Touch and Pay has a zero-tolerance attitude towards data mismanagement and any latitude of such, can damage the reputation of the Company. Accordingly, any violation of this Policy may result in disciplinary action, up to and including dismissal in appropriate circumstances. It is therefore extremely important that you familiarize yourself with this Policy and strictly adhere to it. If you have any questions, please consult the Head of Operations/ Data Protection Officer.
includes first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender
includes billing address, delivery address, email address and telephone numbers
includes bank account and payment card details
includes details about your transactions
includes information on the devices with which you access the platform
includes your username and password, picture, transaction history, your interests, preferences, feedback and survey responses
includes details of your use of our services
Marketing and Communications Data
includes your preferences in receiving marketing from us and our third parties and your communication preferences
includes your current location disclosed by GPS technology or any other location territory
Your Privacy Rights
Your Personal Information
We may receive, use, store and transfer different kinds of personal data about you including the Identity Data, Contact Data, Financial Data, Transaction Data, Device Data, Profile Data, Usage Data, Marketing and Communications Data, Location Data.
Information From Other Sources
This is information we receive about you if you use any of the other Platforms we operate.
When you create an account with us, we may collect information, including nonpublic personal information, about you from third party service providers in order to verify your identity and for fraud prevention, including your prior addresses and names.
The Purpose For Which We Will Use Your Data
The information that we collect from you
We may use information held about you in the following ways:
to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
to ensure that content from our mobile application is presented in the most effective manner for you and to notify you about changes to our service;
to administer our application and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of Your Personal Information
You agree that we have the right to share your personal information:
with any of our affiliated companies and service providers;
with financial service providers, including the financial institutions identified in your cardholder bank agreement that provide banking services in connection with your account;
with non-financial companies, such as email service providers that perform marketing services on our behalf, and fraud prevention service providers that use the information to provide services to us;
with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or alternatively, acquire all or parts of their businesses;
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; and
with relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud
Transfer To Third Party
We may provide other users with your personal information to complete a transaction. Such information may include your name, account identity, contact details or such additional information required information for the transaction.
We work with third parties, including, E-Tranzact, NIBSS and other financial institutions to enable an efficient system.
Changes To Personal Information
It is imperative that your data with us is current and accurate. You may request for the rectification of any personal data that we hold about you so as to enable you to correct any incomplete or inaccurate data we hold about you. We may, however, need to verify the accuracy of the new data you provide to us.
Data Security and Retention
We deploy strict physical, electronic, and administrative security measures to protect your information from access by unauthorised persons, against unlawful processing and foreseeable hazards and breaches when online.
We will retain your data for as long as necessary for the said purpose of the processing, and after that, we will keep your data as long as the law requires and or lawful purposes.
Your Legal Rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Changes to This Policy
We may periodically update this Policy without notifying you, but we will display a conspicuous notice on this Platform to inform you of any significant changes to our Policy.
Please check back frequently to see whether there are any updates or changes to this Policy.
Full name of legal entity: Touch and Pay Technologies Limited
Email address: email@example.com
Postal address: 5 th floor, SAPETRO Towers, Adeola Odeku Street, Victoria Island, Lagos
Telephone number: +2348035870063