This privacy and data protection policy (the policy) will explain how the website uses the personal data we collect from our customers and related partners when they use our website. It describes our commitment to treat your information with the utmost care and confidentiality and explains your privacy rights regarding CELD INNOVATIONS Limited’s (“CELD INNOVATIONS”, “we”, “us” or “our”) collection, use, storage, sharing and protection of your personal information. 

This Privacy Policy describes a user’s privacy rights regarding our collection, use, storage, sharing and protection of personal information. It applies to the website and all related sites, applications, services and tools regardless of how they are accessed or used. This Policy does not apply to services that are not owned or controlled by CELD INNOVATIONS, including third-party websites and the services of other CELD INNOVATIONS’s merchants that maybe accessible through links which are present on our website and all related sites, applications, services and tools. You are encouraged to review the privacy policy of such merchant or third party.

We conduct business in a responsible and sustainable manner and ensure customer information is securely collected, processed, and stored based on business requirements. In furtherance of this and compliance with industry regulations, we have provided appropriate documentation, which includes this policy. We therefore provide notice about this policy and applicable procedures.

Throughout this Privacy Policy, we use the term “personal information or data” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been made anonymous such that it does not identify a specific user.

To use our website or any of our products or services, your consent is required for the use of your data as described in this Policy.

This Privacy Policy is intended to set certain standards across the operations of CELD INNOVATIONS Innovations Limited.

1. The Information we Collect

As part of our operations, CELD INNOVATIONS may collect and processes certain types of personal identifiable information (such as Name, email address, phone number, contact address, limited financial information, location data, device data, etc.) of individuals which include current, past and prospective employees, merchants, suppliers/vendors, customers of merchants, Users and other individuals whom CELD INNOVATIONS communicates or deals with, jointly and/or severally (“Data Subject(s)”).

• We use your Personal Information to:
• Provide you with the required services;
• Respond to your questions or requests;
• Improve features, website content and analyse data to develop products and services;
• Address inappropriate use of our website;
• Prevent, detect and manage risk against fraud and illegal activities using internal and third party screening tools;
• Send you marketing content, newsletters and service updates created by CELD INNOVATIONS, however, we will provide you with an option to unsubscribe if you do not want to hear from us;
• Verify your identity and the information you provide in line with CELD INNOVATIONS’s statutory obligations using internal and third party tools;
• Maintain up-to-date records;
• Resolve disputes that may arise, including investigations by law enforcement or regulatory bodies;
• Any other purpose that we disclose to you in the course of providing CELD INNOVATIONS’s services to you.

We may retrieve additional Personal Information about you from third parties and other identification/verification services such as your financial institution and payment processor. With your consent, we may also collect additional Personal Information in other ways including emails, surveys, and other forms of communication.

Once you begin using our services through your CELD INNOVATIONS account we will keep records of your transactions and collect information of your other activities related to our services. We will not share or disclose your Personal Information with a third party without your consent except as may be required for the purpose of providing you with our services or under applicable legislations.

In providing you with the services, we may rely on third-party servers located in foreign jurisdictions from time to time, which as a result, may require the transfer or maintenance of your personally identifiable information on computers or servers in foreign jurisdictions. We will endeavour to ensure that such foreign jurisdictions have data protection legislation that is no less than the existing data protection regulations in force in Nigeria and your personally identifiable information is treated in a safe and secure manner.

• Purpose Limitation

CELD INNOVATIONS collects Personal Information only for identified purposes and for which consent has been obtained. Such Personal Information cannot be reused for another purpose that is incompatible with the original purpose, except consent is obtained for such purpose

• Data Minimization

CELD INNOVATIONS limits Personal Information collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed.

CELD INNOVATIONS will evaluate whether and to what extent the processing of Personal Information is necessary and where the purpose allows, anonymized data will be used.

• Updates, Modifications & Amendments

We may need to update, modify or amend our Privacy Policy as our technology evolves and as required by law. We reserve the right to make changes to this Privacy Policy from time to time and notify Users of material changes. The Privacy Policy will apply from the effective date provided on our website.

We advise that you check this page often, referring to the date of the last modification on the page. If a User objects to any of the changes to this Privacy Policy, the User must cease using this Site, or terminate their account in the event an account has been created.

• Age Restriction

Our website and services are not directed to children under 18. We do not knowingly collect information from children under 18. If as a parent or guardian, you become aware that your child or ward child has provided us with any information without your consent, please contact us through the details provided in this Privacy Policy.

• Cookies

We use cookies to identify you as a User and make your user experience easier, customise our services, content and advertising; help you ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our website. Cookies allow our servers to remember IP addresses, date and time of visits, monitor web traffic and prevent fraudulent activities.

Our cookies never store personal or sensitive information; they simply hold a unique random reference to you so that once you visit the site we can recognize who you are and provide certain content to you.

If your browser or browser add-on permits, you have the choice to disable cookies on our website, however this may impact your experience using our website.

• How We Protect your Information

CELD INNOVATIONS shall establish adequate controls in order to protect the integrity and confidentiality of Personal Information, both in digital and physical format and to prevent Personal Information from being accidentally or deliberately compromised. CELD INNOVATIONS is committed to managing your Personal Information in line with global industry best practices and in compliance with regulatory requirements. We store and process your personal information on our computers in Lagos, Nigeria and anywhere else where our facilities are located. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration.

Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorization controls. We have also taken additional measure by ensuring our system complies with industry information security standards.

Employees may have access to Personal Information only as is appropriate for the type and scope of the task in question and are forbidden to use Personal Information for their own private or commercial purposes or to disclose them to unauthorized persons, or to make them available in any other way.

• Marketing and sharing Personal Information

CELD INNOVATIONS does not sell, trade or rent personal information to anyone. However, to enable us render our services to you on our website, we may share your information with trusted third parties, such third parties include financial institutions, payment processors, verification services, sanctions screening and identity verification services as well as any third parties that you have directly authorized to receive your Personal Information. Your Personal Information may be stored in locations outside the direct control of CELD INNOVATIONS, for instance, on servers or databases co-located with hosting providers.

We may disclose your Personal Information in compliance with applicable law or a legal obligation to which we are bound.

The use of your information by such third party will be subject to their applicable privacy policy, which you should carefully review.

2. Grounds for Processing of Personal Information

Processing of Personal Information by CELD INNOVATIONS shall be lawful if at least one of the following applies:

• the Data Subject has given consent to the processing of his/her Personal Information for one or more specific purposes;
• the processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which CELD INNOVATIONS is subject;
• processing is necessary in order to protect the vital interests of the Data Subject or of another natural person; and
• processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in CELD INNOVATIONS.

For the purpose of this Privacy Policy, consent means any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which they, through a statement or a clear affirmative action, signify their agreement to the processing of Personal Information relating to them.

3. Choices and Rights

Individuals who have Personal Information held by CELD INNOVATIONS are entitled to reach out to CELD INNOVATIONS to exercise the following rights:

• Right to request for and access their Personal Information collected and stored. Where data is held electronically in a structured form, such as in a Database, the Data Subject has a right to receive that data in a common electronic format;
• Right to information on their personal information collected and stored;
• Right to objection or request for restriction;
• Right to object to automated decision making;
• Right to request rectification and modification of Personal Information which CELD INNOVATIONS keeps;
• Right to request for deletion of their data;
• Right to request the movement of data from CELD INNOVATIONS to a third party; this is the right to the portability of data; and
• Right to object to, and to request that CELD INNOVATIONS restricts the processing of their information

Your request will be reviewed by CELD INNOVATIONS’s Data Protection Officer and carried out except as restricted by law or CELD INNOVATIONS’s statutory obligations. You may decline to provide your personal Information when it is requested by CELD INNOVATIONS, however, certain services or all the services may be unavailable to you. You may review your account settings and update your Personal Information directly or by contacting us.

4. The Data that We Retain

We will retain your information for as long as your account is active or as needed to provide our services to you, comply with our legal and statutory obligations or verify your information with a financial institution.

CELD INNOVATIONS is statutorily obligated to retain the data you provide us with in order to process transactions, ensure settlements, make refunds, identify fraud and in compliance with laws and regulatory guidelines applicable to us, our banking providers and card processors.

Therefore, even after closing your CELD INNOVATIONS account, we will retain certain Personal Information and transaction data to comply with these obligations. All Personal Information shall be destroyed by CELD INNOVATIONS where possible. For all Personal Data and records obtained, used and stored by CELD INNOVATIONS, we shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity and requirement to retain.

The length of storage of Personal Informaiton shall, amongst other things, be determined by relevant legislation

5. Transfer of Personal Information

CELD INNOVATIONS may engage the services of third parties in order to process the Personal Information of Data Subjects collected by the CELD INNOVATIONS. The processing by such third parties shall be governed by a written contract with CELD INNOVATIONS to ensure adequate protection and security measures are put in place by the third party for the protection of Personal Information in accordance with the terms of this Privacy Policy.

• Transfer of Personal Information to Foreign Country

Were Personal Information is to be transferred to a country outside Nigeria, the United States, the United Kingdom and the European Union, CELD INNOVATIONS shall put adequate measures in place to ensure the security of such Personal Information. In particular, CELD INNOVATIONS shall, among other things, confirm whether the country is on the National Information Technology Development Agency (“NITDA”) and General Data Protection Regulation (GDPR) White List of Countries with adequate data protection laws.

Transfer of Personal Information out of Nigeria, the United States, the United Kingdom and the European Union would be in accordance with the provisions of the Nigeria Data Protection Regulation and General Data Protection Regulation. CELD INNOVATIONS will therefore only transfer Personal Information out of Nigeria, the United States, the United Kingdom and the European Union on one of the following conditions:

• The consent of the Data Subject has been obtained;
• The transfer is necessary for the performance of a contract between CELD INNOVATIONS and the Data Subject or implementation of pre-contractual measures taken at the Data Subject’s request;
• The transfer is necessary to conclude a contract between CELD INNOVATIONS and a third party in the interest of the Data Subject;
• The transfer is necessary for reason of public interest;
• The transfer is for the establishment, exercise or defense of legal claims;
• The transfer is necessary in order to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent.

CELD INNOVATIONS will take all necessary steps to ensure that Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside Nigeria, the United States, the United Kingdom and the European Union shall be provided to you upon request.

6. Contact CELD INNOVATIONS’s Data Protection Officer (DPO)

If you have any questions relating to this Privacy Policy or would like to find out more about exercising your data protection rights, please reach out to our DPO via email at abiola@cashtoken.africa

CELD INNOVATIONS maintains a data breach procedure in order to deal with incidents concerning Personal Information or practices leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information transmitted, stored or otherwise processed.

You may contact our DPO upon becoming aware of any breach of Personal Information or if your access credentials have been compromised, to enable us to take the necessary steps towards ensuring the security of your Personal Information or account.