GENIUS BY PETTYSAVE - Privacy Policy

1. CONSENT

By downloading the Genius App by PettySave ("the App"), visiting our website and agreeing to our Terms and Conditions, or performing any other activity that form part of our business (digitally or non-digitally), you confirm that you have read, understood and accepted the terms of this Privacy Policy set out hereunder. You also consent to the following:

• That we can provide materials and other information about your legal rights and duties to you electronically.
• That we are authorized to share, receive, and use data/information collected from your transaction with other affiliated third parties.
• That your electronic signature on agreements and documents has the same effect as if you signed them using ink on paper or any other physical means.
• That we can send all important communications, billing statements, and demand notes and reminders to you electronically via our app or to an email address that you provide to us. When we send you such information/data electronically and/or make it available online as indicated above, that shall have the same meaning and effect as if we provided said information/data to you physically.
• For the avoidance of doubt, approval of the credit facility under this Agreement is conditional upon the validation of your bank verification number (BVN) and verification of other creditworthiness using your credit score, transaction history through your bank statements, among others. This offer will be rescinded, and the approval for the credit facility will not be successful if the BVN validation and other verification checks are unsatisfactory.
• To ensure effective service delivery, uphold quality standards, and protect the interests of our users, all communications between merchants and customers conducted through our platform will be monitored and reviewed by our administrators. This helps us verify that merchants are acting in accordance with our policies and delivering services properly.
• By using our platform, you consent to such monitoring for the purposes of dispute resolution, quality assurance, and compliance enforcement.
• We may request access to your phone contacts when you request to purchase airtime either for self-use or a third party. We may also keep a record of our correspondence with you in order to assist you in the future.
• We may also collect Personal Information from you offline, such as call recording and chat transcript data when you contact our sales and customer representative teams or contact information when you attend or participate at any of our events or webinars.
• Such consent can be withdrawn at any time, provided always that such withdrawal will not affect the legality and binding effect of the processing of your personal information before the consent given was withdrawn.

2. LINKED WEBSITES

Other websites that may be linked to us are not governed by this Privacy Policy. You are advised to review the privacy policies on each of the websites before disclosing any personal information.

This Privacy Policy includes the following matters:

• Definition
• Personal Information which we collect
• Information obtained from you or from your mobile device directly
• Information collected from you when you use the app
• Collection of locations
• Sharing of Personal Information, which we collect
• Security of your Personal Information
• Changes to this Privacy Policy
• Language
• Acknowledgement and consent
• Marketing and promotional material
• Third-party websites
• Governing laws
• How to contact us

3. DEFINITION

Unless otherwise defined, all capitalized terms used in this Privacy Policy shall have the same meanings ascribed to them in our Terms and Conditions (as applicable).

• "Applicable Law" means all national and international legislations, regulations, circulars, guidelines that govern this Privacy Policy or any activities done by us in the processing of your personal information. It shall include, without limitations, the Nigeria Data Protection Act, 2023, the Nigeria Data Protection Regulation, 2019, the Money Laundering (Prevention and Prohibition) Act, 2022 etc.
• "Processing" means the collecting, handling, protecting, and storing of your personal information. It shall include the need and manner of disclosure of your personal information to third parties (including without limitation, our service providers and credit rating agencies).
• "You" means all users of the App, including persons that have downloaded the app, visited the website, or performed any activity that forms part of our business.

4. PERSONAL INFORMATION WHICH WE COLLECT

We collect certain Personal Information about you in various forms. The Personal Information which we collect may be provided by you directly (for example, when you open an Account to use the Service via the App, or you otherwise provide Personal Information to us in a form on our app or website) or by third parties (including but not limited to your employer, providers of "Know-Your-Client" and anti-money laundering services, background check providers, your banks and financial institutions, credit rating and reference providers etc.), or collected by corresponding with us via email or chat, or be collected automatically when you use the App. We may collect information in various forms and for various purposes (including purposes permitted under Applicable Law).

We may use the Personal Information collected from you to:

• Improve our services;
• Exercise our rights under contracts with you, including collecting any amounts due from you;
• Conduct verification or credit checks and reviews on you, obtain or provide credit references, or detect fraudulent applications;
• Provide you with marketing information (you may opt-out by clicking the "unsubscribe" button in our emails or by contacting us);
• Comply with compulsory or voluntary requirements that we have such as legal, tax, regulatory, sanctions or market requirements in Nigeria and overseas;
• Monitor, prevent and detect fraud, enhance our systems' security, monitor and verify identity or access, and combat spam or other malware or security risks;
• Meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms; and
• Fulfil other purposes disclosed at the time you provide Personal Information or otherwise where we are legally permitted or are required to do so.

Information obtained from you or from your Mobile Device directly:

• When you register and create an Account with us using the App, you have to provide certain Personal Information, including (without limitation) your name, age, date of birth, gender, photo, physical home address, e-mail address, working information, emergency contact, your phone number, country of residence, employment details, financial and credit information (including your bank account details, bank verification number, and bank statements where applicable) and an Account ID and/or password amongst others.
• When you use the App, you must provide such relevant information as may reasonably be required by us for the App to work.

Information collected whenever you use the App:

• Whenever you use the App, we may collect certain technical data concerning your usage such as, internet protocol (IP) address, information as webpages previously or subsequently viewed, duration of every visit/session, the internet device identity (ID) or media access control address, and also information regarding the manufacturer, model and operating system of the device that you use to access the App.
• Whenever you use the App, certain information may also be collected on an automated basis using cookies. Cookies are small application files stored on your computer or Mobile Device. We use cookies to track user activity to enhance user interface and experience.
• You agree to provide the information stated above because they are mandatory requirements of the Central Bank of Nigeria, the regulator of our business.
• You will be required to provide technical information to us while using the App, including the type of Mobile Device you use, a unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting.

Collection of Location

We collect your geo-location information when the App is running in the foreground. We endeavor to cease collection of your geo-location information when the App is in the background, but such information may still be collected unintentionally. You can always choose to disable the geo-location tracking information on your Mobile Device temporarily. However, this may affect the functionalities available on the App.

Information Sharing with Third Parties

Upon the initiation or completion of any transaction, and in the course of providing services that you have requested or authorized, we may share your Personal Information with relevant third parties, including:

• Credit bureaus and bodies responsible for verifying Know-Your-Customer (KYC) information;
• Our financial partners who support our operations;
• Persons providing guarantees or security for your obligations;
• Other third parties as may be necessary for the performance of a contract, the fulfilment of legal or regulatory requirements, or the enforcement of our rights under applicable agreements and policies.

When we share your Personal Information with such third parties, we require them to enter into a Third-Party Data Processing Agreement with us. This agreement obliges them to process your Personal Information in accordance with this Privacy Notice, the Nigerian Data Protection Act (NDPA), and other applicable data protection laws.

Storage

We require the storage information permission that allows the App to enable you to upload photos and/or documents to complete the application form during your loan application journey.

Camera

We require the camera information permission to provide you an easy/smooth experience and to enable you to click photos of your KYC documents along with other requisite documents and upload the same on the App during your loan application journey.

Media, Photos and Files

We require the media, photos, and files permission that allows the App to enable you to upload photos or documents to complete the application form during your loan application journey.

Calendar Information

• We require calendar information so that you can set up a loan due date memo in the app after the loan, which will remind you to repay your loan on time.

5. Children's Privacy

We do not knowingly collect personal information from children who cannot give consent or under the age of 18 except as permitted by law. If you are a parent or guardian and you believe your child has provided us with personal information, please contact us. If inadvertent collection occurs, we will promptly take steps to delete such information.

6. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect non-personal information about your interaction with our website. You can set your browser to refuse cookies or to alert you when cookies are being sent.

7. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or the content of these third-party websites except they are our subsidiaries. We encourage you to read the privacy policies of any third-party websites you visit.

8. Your Choices and Rights

• Access and Update: You have the right to access and update your personal information held by Us. You can do this by logging into your account or by contacting us directly.
• Data Retention: We will retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
• The right to rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe.
• Deletion: You have the right to request the deletion of your personal information, subject to certain legal exceptions.

9. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the updated Privacy Policy on our website or by sending you a notification. We encourage you to review this Privacy Policy periodically for any updates.

10. Governing Law

This Privacy Policy is made pursuant to the Nigeria Data Protection Act (NDPA) and other relevant laws, regulations, or international conventions applicable to Nigeria.

By using our Services, you acknowledge that you have read this Privacy Policy and consent to the collection, use, disclosure, and retention of your information as described herein.

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at info@geniusforyou.com