Introduction

Personal information is as important to us as it is to you, At Perophs Investments Limited (“Perophs”) we are committed to protecting your information. By ‘your information’ we mean any information provided to us by you or a third party in relation to the Vested Software Application (“Vested App”). We will only process information where we have obtained your explicit consent or are otherwise lawfully permitted to do so. 

The purpose of this Privacy Notice is to explain how personal information is collected and processed via the Vested App in connection with our business.  “Personal information” means information about a living individual who can be identified from that information (either by self or when it is combined with other information). We may update our Privacy Notice from time to time. When we do we will communicate any changes to you and publish the updated Privacy Notice on our website or through the Vested App. We would encourage you to visit our website regularly to be aware of the purposes for which we process your information and your rights to control how we process it. 

This privacy notice (the “Privacy Notice” or “this notice”) relates to all personal information processing activities carried out by Perophs in relation to the Vested App. Perophs is a data controller of personal information collected and processed for our business (including the products and services that we provide) via the Vested App. In this notice, references to “we”, “us” or “our” refers to Perophs while “you” and “your” means any business customer or partner (which includes suppliers or other organisations we do business with). In the case where an account, product  or  service  has more than one holder, owner or signatory, “you” or “your” can refer to any, both or all of you. 

Our contact details are as follows:  

Email – [email protected]  

Head Office – UAC House, (4th Floor), 1/5 Odunlami Street, Lagos.

Information Processed

We collect and process various categories of personal information at the start of, and for the duration of, your relationship with us. We will restrict the collection and processing of information to information necessary to achieve one or more legitimate purposes as identified in this notice. Personal information may include: 

• Basic personal information,  including but not limited to: first name, last name, gender, phone number, date of birth / age, address / postal address, email, country code, city. 
• Financial information, including account and transactional information and history, bank details, account number, transaction records etc. 
• Information about your family, lifestyle and social circumstances (such as dependents, marital status, next of kin and contact details) 
• Information about your financial circumstances, including personal wealth, assets and liabilities, Proof of income and expenditure, credit and borrowing history and needs and goals
• Goods and services provided
• Visual images and personal appearance (such as copies of passports or CCTV images)
• Online profile and social media information and activity, based on your interaction with us and our websites and applications, including for example, your banking profile and login information, internet Protocol (IP) address, smart device information, location coordinates, online and mobile banking security authentication, mobile phone network information, searches, site visits and Spending patterns 

Information Collected

We may collect personal information about you (or your business) from affiliates and any of these sources : 

• Information you give to us through our various touchpoints (i.e. information uploaded on our Vested App, website, Paper Forms, etc.); 
• Information that we gather from publicly available sources, such as the press, company registers and online search engines; 
• Information that we receive from third parties — third parties who provide services to you or us, credit reference, fraud prevention or government agencies, and other banks or licensed financial institutions; 
• Information that we learn about you when you use our services; 
• Information that we gather from the technology which you use to access our services (for example location data from your mobile phone, or an  IP address or telephone  number)  and how you use it (for example pattern recognition); 
• Information we collect from your device (i.e. phone contacts) are uploaded to enable you perform transactions seamlessly such as purchase airtime, data and send money to contacts on Vested; 

Your Rights

Subject to applicable laws and the applicable data  protection laws including the Nigeria Data Protection Regulation 2019 as may be amended from time to time you have the following rights in relation to the information that we collect from you through the Vested App and other media :

a) To request a copy of the personal data processed in relation to you 

b) To request that we correct your personal data 

c) To request us to delete your personal data, for example if we no  longer  have  a  valid reason to process it

d) To object to how we process your personal data

e) To restrict how your personal data is processed in certain cases, such as when the accuracy of your Personal Data is contested 

f) To request a copy of the personal data you have given to us in a machine-readable format

Information Usage

We may use the information we collect from you when you register on the Vested App, subscribe for a product or service, sign up for our newsletter, respond to a survey or marketing communication, surf the Vested App, create a virtual account, electronic wallet or use other features of the Vested mobile application in the following ways: 

• To manage our relationship with you or your business; 
• To manage and provide  savings, investment, and credit products and services; 
• To communicate with you about our products and services; 
• Personalize your experience; 
• To manage how we work with other companies that provide services to us and our customers; 
• Transaction processing and customer profiling; 
• Being efficient about how we fulfill our legal and contractual duties;
• To detect, investigate, report, and seek to prevent financial crime; 
• To manage risk for us and our customers; and 
• To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, adding and testing systems and processes, managing communications, corporate governance, and audit.

Information Sharing

We will share your personal information if and only if there is a legal basis for doing so. We will NOT disclose your personal information to anyone except:

• Consent is provided 
• Required by law 
• Required by court orders or legal process 
• Violation  of any  part of our  Privacy Notice
• Third parties conducting business on our behalf. These parties process such information for specific and limited purposes, in compliance with the privacy notice and any other appropriate confidentiality and security measures.  

Sensitive Personal Data

Sensitive personal data (also known as Special categories of personal data) make up information we collect from you. In particular, we may process, biometric data, for services that require it. We process such sensitive personal data when you have provided your consent or otherwise required by applicable law and this information will be collected and processed only for the particular purposes and activities for which the information is provided. 

Information Retention

Perophs will retain the information provided based on the nature of activity, the type of record, product or service, applicable legal and regulatory requirements. The retention period may be changed. We will keep your personal data for as long as we have a relationship with you. Once our relationship with you has come to an end (e.g. following closure of your account or following a transaction), or your application for a product is declined or you decide not to go ahead with it, we will only retain your personal data for a period of time that is, depending on the type of personal data, and the purposes for which we hold that information. Also, the retention period will be in line with the requirements of regulatory bodies in Nigeria

Information Protection

We implement a variety of security measures to maintain the safety of your personal information. Any data (including personal information) will be collected and stored on secure file servers. 

Why We Collect Your Data (Legal Basis)  

Cookies

Cookies are small text files containing information which your computer or mobile device downloads when you visit a website, return to websites — or visit websites that use the same cookies — they recognize these cookies and therefore your browsing device. We do not store confidential or sensitive personal information in cookies. 

 To find out more about how we use cookies and what benefits they bring, please take a few moments to read this Cookie Policy.

Why and How We Use Cookies on Our Website

We use cookies to improve your online activity session by making navigation easier and providing important security features. 

We use Google Analytics to collect the following types of information from users who have JavaScript enabled on their browser: 

• Web browser used — software manufacturer, and version number 
• Operating system
• Screen colours
• JavaScript support 
• Flash version 
• Screen resolution 
• Network location and IP address may include 
  • geographic data 
  • Hostname 
  • Connection bandwidth 
  • Time of visit 
  • Pages visited and dwell time on these pages 

• Referring site 
  • The  referring  website URL 
  • Search engine query used 

Google Analytics data is shared with Google. For more information on Google’s Privacy Policies, visit https://policies.poople.com/privacy. 

Cookie Category

Some cookies are needed to make our website work, but we need your consent to use others. The cookie categories are; 

We do not use third party cookies on our website. 

What are your choices regarding cookies

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. This can be done in your browser  settings.  Since browsers differ, we recommend that you access the Help Menu to learn the correct way to modify your cookies. 

If you turn your cookies off, some of the features that make your site experience more efficient may not function properly. 

Where you can find more information about cookies

You can learn more about cookies at http://www.allaboutcookies.orp/ 

Changes to This Privacy Notice 

Based on the changing nature of privacy laws, user needs and our business, this privacy notice may be updated from time to time. Any change to our Privacy Notice will be communicated on our website or the Vested App, and this will be effective as soon as published. Accordingly, we encourage periodic reviews of this Privacy Notice for awareness of any changes that may have occurred.

Consent

We will provide you with our privacy policy whenever we are collecting your personal information irrespective of the medium being used. Your consent will be obtained by asking you to click on a button to show acknowledgement of the policy if the medium being used to collect your personal information is in an electronic format. If your personal information is being collected through a paper document, we will ask you to sign off on the document showing your understanding of our privacy policy. 

Contact us

Perophs is committed to resolving your privacy complaints and concerns as quickly as possible. If you have a concern, complaint or questions regarding this Privacy Notice, or you are concerned about an alleged breach of privacy law or any other regulation by Perophs, you may contact us through the following means: [email protected] . Our Data Protection Officer will investigate your complaint and give you information about how it will be handled.  

Email us at: [email protected]

 You also have the right to complain to the data protection authority in Nigeria – Nigeria Data Protection Bureau or refer the matter to a court of competent jurisdiction or as specified in any applicable engagement agreement with Perophs. 

Website Address: https://ndpb.gov.ng/