This Privacy Policy discloses the privacy practices for (www.wakanow.com). This privacy policy applies to personal information collected by the company and to all types of systems, operations and processes within our environment that involve the collection, storage, use, transmission, and disposal of Personal Information (described below). It is provided to help you understand what information we collect about you, how the information collected is used, how we protect it, and your rights to it, among others. 

This Privacy Policy is strictly restricted to only our services and therefore does not apply to services that are not owned or controlled by us, including third-party platforms/websites. We are committed to handling all personal data provided to us in compliance with both applicable and model data privacy and protection laws.

 It will inform you of the following:

    1.   What personally identifiable information is collected from you through the web site, how it is used and with whom it may be shared.

    2.   What choices are available to you regarding the use of your data.

    3.   The security procedures in place to protect the misuse of your information.

    4.   How you can correct any inaccuracies in the information.

INFORMATION COLLECTION, USE, ANDSHARING 

We are the sole owners of the information collected on this site. We only have access to collect information that you voluntarily give us via email or other direct contact from you. We will not sell or rent this information to anyone.

We will use your information to respond to you, regarding the reason you contacted us. We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request.

Unless you ask us not to, we may contact you via email in the future to tell you about specials, new products or services, or changes to this privacy policy.

PERSONAL INFORMATION

As part of our operations, we collect and process certain types of information (such as names, telephone numbers, addresses etc.) of individuals that makes them easily identifiable. These individuals include current, past, and prospective employees, guarantors, referees, suppliers/vendors, customers or former customers, and other individuals whom we communicate or deal with,jointly and/or severally (“Data Subject(s)”).

You may voluntarily provide us with certain Personal Information, to enable you to gain access to and use our services. This information relates to an identified person or information that can be used to identify you.

We will always solicit for your consent before sharing or disclosing your Personal Information with a third party except as may be required for the purpose of providing you with our services or under applicable legislations. The following are the information that we collect and process:

                     i.              Individual personal information (e.g., name,previous names, date, and place of birth, etc.);

                    ii.              Individual personal contact details (e.g.,address, email address, mobile numbers);

                   iii.              Identifying information (e.g., photo ID,nationality, utility bill, national ID card and/or number, guarantor’s details,referee details, vendor’s personal data,);

                  iv.              Information about the ways you interact with the company (e.g., channels used, geographic information, software used andinformation concerning your complaints);

                    v.              Information captured in customer documentation or data exchange such as application forms or advisory documents or via telephone (e.g., records of advice);

                  vi.              Information from cookies and similar technologies used to remember your preferences and tailor content;

                 vii.              Data or records of correspondence related to relevant exchanges of information (e.g., emails);

                viii.              Information to fulfill regulatory obligations(e.g., transaction details, user activity);

                  ix.              Information from other entities (e.g., relevanttransaction information)

                    x.              Information from third parties providinginformation to identify and manage fraud;

                  xi.               Data from closed circuit television (CCTV) in and around the company’s facilities (these may collect photos or videos of you); and

                 xii.              Other information about you that is voluntarily provided by filling in online forms or by communicating with us, whether face-to-face or via other available channels (e.g., by phone, email, oronline).

.

WE USE YOUR PERSONAL INFORMATIONTO:

a)     provide you with the required services;

b)     respond to your questions or requests;

c)     improve features, platform and website content and analyse data to develop services;

d)     address inappropriate use of our Services;

e)     prevent,detect and manage risk against fraud and illegal activities using internal and third-party screening tools;

f)       verify your identity and the information you provide in line with our statutory obligations using internal and third-party tools;

g)     maintainup-to-date records;

h)     resolve disputes that may arise, including investigations by law enforcement or regulatory bodies; and

i)       any other purpose that we disclose to you in the course of providing our Services to you.

PURPOSE LIMITATION

We collect 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 PROCESSING PRINCIPLES

Your personal data will be:

a)     collectedand processed in accordance with specific, legitimate, and lawful purposes,consented to by you;

b)     adequate,accurate and without prejudice to the dignity of the human person;

c)     stored only for the period within which it is reasonably needed; and

d)     secured against all foreseeable hazards and breaches such as theft, cyberattack, viralattack, dissemination, manipulations of any kind, damage by rain, fire, orexposure to other natural elements.

OUR LAWFUL BASIS FOR PROCESSING PERSONAL INFORMATION

We will only use and process your personal dataas permitted by the Nigerian Data Protection Act, 2023. We have set out below adescription of all the legal bases we may rely on to process your personaldata:

a)     Where you have given us consent to the processing of your personal data for one or more specific purposes;

b)     where processing is necessary for the performance of a contract to which you are aparty or to take steps at your request prior to entering into a contract;

c)     where processing is necessary for compliance with a legal obligation to which we are subject;

d)     where processing is necessary to protect your vital interests or the vital interests of another natural person, and

e)     where processing is necessary for the performance of a task carried out in the public interest or in exercise of an official public mandate vested in us.

f)       For the purpose of the legitimate interests pursued by us as data controller or data processor, or by a third party to whom the data is disclosed.

            Note that we may process your personal data for more than one lawful ground depending on the specific purposefor which we are using your personal data. Please contact us by sending an email to legal@wakanow.com. if you need details about the specific legal ground we are relying on to process your personal data where more than one ground may have been used to process your personal data.

  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.

DATA MINIMIZATION

We limit Personal Information collection and usage to data that is relevant,adequate, and necessary for carrying out the purpose for which the data isprocessed. We will evaluate whether and to what extent the processing of Personal Information is necessary and where the purpose allows, anonymized data will be used.

DATA RETENTION

We will retain your Personal Information for as long as is needed to provide our services to you, comply with our legal and statutory obligations or verify yourinformation with the required verification authorities.

            We are statutorily obligated to retain the Personal Information and data you provide us with to carry out our services and in compliance with laws and regulatory guidelines applicable to us and our partners. Therefore, even after discontinuance of ourservices, we will retain certain Personal Information and transaction data to comply with these obligations.

For all Personal Information and records obtained, used, and stored by us, we shall perform periodical reviews of the data retained to confirm the accuracy,purpose, validity, and requirement to retain.

The length of storage of your Personal Information shall, amongst other things, be determined by:

a)    the contract terms agreed between us and the Data Subject or as long as it is needed for the purpose for which it was obtained; or

b)    where the relationship has statutory implication or a required retention period; or

c)    where there is an express request for deletion of the Personal Information by the Data Subject, provided that such request will only be treated where the Data Subject is not under any investigation which may require us to retain such Personal Information or there is no subsisting contractual arrangement with the Data Subject that would require the processing of the Personal Information; or

d)    where we have another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.

YOUR ACCESS TO AND CONTROL OVERINFORMATION

Once your Personal Information is held by us, you are entitled to reach out to us to exercise the following rights which are guaranteed by the Nigeria Data Protection Act with some limitations.

a)     Request access to your personal data (commonly known as a “data subject accessrequest”): This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may notify you of our refusal to comply with your request in these circumstances. Where we have reasonable doubts concerning the identity of the natural person making the request for information, we may request the provision of additional informationnecessary to confirm the identity of the Data Subject. Where data is held electronically in a structured form, such as in a Database, as the Data Subject, you have a right to receive that data in a common electronic format;

b)     Right to 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, complete or updated, though we may need to verify the accuracy of the new data you provide to us.

c)     Rightto request erasure or deletion of your personal data: Thisenables you to ask us to delete or remove personal data where there is no goodreason for us continuing to process it. You also have the right to ask us todelete or remove your personal data where you have successfully exercised yourright to object to processing (see below), where we may have processed yourinformation 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.

d)     Right to object to the processing of your personal data: Where we are relying on a legitimate interest (or those of a third party) there maybe something about your situation which could justify an objection to processing on this ground as you may 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 override your rights and freedoms.

e)     Right to 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:

                                i.       If you want us to establish the data’s accuracy;

                              ii.       Where our use of the data is unlawful but you do not want us to erase it;

                             iii.       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; or

                             iv.       You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

f)     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.

g)     Right to withdraw consent at anytime where we are relying on consent to process your personal data: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 services to you. We will advise you if this is the case at the time you withdraw your consent. Your request will be reviewed by us and carried out except as restricted by law or our statutory obligations. You may decline to provide your Personal Information when it is requested by us, however, certain services or all services may be unavailable to you. You may review and update your Personal Information directly or by contacting us.

SECURITY

We take precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline. Wherever we collect sensitive information (such as credit card data),that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for "https" at the beginning of the address of the web page.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.

UPDATES, MODIFICATIONS ANDAMENDMENTS

We reserve the right to update, modify, change, or revise this Privacy Policy from time to time. The changes will not be retroactive, and the most current version of this Privacy Policy which will always be on this page and will continue to govern our relationship with you. We advise that you check this page often,referring to the date of the last modification on the page. We will also try to notify you of any material changes which could be done via email associated with your account or service notification. By continuing to use our services after the changes become effective, you agree to be bound by the revised Privacy Policy.

If you feel that we are not abiding by this privacy policy, you should contact us immediately via email at legal@wakanow.com.

REGISTRATION 

For effective use of this website, users are advised to complete the registrationform. During registration a user is required to give certain information (such as name and email address). This information is used to contact you about the products/services on our site in which you have expressed interest. At your option, you may also provide demographic information (such as gender or age) about yourself, but it is not required.

COOKIES

We use "cookies" on this site. A cookie is a piece of data stored on a site visitor's hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, depending on your browser settings you would not have to log in a password more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any personally identifiable information on our site.

Someof our business partners may use cookies on our site (for example,advertisers). However, we have no access to or control over these cookies.

SHARING 

We share aggregated demographic information with our partners and advertisers.This is not linked to any personal information that can identify any individual person. We use a credit card processing company to bill users for products and services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes beyond fulfilling your order.

We partner with other parties to provide specific services. When the user signs up for these services, we will share names, or other contact information that is necessary for the third party to provide these services. These parties are not allowed to use personally identifiable information except for the purpose of providing these services.

Using the Wakanow mobile phone and tablet Apps (the "Mobile Apps")

When you use the Mobile App, we collect and use information about you in the same way and for the same purposes as we do when you use our website.

Inaddition to this, we also use some other information that we collect automatically when you use our Mobile Apps e.g. we collect information about Mobile App functionality that you access and use. This allows us to identify those areas of the Mobile App that are of interest to our customers so that we can refine and continuously improve the Mobile App. The information we collect for this purpose does not enable us to directly identify you.

When you use our Mobile App, you can choose to allow access to your current location– provided by your mobile device using GPS or similar technologies – in order to identify nearby hotels or airports. If you choose to allow access, this location data may be collected anonymously as part of search requests logged by our servers. You can switch off the Mobile App’s access to your location at anytime through your phone settings menu.

Each Mobile App will also send us error-reporting information in the event that it crashes or hangs. This enables us to investigate the error and to improve the stability of the Mobile App for future releases. We do not use this information for any purpose other than investigating and remedying the error.

You always have the ability to control what information a Mobile App sends to us.You can exercise this control either by changing the settings of the Mobile App under its setting menu or changing the settings of your mobile device.Alternatively, you can remove the Mobile App from your mobile device entirely and access our services through our website.

We may share your information with law enforcement agencies, public or tax authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

a)     comply with a legal obligation, process, or request (including tax and relatedreporting requirements);

b)     enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;

c)     detect,prevent, or otherwise address security, fraud, or technical issues; or

d)     protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection and creditrisk reduction).

Please see the list and details of categories of third-party processors we share your personal datawith below: Flutterwave- payment gateway

TRANSFER OF PERSONAL INFORMATIONTO FOREIGN COUNTRY

Where Personal Information is to be transferred to a country outside Nigeria, we shall put adequate measures in place to ensure the security of such Personal Information. In particular, we shall, among other things, confirm whether the country is on the Nigeria Data Protection Commission ("NDPC”) Whitelist of Countries with adequate data protection laws.

Transfer of Personal Information out of Nigeria would be in accordance with the provisions of the Nigeria Data Protection Act ("NDPA”) 2023. We will therefore only transfer Personal Information out of Nigeria on one of the following conditions:

a)     the consent of the Data Subject has been obtained;

b)     the transfer is necessary for the performance of a contract between us and the DataSubject or implementation of pre-contractual measures taken at the DataSubject’s request;

c)     the transfer is necessary to conclude a contract between us and a third party in the interest of the Data Subject;

d)     the transfer is necessary for reason of public interest;

e)     the transfer is for the establishment, exercise, or defense of legal claims;

f)       the transfer is necessary to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent.

We will take all necessary steps to ensure that your Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside Nigeria shall be provided to you upon request.

LINKS 

This web site contains links to other sites. Our website includes hyperlinks to, and details of, third party websites.

Please be aware that we are not responsible and have no control over the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site to read the privacy statements of any other site that collects personally identifiable information.

VISITING OUR WEBSITE FROM OUTSIDE NIGERIA

If you are visiting our website from outside Nigeria, please be aware that yourinformation may be transferred to, stored, and processed in Nigeria from whereour central database is operated. The data protection law and other laws ofNigeria may vary in content or may not be as comprehensive as those in yourcountry, but please be assured that we take steps to ensure that your privacyis protected. By using our services, you understand that your information may betransferred to our facilities and to those third parties with whom we share itas described in this Policy.

SURVEYS & CONTESTS/PROMOTIONS 

Fromtime-to-time our site requests information via surveys or contests.Participation in these surveys or contests is completely voluntary and you maychoose whether or not to participate and therefore disclose this information.Information requested may include contact information (such as name andaddress), and demographic information (such as post code, age level etc).Contact information will be used to notify the winners and award prizes. Surveyinformation will be used for purposes of monitoring or improving the use andsatisfaction of this site.

 PRIVACY POLICY

Thisprivacy policy applies  to personalinformation collected through our website and personal information collectedoffline.

TERMS AND CONDITIONS

Pleasealso visit our Terms and Conditions section establishing the use, disclaimersand limitations of liability governing the use of our website at http://www.wakanow.com

YOUR CONSENT

Byaccessing or using our services in any manner, you suggest to us that you haveread and adopted this Privacy Policy and consent to the data practicesdescribed herein.

Youagree that upon granting us your consent, you have the legal capacity to giveconsent and you are aware of your privacy rights and your option to withdrawyour consent at any given time.

If you do not accept this Privacy Policy and donot meet or comply with the provisions set forth herein, then you may not useour services.

AGE RESTRICTION

Ifyou access our services or platform and you are below 18 years, you representand warrant that you have obtained consent from your parent(s) or legalguardian(s).  If you have inadvertentlyprovided personal data of a child to us, please notify us at Nasir@wakanow.com  and we will delete such personal data.

Consistentwith Section 8 of the Nigeria Child Rights Act (“the Act”), Cap C50, Laws ofthe Federation of Nigeria 2010, Section 31 of the Nigeria Data Protection Act2023, we will never knowingly request Personally Identifiable Information fromanyone below the age of 18 under the Act without prior verifiable parentalconsent. If we become aware that a child below the age of 18 under the Act hasprovided us with personal data without verifiable parental consent, we will useour best efforts to remove such information from our files. If as a parent orguardian, you become aware that your child or ward child has provided us withany information without your consent, please contact us through the detailsprovided in this Privacy Policy.

COMPLIANCE

Pleasenote that the collection, processing, security, storage, and erasure of yourpersonal data including any updates to this privacy policy will be inaccordance with existing or new privacy and data protection provisions and lawsin Nigeria which includes but not limited to the following:

a)     Constitutionof the Federal Republic of Nigeria 1999 (as Amended);

b)     NigeriaData Protection Act 2023 ("NDPA”); 

c)     NigeriaData Protection Regulation 2019 ("NDPR”); 

d)     NDPR2019 Implémentation Framework ;

e)     NigeriaCybercrimes (Prohibition, Prevention, Amendement) Act 2024 ;

f)       NigeriaMoney Laundering (Prevention and Prohibition) Act, 2022;

g)     NigeriaFederal Competition and Consumer Protection Act, 2018 (FCCPA);

h)     NigeriaFreedom of Information Act 2011;

i)       CentralBank of Nigeria Risk-Based Cybersecurity Framework and Guidelines for OtherFinancial Institutions 2022.

COMPLAINTS AND REMEDIES

Youmay file a complaint in accordance with this Privacy Policy if you believe thatany provision of this Privacy Policy or your privacy rights have been violatedin respect of your personal information or if your access to our Services havebeen compromised, to enable us to take the necessary steps towards ensuring thesecurity of your Personal Information. All complaints must be addressed to thecompany by sending an email to our Data Protection Officer using the followingcontact details:

Email:Nasir@wakanow.com

Pleasenote that, the complaint and resolution procedure is not prejudicial to yourright to complain to the data protection authorities (in this case, you shouldcontact the Nigeria Data Protection Commission (NDPC) using the followingcontact details: 

Address:

NDPC: No. 5, Donau Crescent,

Off Amazon Street, Maitama,

 Abuja,Nigeria.

Email: info@ndpc.gov.ng

Wewill notify you of any breach and also notify Nigeria Data ProtectionCommission (NDPC) within 72 hours of becoming aware of such breach. 

Youmay also seek redress in a court of competent jurisdiction. We would, however,appreciate the chance to deal with your concerns before you approach the dataprotection authorities. Kindly contact us in the first instance by sending anemail to: Nasir@wakanow.com

QUESTIONS AND INQUIRIES

Youmay also contact us if you have any questions, comments and requests relatingto this Privacy Policy or would like to find out more about exercising yourdata protection rights.  Please contactus via Nasir@wakanow.com

Ifyou are in Lagos, we can also be reached at:

WAKANOW.COM  LIMITED

Plot8 Elegushi Beach Road

OffIkate Roundabout

Lekki/EpeExpressway

LagosState, Nigeria.