INFORMATION YOU PROVIDE US

In general, you can visit www.smartsaver.ng or our mobile application without telling us who you are or revealing any information about yourself. When you submit an inquiry via ourServices or register for a SmartSaver.ng account, we may collect personal information from you, which may include your name, email address, BVN, mobile phone number, banking information, and other information that identifies you (collectively, & Personal Information ).

By providing your Personal Information to us, you expressly agree to our collection, use,storage, and disclosure of such information as described in this Privacy Policy. We may also ask you to create login information for your SmartSaver.ng account, such as a username and password. When you provide your mobile phone number, we may ask for your consent to receive text messages relating to our Services at that number.

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally, identifiable information may include, but is not limited to:

Email address First name and last name Phone number Address, State, Province, ZIP/Postal code, City Usage Data Bank Verification Number (BVN) National Identification Number (NIN) Photograph Date of Birth Image of a government-issued identity document (NIN, International Passport, Driving License, Voter Id)

You may withdraw your consent by contacting us as indicated below or by replying with STOP to any text message we send you. Please note that if you withdraw your consent to receive text messages from us, you may not be able to use some of our Services. Your mobile carrier standard text message and data charges may apply to text messages you receive from us, and you are responsible for any fees charged by your mobile carrier if we contact you.

INFORMATION ABOUT YOUR TRANSACTIONS

We collect Personal Information about your transactions with us and others.

INFORMATION FROM THIRD PARTIES

We also collect Personal Information about you from other companies. For instance, we may receive Personal Information about you from a consumer reporting agency.

INFORMATION AUTOMATICALLY COLLECTED

We (or our service providers acting on our behalf) may collect information about your use of our Services. This information may include Personal Information as well as statistical information that do not identify you (Analytic). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy.

Information that we automatically collect in connection with your access or use of our Services may include:

Device Information: We may collect Device-specific information (such as hardware model, operating system version, unique Device identifiers, and mobile network Information, including your mobile phone number). We may associate your Device identifiers or mobile phone number with your SmartSaver.ng account.

Log Information: We may record or log information from your Devices, their software, and your activity accessing or using our Services. This information may include:

• The Devices Internet Protocol (IP) address
• Identification numbers associated with your Devices
• The Devices Internet Protocol (IP) address
• Device event information, such as crashes, system activity, and hardware settings
• Location preferences
• Date and time stamps of transactions
• System configuration information
• Other interactions with our Services

Sensitive Data

We may collect special or sensitive data about you such as gender/sex, personal identifiable information, information on your previous offences and convictions and sensitive financial information. From your device we may collect your SMs logs, contacts, phone state, location and applications. Where we collect such information, we shall collect, process and store that data in accordance with the provisions of the prevailing Data Protection Laws

Location Information

We may use GPS technology or other location services to determine your location. You may revoke their consent of location data at any time by logging out and uninstalling the the App from their device.

INFORMATION COLLECTED THROUGH COOKIES AND SIMILAR TECHNOLOGIES

We use cookies to personalize our Services for you and to collect aggregate information about usage of our Services. A cookie is a text file or other local storage identifier provided by your browser or associated applications. We use cookies for record-keeping purposes and to enhance the quality of your use of our Services. The cookies assign random, unique numbers to your Devices to enable our systems to recognize your Devices and to allow us to see how you use our Services. Additional general information about cookies and how they work is available at www.allaboutcookies.org.

The cookies we use in connection with our Services include: Session cookies: Session cookies are temporary cookies that expire and are automatically erased whenever you close your browser window. We use session cookies to grant users access to content and to enable actions they must be logged into their SmartSaver.ng account to perform.

Persistent cookies: Persistent cookies usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve our Services. For example, we may use a persistent cookie to associate you with your SmartSaver.ng account or to remember your choices for our Services.

Third-party cookies: We permit certain third parties to place cookies through our Services to provide us with better insights into the use of our Services and user demographics and to advertise our Services to you. These third parties may collect information about your online activities over time and across different websites when you access or use our Services. For example, we utilize Google Analytics to analyze usage patterns for our Services. Google Analytics generates a cookie to capture information about your use of our Services, which Google uses to compile reports on website activity for us and to provide other related services.

Google may use a portion of your IP address to identify its cookie, but this will not be associated with any other data held by Google. We may also permit third-party service providers to place cookies for our Services, as indicated above, to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties.

By accessing or using our Services, you consent to the placement of cookies on your Devices as described in this Privacy Policy. If you prefer not to receive cookies through our Services, you may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Unless you set your browser settings to refuse all cookies, our system may issue cookies when you access or use our Services. If you set your browser settings to refuse all cookies, the performance of certain features of our Services may be limited or not work at all.

DO-NOT-TRACK SIGNALS

Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.

To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

To manage Your requests: To attend and manage Your requests to Us.

For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.

For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. You have the right to request deletion of the data we have collected about you. However, we will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

How We Share Information

We do not share your Personal Information with: (1) other financial companies for joint marketing purposes; (2) affiliated companies for their everyday business purposes; or (3) any third parties so they can market to you.

We may share your Personal Information with unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to help complete a transaction for you; (3) if the information is provided to: (a) comply with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas; (b) enforce our Terms of Use or other agreements; or (c) protect our rights, property, or safety or the rights, property, or safety of our users or others (e.g., to a consumer reporting agency for fraud protection, etc.); (4) if the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets); (5) if the information is provided to our third-party service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); (6) for our everyday business purposes; or (7) as permitted by applicable law or otherwise described in this Privacy Policy. When you are no longer our customer, wecontinue to share your information as described in this Privacy Policy.

We may disclose Analytics with third parties as described elsewhere in this Privacy Policy and for our commercial purposes.e.

Accessing Your Information

If you do not wish to receive offers or other notices from us in the future, you can opt out by contacting us as indicated at the end of this Privacy Policy or by following the unsubscribe" instructions in any communication you receive from us. Please be aware that you are not able to opt out of receiving communications about your SmartSaver.ng account or related transactions with us.

Opt-Out Rights

You must notify us of any change in your Personal Information by updating your SmartSaver.ng account profile through our Services. Any changes will affect only future uses of your Personal Information.

Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information. Otherwise, we will hold your Personal Information for as long as we believe it will help us achieve our objectives as detailed in this Privacy Policy.

You can ask us whether we are storing your Personal Information and you can ask to receive a copy of that Personal Information. Before sending you any Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information we hold about you.

Information You Share Socially

Our Services may allow you to connect and share your actions, comments, content, and information publicly or with friends. We are not responsible for maintaining the confidentiality of any information you share publicly or with friends. Our Services may also allow you to connect with us on, share on, and use third-partywebsites, applications, and services.

Please be mindful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those sites and services directly if you want to learn about their privacy practices.

We have, and require our third-party service providers that receive Personal Information from us to have, a comprehensive written information security program that contains administrative, technical, and physical safeguards for our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, or alteration. When your bank account information is transmitted via our Services, it will be protected by encryption technology, such as Secure Sockets Layer (SSL).

No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your username and password for your SmartSaver.ng account and do not share them with others. If we receive instructions using your SmartSaver.ng account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your SmartSaver.ng account or any other breach of security. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate SmartSaver.ng accounts, and to remove or edit content.

Protecting Children’s Privacy

Our Services are not directed, or intended to be attractive, to children under the age of 18. We do not knowingly collect Personal Information from children under the age of 18. If you are under the age of 18, do not use our Services or submit any information to us.

Links to Third-Party Websites

When you use our Services, you may be directed to other websites that are beyond our control. We may also allow third-party websites or applications to link to our Services. We are not responsible for the privacy practices of any third parties or the content of linked websites, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties and websites. This Privacy Policy only applies to our Services.

Changes to our Privacy Policy

Subject to applicable law, we may revise this Privacy Policy at any time and in our sole discretion. When we revise this Privacy Policy, we will post the revised version via our Services and will update the date at the top of this Privacy Policy.

The revised Privacy Policy will be effective upon posting via our Services, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing or using our Services. If you do not agree to the terms of this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access and use of our Services.

Except as otherwise expressly stated by us, \your access and use of our Services is subject to the version of this Privacy Policy in effect at the time of access or use.

Complaints handling

All complaints from data subjects regarding the way data is handled will be forwarded
to: care@smartsaver.ng

A complaint can be made either orally or in writing but where an oral complaint
is made the designated officer will as soon as practicable reduce the oral complaint into writing.

We will investigate every complaint that we receive and get back to you within 14 days
of receiving the complaint.

If you are not satisfied with the findings, you have the right to appeal or to lodge a
complaint to the Data Protection Authority established under the relevant Data
Protection Legislation as may be applicable.

Contact Us

If you have any questions regarding this Privacy Policy, or if you wish to ask us to delete, correct, or show you your Personal Information as provided above, please contact us at care@Smartsaver.ng