Privacy policy

INTRODUCTION

At CrowdForce, the privacy of all personal information provided by our Data Subjects is of paramount importance to us. Consequently, we have developed this Privacy Policy to enlighten you on your privacy rights in relation to how personal information is collected, used, stored, and disclosed by CrowdForce ("we," "us," and "our"). This Privacy Policy applies to all users (individually referred to as "you") of our websites, applications, and other online services to which this Privacy Policy is posted (collectively, our "Services").

CONSENT

2.1 This privacy policy between CrowdForce and you constitute our commitment to your privacy on all our services. By accessing or using our services and providing your Personal Information to us, you expressly CONSENT to our collection, use, storage, and disclosure of such information as described in this Privacy Policy.
2.2 However, if after you opt-in, you change your mind, you may withdraw your consent for the continued collection and use of information in accordance with this policy, at anytime, by contacting us.
2.3 The provisions contained in this Privacy Policy supersedes all previous notices and statements regarding our privacy practices with respect to our Services. If you do not agree to every provision of this Privacy Policy, you may not access or use our Services

 CROWDFORCE EMPLOYEE OBLIGATION

3.1 CrowdForce employees who handle your Personal Information are under an obligation to treat it confidentially and may not disclose it to third parties to the extent provided by the applicable privacy Laws and Regulations.
3.2 CrowdForce employees are also responsible for the internal security of the information you provide and that which we collect. Employees who violate this privacy policy are subject to a range of disciplinary actions.

INFORMATION WE COLLECT

4.1 Information You Provide Us:
While using our services, we may ask you to provide us with certain Personal identifiable Information (PII) that can be used to contact or identify you. Personal Identifiable Information may include, but is not limited to your name, username, password, residential address, email address, phone number, BVN, date of birth, banking information and other information that identifies you (collectively, "Personal Identifiable Information"). In some other circumstances, the personal information we request/collect from you is needed to meet our legal or regulatory obligations or to provide you with the products or services requested by you.
We may also ask you to create login information in order to use any of our services, such as a username and password.
4.2 Information About Your Transaction:
We collect Personal Information about your transactions with us when you use our digital platform to send and receive money, make purchases from merchants, pay bills, and deposit & withdraw cash, as well as other information associated with the transaction such as amount sent or received, amount paid for products or services, merchant information, including information about your device and geolocation. When you use our services, we also collect Personal Data about the other participants associated with the transaction. We collect Personal Data such as name and financial account information about the participant who is receiving money from you or sending money to you.
4.3 Information from Third Parties:
In some cases, we may also collect Personal Information about you indirectly from third parties including but not limited to:
  • third parties such as providers of ‘know your client’ and anti-money laundering services which we use to help us meet our legal requirements in this area and to help us verify your identity where we provide you with products or services;
  • background check providers which we sometimes use to verify your identity when you apply for a product of ours;
  • third party service providers that help us to operate our website; and (iv) your banks and financial institutions.
4.4 Information You Provide When You Apply for a Job with Us:
When you apply for a job with us, we may request Personal Data about your education, employment and state of health. We may also carry out screening checks (including reference, background and criminal record checks). We may exchange your Personal Data with academic institutions, recruiters, health maintenance organizations, law enforcement agencies, referees and your previous employers. By putting forward your application, you consent to the collection, processing, storage and disclosure of your personal data in accordance with the terms of this policy.
4.5 Information Collected by Cookies and Other Technologies:
Like most online services and mobile applications, we may use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions or all of our Service.
4.6 Information that we Automatically Collect:
We (or our service providers acting on our behalf) may collect information about your use of our Services. This information may include Personal Information as well as statistical information that does not identify you ("Analytics"). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy.
We automatically collect log information when you use our services, such as:
  • Device information, such as your web browser type and language;
  • Identification numbers associated with your Devices;
  • Device identifiers;
  • Access times;
  • Pages Viewed;
  • The Device's Internet Protocol ("IP") address;
  • Identifiers associated with cookies or other technologies that may uniquely identify your device or browser;
  • Pages you visited before or after navigating to our website;
  • Location preferences;
  • Date and time stamps of transactions;
  • System configuration information; and
  • Other interactions with our Services.
4.7 Do-Not-Track Signals:
Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.

CHILDREN'S PRIVACY

Our Service is not for anyone under the age of 18 (“Children”).
We use cookies to:
We do not knowingly collect Personally Identifiable Information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we shall take steps to remove that information from our server.

HOW WE USE THE INFORMATION WE COLLECT

6.1 Provide You with Our Products and Services: We will use your personal identifiable information to provide you with our products or services, authenticate your access to an account, communicate with you about your account etc. We may also use your personal information in the course of correspondence relating to our products or services. Such correspondence may be with you, our service providers or public or judicial authorities with the necessary authorization.
6.2 Due Diligence: In some cases, we use your personal information to conduct due diligence checks before providing products or services to you, and to process an application from you or a prospective client to receive products or services from us in compliance with the applicable laws and regulations. This helps us manage risk, fraud and abuse of our services and protect you from fraud by verifying your identity.
If you are referred to us by an intermediary or similar third party, we also typically use your personal information to assess whether to accept or reject your referral to CrowdForce by that intermediary or similar third party.
6.3 Improving our Products and Services: We generally use your personal information collected via our website to:
  • to manage and improve any services provided via our website;
  • resolve disputes and troubleshoot problems;
  • to customize the content of our website to provide you with a more personalised experience and to offer our products and services and products and services of third parties that we think you might be interested in;
  • to effectively manage and respond to any request that you submit through our website;
  • To allow us to better serve you in responding to your customer service requests;
  • To send periodic emails regarding your order or other products and services; and
  • To follow up after correspondence (live chat, email or phone inquiries).

You may elect not to receive promotional emails from us either by "unsubscribing" to an email you receive from us or by contacting us as indicated below. If you unsubscribe from receiving emails from us, we may still send you non-promotional emails, such as emails about your use of our products or services, account, or our ongoing business relations, unless you withdraw your consent to receive electronic communications as provided in our Terms of Use.

LEGAL BASIS FOR PROCESSING PERSONAL DATA

7.1 The legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
The Company may process your Personal Data because:
  • We need to perform a contract with you;
  • You have given us explicit consent process your personal data;
  • The processing is in our legitimate interests and it is not overridden by your rights
  • For payment processing purposes; and/or
  • To comply with all applicable Laws and Regulations and fulfil our legal obligations to which we are subject to, such as keeping records in accordance with applicable regulations or providing information to a public body or law enforcement agency.
7.2 We may also process sensitive personal information relating to you for any of the purposes outlined above, we will do so because either: (1) you have given us your explicit consent to process that information; (2) the processing is required by law or regulatory requirements to process that information in order to ensure we meet our KYC and ‘anti money laundering’ obligations; or (3) the processing is necessary for the establishment, exercise or defense of legal claims.
7.3 The legal grounds for processing sensitive personal information outlined above are contained in the EU’s General Data Protection Regulation (GDPR) and the Nigeria Data Protection Regulation (NDPR) 2019.

HOW WE SHARE THE INFORMATION WE COLLECT

8.1 We only share your information as permitted by all applicable privacy laws and regulations or otherwise described in this Privacy Policy.
8.2 We generally disclose details about you to professional advisors and third parties that provide services to us (such as IT systems providers, platform providers, financial advisors, consultants including lawyers and accountants).
8.3 We work with third-party partners who help us provide and improve our services. We also impose strict restrictions on how our partners can use and disclose the data we provide. We may share information with third parties:
  • That you explicitly give consent to such collection, use or disclosure, or as required or permitted by law;
  • That help to complete transactions for you;
  • Service providers with whom CrowdForce has a contractual agreement with, which includes appropriate privacy standards and who do not retain, share, store or use personally identifiable information other than for the following purposes: (i) for the delivery of e-newsletters and related materials, (ii) to process credit card information for billing purposes, (iii) to perform functions such as data processing, database services or information technology support; (iv) providing customer service and/or (v) for marketing CrowdForce’s products or services;
  • To enforce our website’s Terms and Conditions of Use, to protect the safety and security of visitors and our websites, or to protect our rights, safety or property; and/or
  • Law enforcement agencies or investigative agencies or any competent regulatory or governmental agencies, if we are requested to do so by law, to assist in the prevention, detection or prosecution of money laundering activities, fraud or criminal activities or to comply with applicable laws, rules, regulations, court order or subpoenas.
8.4 Please note that some or all of the personal information that we collect may be stored or processed outside of Nigeria, data protection laws may differ from those in other jurisdiction in which you live. As a result, this information may be subject to access requests from the governments, courts, law enforcement officials and national security authorities in other jurisdictions according to the States’ laws. Subject to these laws, we will use reasonable efforts to ensure that the appropriate protections are in place to maintain protections on the personal information we collect.
8.5 We disclose to third parties only as much personal information as is required to perform the task they have been retained for. We will share personal information only with those who have agreed to follow our policies and share our high standards of privacy protection, in compliance with the applicable law.
8.6 When you are no longer our customer, we continue to share your information as described in this Privacy Policy.
8.7 We DO NOT SHARE your Personal Information with: (1) other financial companies for joint marketing purposes; (2) affiliated companies for their everyday business purposes; or (3) any third parties so they can market to you.

RETENTION OF DATA/INFORMATION OF USERS

9.1 The Company will retain your Personal Data only for as long as it is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
9.2 The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer periods.

STORAGE OF YOUR DATA

10.1 The information that we collect from you will be transferred to and stored on our secure cloud-based data storage, as well as in our office premises and a network accessible storage which includes external drives only for authorized users. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
10.2 We shall erase/delete personal data in the event of any of the following:
  • You withdraw your consent, object to the processing and/or there is no overriding lawful basis for the processing;
  • The personal data is no longer necessary in relation to the purposes for which they were collected or processed;
  • The personal data was unlawfully collected or processed in the first place; and
  • In compliance with the Nigerian Data Protection Regulation (NDPR) or any other lawful directive.

USERS’ DATA PROTECTION RIGHTS

11.1 If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
11.2 In certain circumstances, you have the following data protection rights:
  • The right to access, update or delete the information we have on you. Whenever possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete. You can do so by sending us an email.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent at any time where CrowdForce relied on your consent to process your personal information.

LINKS TO THIRD-PARTY WEBSITES

When you use our services, you may be directed to third party 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 strongly advise you to read the applicable privacy policies and terms and conditions of such websites. This Privacy Policy only applies to our services.

SECURITY OF DATA/INFORMATION OF USERS

13.1 The security of your data is important to us and we will strive to use commercially acceptable means to protect your Personal Data. Our website and mobile applications are scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
13.2 We maintain technical, and physical safeguards for our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, unauthorized access, disclosure or alteration.
13.3 The security measures include firewalls and data encryption which are only accessible by a limited number of persons who have special access right to our systems. We also maintain physical access controls to our premises, CCTV cameras for public safety and quality control as well as information access authorization controls.
All our transactions are processed through a gateway provider and are not stored or processed on our servers.
While we will ensure that your Personal Data is securely stored, bear in mind that no method of transmission over the internet or method of electronic storage is 100% secure and we cannot guarantee its absolute security.
In addition, you are responsible for securing and maintaining the privacy of your Personal Data and you must not share them with third parties. You agree to notify us immediately of any unauthorized use of your account or any other breach of security. 

NOTIFICATION OF CHANGES TO PRIVACY POLICY

CrowdForce reserves the right to modify or supplement this Policy at any time. All changes and revised version of the Privacy Policy shall be posted on our website and mobile applications so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we may disclose it. CrowdForce will always seek an individual’s consent if it intends to collect, use or disclose his or her personal information for purposes other than those to which the individual has consented unless otherwise required or permitted by law.

CONTACTING US

If there are any questions regarding this privacy policy or if you would like to access or correct any personal information that we hold regarding you, please feel free to reach out to us by sending an email to: legal@CrowdForce.io.