Introduction

Welcome to the Touch and Pay Privacy Policy!

This NFC card management and financial technology services called Touch & Pay is operated by Touch and Pay Technologies Limited (hereinafter referred to as “we”, “our”, “us” or “Touch & Pay”). This Privacy policy between Touch & Pay and You, constitutes our commitment to your privacy on our mobile application, other platforms and our premises.

This privacy policy (“Policy”), together with our terms of use and any other documents referred to on it, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.The penalties for violating the Regulation can be severe for Touch and Pay and for the individual involved.

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.

Definition

Identity Data

includes first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender

Contact Data

includes billing address, delivery address, email address and telephone numbers

Financial Data

includes bank account and payment card details

Transaction Data

includes details about your transactions

Device Data

includes information on the devices with which you access the platform

Profile Data

includes your username and password, picture, transaction history, your interests, preferences, feedback and survey responses

Usage Data

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

Location Data

includes your current location disclosed by GPS technology or any other location territory

Your Privacy Rights

This Privacy Policy describes your privacy rights regarding our collection, use, storage, sharing and protection of your personal information. It applies to the Touch & Pay applications, services, tools and physical contact with us regardless of how you access or use them. If you have created a username, identification code, password, pin code or any other piece of information as part of our access security measures, you must treat such information as confidential.

Consents

You accept this Privacy Policy when you give consent upon access to our platforms, or use our services, content, features, technologies or functions offered on our mobile application or visit any of our offices for official or non- official purposes. This Policy governs the use of Touch & Pay services and intervention projects by our users and stakeholders unless otherwise agreed through written contract.

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.

Cookies

Cookies are small files placed on device that enables the mobile application to identify your device as you view different pages. Cookies allow mobile applications to store your preferences in order to present contents, options or functions that are specific to you. Like most interactive mobile applications, our mobile application uses cookies to enable the tracking of your activity for the duration of a session. Our mobile application uses only encrypted session cookies which are erased either after a predefined timeout period or once the user logs out of the platform and closes the application. They will typically store information in the form of a session identification that does not personally identify the user.

This helps us to provide you with a good experience when you access our Platform and allows us to improve our site.

You can set your browser to refuse all or some browser cookies or to alert you when Platforms set or access cookies. If you disable or refuse cookies, please note that some parts of this Platform may become inaccessible or not function properly.

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 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 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.

Governing Law

This Privacy Policy is made pursuant to the Nigeria Data Protection Regulation (2019) or any other relevant Nigerian laws, regulations or international conventions applicable to Nigeria. Where any provision of this Policy is deemed inconsistent with a law, regulation or convention, such provision shall be subject to the overriding law, regulation or convention.

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.

Complaints

If you have any questions about this privacy policy or our privacy practices, please contact our customer service through any of the following ways:

Full name of legal entity: Touch and Pay Technologies Limited
Email address: hello@touchandpay.me
Postal address: 5 th floor, SAPETRO Towers, Adeola Odeku Street, Victoria Island, Lagos
Telephone number: +2348035870063