where applicable).
This Notice stipulates Lifteller's approach to handling your data and your rights with regards to our collection, use, storage and sharing of your personal data, which may be collected by Lifteller and/or Subsidiaries in the course of providing you with exceptional products and services, across all our delivery points.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- [IMPORTANT INFORMATION AND WHO WE ARE]
- [THE DATA WE COLLECT ABOUT YOU]
- [HOW IS YOUR PERSONAL DATA COLLECTED?]
- [HOW WE USE YOUR PERSONAL DATA]
- [THIRD-PARTY PROCESSING]
- [INTERNATIONAL TRANSFERS]
- [DATA SECURITY]
- [DATA RETENTION]
- [YOUR LEGAL RIGHTS]
- [CHANGES TO PRIVACY NOTICE]
Important information and who we are.
Purpose of this privacy notice
This privacy notice aims to give you information on how Lifteller collects and processes your personal data through your use of our App, including any data you may provide through our App when you use any of our services or that we may infer from such use, and the steps you can take to protect your privacy.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements other notices and privacy notices and is not intended to override them.
Third-party links
This App 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 process data about you. We do not control these third-party websites and are not responsible for their privacy practices and procedures. When you leave our App, we encourage you to read the privacy notice of every website you visit through our App.
The information we collect about you.
In the course of consuming services provided to you by Lifteller and/or Subsidiaries to meet your needs, through this channel, we collect information you provide us via forms, phone calls, and correspondence by mail or emails, service point interfaces, as well as other channel enablers as might be available. The information we collect may include, but not limited to:
- Identity Data such as Name, photograph/photo ID
- Contact Data such as residential/contact address, email address and telephone numbers
- Financial Data such as bank account details and bank verification number
- Transaction Data such as details about payments to and from you
- Technical Data such as 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 App.
- Profile Data such as your username and password, preferences, feedback, and survey responses.
- Usage Data such as information about how you use our App, products, and services.
- Marketing and Communication Data such as your preferences in receiving marketing from us and our third parties, and your communication preferences.
We collect Sensitive Personal Data about you, such as biometric data (through our facial verification system). However, we do not collect other sensitive information such as race, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, criminal convictions and offences.
If you fail to provide personal data
Where we are required to collect personal data, or need it to provide our services to you, and you fail to provide that data when requested, we may be unable to provide the service to you.
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 data by filling out forms or by corresponding with us by phone, email, or other available means. This includes personal data you provide when you:
- create an account on our App;
- request marketing materials or communication to be sent to you;
- make payments using our App; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
- Third parties or publicly available sources. We may also receive and use personal data about you from various third parties.
How we use your personal data
- We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:
- When you give us consent.
- To provide our product and services to you
- Where we need to comply with a legal obligation.
- To protect your vital interest or that of another individual.
- 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.
- We will get your consent before sending third-party direct marketing communications to you. You have the right to withdraw consent to receive marketing materials at any time by contacting us.
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 of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
- Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful ground we are relying on to process your personal data, where more than one ground has been set out in the table below.
| Purpose/Activity | Lawful basis |
|---|---|
To provide products and services which you have requested, and to conduct business with you (for example, to register you as a new user, to process your application, to manage your account, to tell you about important changes to our services, to process and to respond to your enquiries, complaints and issues), to update and improve your records. | Performance of a contract with you |
For security, financial information identification and verification purposes. | Compliance with a legal obligation (e.g., compliance with our Anti-Money Laundering and Know Your Customer obligations). |
To detect, investigate, prevent and prosecute criminal activity and to meet our regulatory, legal and compliance obligations (including performing regulatory and prudential compliance checks on an ongoing basis, account and transaction monitoring, checks for sanctions and politically exposed persons, and transaction and tax reporting. Also making disclosures to, co-operating with, and complying with requests from: public authorities, regulators, courts of law, tax authorities, governmental bodies or law enforcement agencies, and investigating and preventing fraud, terrorism and other crimes. | Compliance with a legal obligation Legitimate interests (ensuring effective compliance in all relevant jurisdictions, protecting our customers, maintaining a good relationship with law enforcement, regulators and other relevant authorities. Also, we have a legitimate interest in protecting our legal rights). |
To improve customer service, and to decide if a product or service is suitable for your needs. | Legitimate interests (we have a legitimate interest in providing quality customer service, as this allows us to maintain good client relationships and to deal with queries and complaints effectively. Also, we have a legitimate interest in ensuring that we provide our customers with appropriate products and services, to ensure both appropriate risk management and good client relationship management. |
To provide you with the appropriate level of service, to accommodate your specific individual needs and treat you fairly based on any vulnerability you may have, whether you have told us, or we believe it necessary to record, to improve user service and ensure equal treatment, protect vulnerable customers, or safeguard your economic well-being. | Consent Vital Interest Legitimate interests (we have a legitimate interest in providing quality customer service, as this allows us to maintain good client relationships and to deal with queries and complaints effectively). |
To carry out operational and administrative functions (e.g. to maintain our own accounts and records, to operate information technology systems, to carry out billing-related and payments administration). | Comply with a legal obligation (to maintain certain statutory records) Legitimate interests (we have a legitimate interest in running our business efficiently). |
To share relevant information in respect of a prospective sale of Lifteller, or any of its subsidiaries, or any part of its or their business. | Legitimate interests (we have a legitimate interest in complying with due diligence requirements and being efficient in how we run the business). |
Marketing: To tell you about products and services that may interest you (by email, phone or text, in accordance with your preferences). | Consent Legitimate interests (we have a legitimate interest in making our customers aware of our other services and offerings). |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You have the right to revoke your consent to such uses at any time by contacting us or adjusting your preferences through our communication channels. We are committed to respecting your choices and ensuring that your data is handled in accordance with your preferences.
Promotional offers from us
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).
We will send you marketing communications where you have given your consent to receive them. You may withdraw your consent or opt out of receiving such communications at any time by following the unsubscribe instructions provided in each message or by contacting us directly
Third-party marketing
We will obtain your consent before we share your personal data with any other third party service provider for marketing purposes.
Opting out
You can ask us or our third parties (marketing agencies providing services on our behalf) to stop sending you marketing messages at any time by following the unsubscribe instructions provided in each message.
Where you opt out of receiving these marketing messages, this will not apply to personal data retained for the purpose of providing /service to you.
Change of purpose
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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
Please note that we may process your personal data without your knowledge or consent, where it is required or permitted by law.
International Transfers
We do not transfer your personal data outside of Nigeria. All data processing activities are conducted within Nigeria. If it becomes necessary to transfer your personal data internationally in the future, we will inform you and ensure such transfers are carried out in accordance with applicable data protection laws and with appropriate safeguards.
Data Security
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. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
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.
Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purpose of satisfying any legal and regulatory 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.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
You have rights under data protection laws in relation to your personal data. You may:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Withdraw consent
- Lodge a complaint with the relevant authority
If you wish to exercise any of the rights set out above, except the right to lodge a complaint with the relevant authority, please contact our Data Protection Officer:
Oloruntoba Freeman,
freeman@lifteller.com
Changes to the Privacy Notice
Our Privacy Notice may be updated from time to time. We will post any privacy notice changes on this page and, if the changes are significant, we will provide a more prominent notice.