Privacy Policy

PRIVACY POLICY STATEMENT

Value Payment Solutions Limited (VALUEPAY) as a payment solutions service provider is centred on delivering value through innovation and exceptional user experience and therefore recognizes at all levels the need to ensure that its business operates smoothly and without interruption for the benefit of its customers, shareholders, and other stakeholders.

Value Payment Solutions Limited (VALUEPAY) is committed to protecting your privacy. Kindly visit our website www.valuepayng.com to see how our goals align with your privacy needs.

We at VALUEPAY respect your privacy and want you to understand how we collect, use, and share data about you. This Privacy Policy covers our data collection practices and describes your rights to access, correct, or restrict our use of your personal data.

Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use the Company’s website, mobile applications, APIs or related services (the “Services”).

By using the Services, you agree to the terms of this Privacy Policy. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services.

SCOPE

This End User Privacy Policy (“Policy”) describes how we collect information when you use our website, services, tools and application program interface (API) (collectively, “Services”) or otherwise interact with us to operate, improve, develop, and protect our services, and as otherwise outlined in this Policy.

We value transparency and want to provide you with a clear and concise description of how we treat your End User Information.

We may check the details you provide with fraud prevention agencies and share your information with them if we suspect fraud. It is important that you do not provide false, inaccurate information or impersonate another individual.

Please note that this Policy only covers Value Payment Solutions Limited. This Policy also does not cover any websites, products, or services provided by others. We encourage you to review the privacy policies or notices of developers or those third parties for information about their practices.

Value Payment Solutions Limited (“VALUEPAY”) (the “Data Processor and Controller”) provides online payment services for:

You, (the "Data Subject") (via the “VALUEPAY platform”); or
Relying parties (via the platform) and their users or customers. A Relying Party or Relying parties refers to businesses that require online payment services and who share your information with us through our platform through a formal agreement with Value Payment Solutions Limited (the "Relying Parties").

PERSONAL INFORMATION WE COLLECT FROM YOU

Personal information is data that can be used to identify or contact an individual.

By using our Services, you consent to the storage, usage and disclosure of your personal information including your nonpublic personal information (collectively referred to as “Personal Information”) either as Data Controller or in our capacity as Data Processor. By accessing or using the Services or otherwise providing information to us, you consent to the control and processing of the information by Value Payment Solutions Limited and Relying Parties.

We collect Personal Information from you for a number of reasons including processing your payment as a user of a Relying Party's service through the API platform or providing services on our own behalf through our Services. Your Personal Information is either supplied by the Relying Party to us, or captured through our Services, where you enter these details directly. If you provide Personal Information about other individuals (such as employees, dependents, etc.), you must obtain their consent prior to your disclosure to VALUEPAY. Any Personal Information we collect will be used strictly in accordance with current data protection legislation and this Privacy Statement.

INFORMATION YOU PROVIDE TO US DIRECTLY

Personal data of the relevant customers and partners can be processed in order to establish, execute and terminate a contract. Prior to a contract or during the contract initiation phase, personal data shall be processed to fulfil customer due diligence requirements prior to the contract conclusion.

INFORMATION WE MAY COLLECT FROM OTHER SOURCES

When a Data Subject or a Relying Party creates an account with us, we may collect information, including Personal Information, about you or your data subjects from nonaffiliated third-party service providers and statutory authorities in order to verify identities and for fraud prevention, including prior addresses, names and consistency of information across other identity documents. Personal Information collected may come directly from you, or through our affiliates or other third parties (such as employers, statutory authorities, etc.).

When we collect information from a Relying Party we ask them to ensure that they have the Data subjects consent to share the Personal Information and that they ensure compliance with this Privacy Statement.

INFORMATION WE MAY COLLECT WHEN YOU VISIT OUR WEBSITES

For purposes of this Privacy Statement, "website" includes our mobile applications.

By using our websites and associated microsites, you agree to the processing of your Personal Information as explained in this Privacy Statement, including the placement of cookies on your device.

Personal information is collected to fulfil your requests for products and services and to improve your online experience. We take steps to limit the amount of Personal Information collected to what is required to support the intended purpose of the collection.

VALUEPAY may ask you for some or all of the following types of information when you register for events, promotions, request services, manage accounts, access various content and features or directly visit our websites. The information includes, but is not limited to:

Contact Information: Name, Email Address, Postal Address, Phone Number, Mobile Number, Facsimile Number;
Financial/Billing Information: Name of Banking Institution, Credit Card Number, Account Number, Routing Number;
Communication Preferences such as newsletters you would like to receive;
Search Queries.

In some instances, VALUEPAY will automatically collect certain types of information when you visit our websites and through emails exchanged between VALUEPAY and the customer, or through our customer service chat. Automated technologies may include the use of web server logs to collect IP addresses, "cookies'' and web beacons. The collection of this information will allow us to improve the effectiveness of our websites and our marketing activities.

1. Mobile Devices:

If you access our websites on your mobile device, VALUEPAY may collect your unique device identifier and mobile device IP address, as well as information about your device's operating system, mobile carrier and your location information.

When you provide us your mobile phone number as your contact phone number, you consent to the use of your mobile phone number for the purposes identified in this Privacy Statement. If you choose to receive notifications from us on your mobile device (e.g. text notifications), you also consent to the use of your mobile phone number for that purpose.

2. Location Information:

We may obtain your location information from our Business Partners, or otherwise on our Services. We may also incorporate geo mapping into our Services, and you may consent to the collection of location information by the third party geo mapping service provider in connection with your use of the geo mapping service. Any information collected via your use of the geo mapping service should be transmitted directly through the geo mapping service provider and is not through VALUEPAY. Please refer to the geo mapping service provider' privacy policy for details about their collection, use and sharing of this information.

3. Links to Other websites:

Our websites may contain links to other sites which are outside our control and are not covered by this Privacy Statement. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their privacy policies. VALUEPAY is not responsible for the content or privacy practices of linked sites or any use of those sites.

Please be aware that VALUEPAY website may contain links to sites maintained by other organisations. We encourage you to review the privacy policy of each website you visit.

HOW WE GET DATA ABOUT YOU

1. Cookies and Similar Technologies

VALUEPAY collects information during your visit to the website through the use of cookie technology. A cookie is a piece of programming information contained in a very small text file that is placed in your internet browser or elsewhere on your hard drive. You can control acceptance of cookies by modifying your internet browser preferences. You have the ability to accept all cookies, to be notified when a cookie is set or to reject all cookies. Please note that, if you choose to block all cookies (including essential cookies) you may not be able to access all or part of our site and may be unable to use those services or engage in activities that require the placement of cookies. VALUEPAY uses cookies to distinguish you from other users of our website and also provide us with aggregated website usage statistics.

In addition, on some occasions, VALUEPAY may use tracking technologies such as web beacons, to collect information about your visits to our websites. These are small electronic images embedded in web content or e-mail messages and are ordinarily not visible to users. Like cookies, this tracking technology enables us to track pages and content accessed and viewed by users on VALUEPAY websites. The use of these technologies also helps us to provide you with a positive experience when you browse our websites, and it also helps refine our content and personalize your experience.

2. Information We Collect When You Engage With Us on Social Media

You can engage with VALUEPAY through social media websites or applications or through features such as plug-ins or applications on our websites that integrate with social media sites. You may also choose to link your account with us to third party social media sites. When you link your social media account, or engage with VALUEPAY on or through third party social media sites, plug-ins, or applications, you may allow VALUEPAY to have ongoing access to certain information from your social media account (e.g., name, e-mail address, photo, gender, birthday, the posts or the 'likes' you make).

If you post information when you interact with our Services through social media sites, plug-ins or other applications, depending on your privacy settings, this information may become public on the Internet. You can control what information you share through privacy settings available on some social media sites. For more information about how you can customise your privacy settings and how third party social media sites handle your personally identifiable information, please refer to their privacy help guides, privacy policies and terms of use.

3. Information We May Collect Through Third Party Advertising

We may allow others to provide analytics services on our behalf and to serve advertisements on our behalf across the internet. These Third-Party Advertising Partners may use cookies, web beacons and other technologies to display advertisements of our products to you when you are on other, third-party websites that are affiliated in some way with the advertising partners. The information collected and shared via cookies may contain Personal Information.

The Third-Party Advertising Partners may collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by VALUEPAY and others, to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising targeted to your interests and better understand your online activity.

HOW WE USE YOUR DATA

We use information to operate the Services, including:

1. To Process Your Requests to Administer Your Account and Provide the Services to You

As part of our verification process we will obtain electronic copies of your documents, financial data and credit reference files and this will be stored in a private area accessible only by VALUEPAY and to the extent that is necessary, the Relying Party.

This information may be disclosed to authorize Relying Parties through our credit referencing, fraud prevention, risk assessment and identification products. Personal Information in our possession shall only be used in accordance with this Policy Statement, in performing statistical analysis of users’ behaviour as a whole; and to help in the creation of anonymized statistical data which we may use at our discretion (including licensing to third parties).

VALUEPAY collects this information in a transparent way and only with the full cooperation and knowledge of interested parties. Once this information is available to us, the following rules apply:

Our data will be:

Accurate and kept up-to-date;
Collected fairly and for lawful purposes only;
Processed by VALUEPAY within its legal and moral boundaries; and
Protected against any unauthorized or illegal access by internal or external parties.

Our data will not be:

Communicated informally;
Transferred to organizations, states or countries that do not have adequate data protection policies; and
Distributed to any party other than the ones agreed upon by the data’s owner (exempting legitimate requests from law enforcement authorities).

VALUEPAY’s Business Partners are encouraged to:

Let people know which of their data is collected;
Inform people about how VALUEPAY will process their data; and
Inform people about who has access to their information.

2. To Share Your Information

We may disclose any information we collect as follows:

The Reporting Entity with whom you are establishing a relationship, applying for a financial product or service with and other similar organisations, or those that are nominated by you;
Government entities and other external data providers that hold information on you in order to verify that the information provided by you is consistent with the records held by such entities;
To financial service providers, including the financial institutions identified in your cardholder bank agreement that provide banking services in connection with your account;
To another user when you sign up for VALUEPAY’s services via a referral link. The user that referred you may receive information indicating that you have enrolled with VALUEPAY. You may avoid this sharing by not using a referral link to enroll;
To Business Partners, affiliated companies, and authorized service providers, we disclose Personal Information as is necessary to provide our Services. These service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements. We do not rent, sell or otherwise disclose Personal Information about our online visitors with unaffiliated third parties for their own marketing use;
With a non-affiliated third-party to access and transmit your personal and financial information from a relevant financial institution. You grant the third-party the right, power, and authority to access and transmit this information according to terms of their privacy policy;
With other non-affiliated companies for our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations or report to credit bureaus. For example, in connection with our everyday business purposes, we may share information about you as follows:

In response to a request for information, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process; With relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud; If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of VALUEPAY , or others; and

8. We may also share aggregated or de-identified Information, which cannot reasonably be used to identify you. For example, we may share transaction zip codes and merchant names with third parties to improve our accuracy in geo-locating transactions and to improve the clarity of transaction descriptions.

3. To Improve the Services and Develop New Ones

Administer focus groups and surveys;
Conduct research and analysis of Users’ behaviour to improve the Services;
Develop new features and services.

4. To Prevent, Detect and Fight Fraud or Other Illegal or Unauthorized Activities

Address ongoing or alleged fraud or other misbehaviour on or though the Services;
Analyze data to better understand and design countermeasures against fraud;
Retain data related to fraudulent activities to prevent recurrences.

5. To Ensure Legal Compliance

Comply with legal requirements;
Assist law enforcement;
Enforce or exercise our rights, for example our Terms of Service;
To process your information as described in this Privacy Policy, we rely on the following legal bases:

Legitimate Interests: We may use your information where we have legitimate interests to do so. For example, we analyse our Users’ behaviour to improve the Services, to prevent and detect fraud and misuse, and to market the Email Notifications to you.
Consent: From time to time, we may ask for your consent to use your information. You may withdraw your consent at any time by contacting us using the contact information provided above.

HOW WE SHARE YOUR INFORMATION

VALUEPAY takes reasonable steps to protect your Personal Information from misuse, loss, unauthorized access, modification or disclosure.

1. With our Affiliates

We share your information with our affiliates to help us with technical processing operations, such as data hosting and maintenance, client care, marketing and targeted suggestions, better understanding how the Services are used and Users’ behaviour to improve the Services, securing our data and systems, fighting against spam, abuse, fraud and intellectual property infringement.

2. When Required by Law

Applicable law may require us and our service providers to disclose your information if:

reasonably necessary to comply with a legal process, such as a court order, subpoena or search warrant, government investigation or other legal requirements; or
necessary for the prevention or detection of crime (subject in each case to applicable law).

3. To Enforce Legal Rights

We may also share information:

if disclosure would mitigate our liability in an actual or threatened lawsuit;
as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties;
to enforce our agreements with you; and
to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

4. With Your Consent or at Your Request

We may ask for your consent to share your information with third parties. When we do, we will make clear why we want to share the information.

We may collect and provide aggregate information about our Users (such as how many persons visited a particular page or activity or the likes and dislikes of our Users) to our advertisers, sponsors, promotional partners and affiliates but this aggregated information does not include personal information about any individual User.

OUR USE OF COOKIES

Our Websites use cookies and other tools.

A cookie is a small data file that contains a unique identification number that a website places on your hard drive when you visit a site. The cookie stores information about your computer, the type of browser you use, and how many times your computer visits a certain site. Cookies enable us to track how often Users are visiting our Websites and the specific pages visited, the number of entries in specific events, the estimated audience size for sponsors and advertisers, and other User preferences. You can refuse to use cookies by turning them off in your browser. You do not need to have cookies turned on to use most of the Website. However, you may find that some areas on the Website will be slower, or may not function at all, and you may not be able to participate in certain activities such as contests or sweepstakes if the cookies are disabled.

HOW WE PROTECT AND RETAIN INFORMATION

We use physical, technical and organizational measures designed to protect your information against unauthorized access, theft and loss. We restrict access to your personal information to those employees who need to know that information to service your account or perform their job functions.

All Relying Parties and agents are contractually bound to maintain the confidentiality of Personal Information and may not use the information for any unauthorized purpose.

VALUEPAY is committed to:

Restricting and monitoring access to sensitive data;
Developing transparent data collection procedures;
Training employees in online privacy and security measures;
Building secure networks to protect online data from cyber-attacks; and
Establishing data protection practices (document shredding, secure locks, data encryption, frequent backups, access authorization etc.).

Only employees who need the information to perform a required process are granted access to personally identifiable information to the extent that is necessary. The computers and hardware in which VALUEPAY stores personally identifiable information are kept in a secure environment.

We follow best practice industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. When you enter sensitive information (bank credentials, credit and card number) you should always use encrypted secure socket layer technology (SSL).

1. Data Retention

When we receive information regarding the customers (“Customers”) of a Relying Party and from verification of Business Partners in order to perform our Services. We shall do as follows:

a. Information received from Relying Party

VALUEPAY will obtain information from Relying Parties. VALUEPAY will use this data to verify the information provided by a Data Subject. Subsequent to the verification process, VALUEPAY will dispose of the data provided by the Relying Party.

b. Information Received From Data Subjects

VALUEPAY will collect information from Data Subjects on behalf of Relying Parties. VALUEPAY may use this information to query a Relying Party and verify the information against data provided by the Relying Party.

VALUEPAY may provide a copy of the information obtained from a Data Subject on behalf of a Relying Party to a Reporting Entity if required in accordance with identity verification reporting. VALUEPAY may retain information collected from the Data Subject for a brief period to enable auditing, after which VALUEPAY will remove the data from its systems.

c. Information Received From Reporting Entities

VALUEPAY will collect a Data Subject's information from a Reporting Entity. VALUEPAY may use this information to query Data Subject and verify the information against data provided by a Reporting Entity. The comparison may be done by VALUEPAY or the Reporting Entity.

VALUEPAY may retain information collected from Reporting Entities for the period allowed based on the statute of limitation of the jurisdiction or as is necessary to enable auditing. Following the brief period, VALUEPAY will remove the data from its systems.

If you believe that your account or information is no longer secure, please notify us immediately at contact@valuepay.ng.

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using the Websites);
Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them);
Whether retention is advisable; and considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).

YOUR CHOICES ABOUT YOUR INFORMATION

1. Information on VALUEPAY Database

If you would like to review, correct, update, suppress, restrict or delete personal information (including Personal Data as defined in the PRIVACY SHIELD section below) that you have previously provided to us, or if you would like to receive an electronic copy of your personal information for purposes of transmitting it to another company (if this right to data portability is provided to you by law), you can contact us at :

Email: contact@valuepay.ng or;

Write to us at:

Value Payment Solutions Limited

Attn: Privacy/Legal Team,

Address: House 55, 6th Avenue Gwarinpa II, Abuja, Nigeria.

In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database, or other limitations you would like to put on our use of your personal information. For your protection, we only fulfil requests for the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we often need to retain certain data for recordkeeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion. Our databases and other records may have residual data which will not be removed. In addition, we also may not allow you to review certain data for legal, security or other reasons. If at any time you believe that the Services have not adhered to this Privacy Policy, please let us know. We will use good faith efforts to determine and correct the problem.

2. Children’s Privacy

VALUEPAY respects the privacy of your child and we want to share with you our policies regarding children under the age of sixteen (16). Although Users of all ages may navigate through the Services, we do not knowingly collect personal information from anyone under age sixteen (16). If we learn that a child under age sixteen (16) has improperly provided us with information, we will notify the child’s parent or legal guardian and thereafter delete the child’s personal information from our records.

3. Links to Other Websites And Services

The Services may include links to third-party websites and services that are not operated by us. When you click these links, you will be directed away from the Services. A link to a third-party website or service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a third-party website or service, you are subject to its privacy practices and policies, not ours. VALUEPAY does not guarantee and is not responsible for the privacy or security of these third-party external websites, or for any information represented in these websites.

CROSS-BORDER DATA TRANSFERS

Value Payment Solutions Limited is headquartered in Abuja, Nigeria. Our Data Privacy is governed by the Nigerian Data Protection Laws, European Union Data Protection Regulations and the Data Protection Regulations of the jurisdictions in were our services are used. Sharing of information sometimes involves cross-border data transfers to or from Africa and other jurisdictions. By visiting or using our Services, you consent to storage of your data on servers located in our host countries. We use the European Union Data Protection Privacy Shield and standard contractual clauses approved by our host countries to validate transfers of foreign residents’ personal information from and to various countries. For more information about our Privacy Shield certification, please read the PRIVACY SHIELD section below.

PRIVACY SHIELD

VALUEPAY complies with the Nigerian Data Protection Privacy (“Privacy Shield Frameworks“) as set forth by the Nigerian Information Technology Development Agency regarding the collection, use and retention of Personal Data (as defined below) transferred from Nigeria to Foreign countries. VALUEPAY has certified that it adheres to the Privacy Shield Principles with respect to such Personal Data. If the policies in this Privacy Shield Policy and the data subject rights under the Privacy Shield Principles conflict, the Privacy Shield Principles shall govern.

To learn more about the Privacy Shield program, please visit:

https://nitda.gov.ng/wp-content/uploads/2019/01/Nigeria%20Data%20Protection%20Regulation.pdf

With respect to Personal Data received or transferred pursuant to the Privacy Shield Frameworks, VALUEPAY is subject to the regulatory enforcement powers of the Nigerian Information Technology Development Agency.

1. DEFINITIONS

In this PRIVACY SHIELD section:

“Database” means a collection of data organized in a manner that allows access, retrieval, deletion and procession of that data; it includes but not limited to structured, unstructured, cached and file system type databases;

“Foreign Country” means other sovereign states, autonomous or semi-autonomous territories within the international community;

“Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; It can be anything from a name, address, a photo, an email address, bank details, posts on social networking websites, medical information, and other unique identifier such as but not limited to MAC address, IP address, IMEI number, IMSI number, SIM and others;

“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;

“Third Party” means any natural or legal person, public authority, establishment or any other body other than the Data Subject, the Data Controller, the Data Administrator and the persons who are engaged by the Data Controller or the Data Administrator to process personal data.

2. PRIVACY SHIELD PRINCIPLES

VALUEPAY commits to processing Personal Data in accordance with the Privacy Shield Principles as follows:

1. Notice

Prior to collecting Personal Data, VALUEPAY notifies Foreign Users about the categories of Personal Data that VALUEPAY collects and the purposes for collection and use of their Personal Data. VALUEPAY will only process Personal Data in ways that are compatible with the purpose for which the Company collected it or for purposes later authorized.

We use the Personal Data that we collect from Foreign Users of the Services as described in our Privacy Policy. Before VALUEPAY uses Personal Data for a purpose that is materially different from the purpose for which VALUEPAY collected it or that was later authorized; VALUEPAY will provide Foreign Users with the opportunity to opt out.

2. Choice

If the Company collects Sensitive Personal Data, we will obtain explicit opt-in consent whenever Privacy Shield requires. VALUEPAY will obtain opt-in consent before Personal Data is disclosed to third parties other than those described in our Privacy Policy, before Personal Data is used for a different purpose than that purpose for which it was collected or later authorized, and whenever Privacy Shield requires.

Please see the YOUR CHOICES ABOUT YOUR INFORMATION section in our Privacy Policy for more information about how to exercise your choices.

3. Accountability for Onward Transfer

VALUEPAY shares Personal Data collected through the Services as described above.

If VALUEPAY transfers Personal Data to a third-party, VALUEPAY takes reasonable and appropriate steps to ensure that each third-party transferee processes Personal Data transferred in a manner consistent with VALUEPAY’s obligations under the Privacy Shield Principles. VALUEPAY will ensure that each transfer is consistent with any notice provided to Foreign Users and any consent they have given. VALUEPAY requires a written contract with any third party receiving Personal Data that ensures that the third party;

processes the Personal Data for limited and specified purposes consistent with any consent provided by Foreign Users,
provides at least the same level of protection as is required by the Privacy Shield Principles,
notifies VALUEPAY if it cannot comply with Privacy Shield; and
Ceases processing Personal Data or takes other reasonable and appropriate steps to remediate.

As noted above, under certain circumstances, VALUEPAY may be required to disclose Personal Data in response to valid requests by public authorities, including for national security or law enforcement requirements.

VALUEPAY remains liable under the Privacy Shield Principles if an agent processes Personal Data in a manner inconsistent with the Principles unless the Company is not responsible for the event giving rise to the damage.

4. Security

VALUEPAY takes appropriate measures to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration, unavailability and destruction. In determining these measures, the Company considers the risks involved in the processing and the nature of the Personal Data.

5. Data Integrity and Purpose Limitation

VALUEPAY takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete and current. VALUEPAY adheres to the Privacy Shield Principles for as long as it retains Personal Data in identifiable form. VALUEPAY takes reasonable and appropriate measures to comply with the requirement under the Privacy Shield to retain Personal Data in identifiable form only for as long as it serves a purpose of processing.

VALUEPAY limits the collection of Personal Data to information that is relevant for processing. VALUEPAY does not process Personal Data in a way that is incompatible with the purpose for which it was collected or subsequently authorized by a Foreign User.

6. Access

A Foreign User has the right to access his or her Personal Data and to correct, amend, limit use of or delete the Personal Data if the Personal Data is inaccurate or processed in violation of the Privacy Shield Principles. VALUEPAY is not required to grant the rights to access, correct, amend and delete Personal Data if the burden or expense of providing access, correction, amendment or deletion is disproportionate to the risks to the Foreign User’s privacy or if the rights of persons other than the Foreign User are or could be violated.

Please see the YOUR CHOICES ABOUT YOUR INFORMATION section in our Privacy Policy for more information about how to exercise your choices.

7. Recourse, Enforcement, and Liability

In compliance with the Privacy Shield Principles, VALUEPAY commits to resolve complaints about your privacy and our collection or use of your Personal Data transferred to Nigeria pursuant to the Data Protection Regulations. Foreign individuals with Privacy Shield inquiries or complaints should first contact VALUEPAY at contact@valuepay.ng

If your Privacy Shield complaint cannot be resolved by other redress mechanisms VALUEPAY has further committed to refer such unresolved complaints under the Privacy Shield Principles to Alternative Dispute Resolution mechanism, Lagos Court of Arbitration, Nigeria and its proceedings will be governed by the Nigerian Arbitration Laws.

VALUEPAY commits to periodically review and verify its compliance with the Privacy Shield Principles and to remedy any issues arising out of failure to comply with the Privacy Shield Principles.

UPDATES AND MODIFICATIONS TO THIS PRIVACY POLICY

From time to time, we may update this Privacy Policy. If we make any material change to it, we will notify you via email, through a notification posted on the Services, or as required by applicable law. We will also include a summary of the key changes. Unless stated otherwise, modifications will become effective on the day they are posted.

As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.

a. Interpretation

Any capitalized terms not defined in this policy are defined as specified in VALUEPAY’s Terms of Use. Any version of this Privacy Policy in a language other than English is provided for convenience. If there is any conflict with a non-English version, you agree that the English language version will control.

b. Contact Us

If you have any questions, concerns, or disputes regarding our Privacy Policy, please feel free to contact our privacy team (including our designated personal information protection manager) at:

Email: contact@valuepay.ng or;

Write to us at: