PRIVACY POLICY

Accelete Nigeria Limited (“We”, “Us”, “Our”) is the operator of the Website and Mobile Application called “Incash” which provides an employee financial wellness platform which provides verified employees with salary advances (The “Services”). We help employers strategically manage their funds and ensure that all employees get their rights of financial freedom.

At Accelete Nigeria Limited we are committed to protecting the privacy of the personal information that is provided to or collected by us while using our Services. We acknowledge and comply with our legal obligations in relation to applicable data protection laws.

This privacy policy explain:

• How we may collect, use, manage, and disclose information about clients, other business, and contacts
• How we may collect, manage, and use personal information obtained from you.
• The rights you may have in respect of your own personal information.

PURPOSE OF THIS PRIVACY POLICY

The purpose of this privacy policy is to give you information about how we collect and process your personal data. This privacy policy supplements our Terms of Use that is currently on our website and such other notices that we may provide on specific occasions when we are collecting or processing your personal data.

THE INFORMATION THAT WE MAY COLLECT:

The scope of information we may collect from persons using our Services include:

• All personal information obtained from persons using the Service.
• Information provided to us while making an enquiry on the use of the Service.
• Information provided to us while reporting a problem or making a complaint about the Service.

THE TYPE OF INFORMATION WE MAY COLLECT

The specific types of personal Information that we may collect, use and store are as follows:

• “Identity Data”: This includes your first name, middle names, maiden name, last name, gender, title, date of birth, photographic identification, National identification number and Identification Card.
• “Contact Data”: This includes your home address, email address and telephone number.
• “Account Information”: This includes information such as usernames and passwords, authentication methods and roles, and similar data.
• “Financial Data”: This includes information on your monthly salary, bank information and Bank Statement.
• “Technical Data”: This includes information collected when you access Incash's Services, your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you are using.
• Marketing and Communication Data: This includes data relating to your preferences in receiving newsletters with respect to our products and Services from us as well as your communication preferences. 
• Professional Data: This includes your company name, job title, salary amount and salary payment date.

WHY WE COLLECT INFORMATION

We collect information to enable us to process your salary advance and to provide you with our Services.

We also collect data to be able to respond to questions or requests which you submit as well as anticipate and resolve problems with any services we offer to you.

HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

• Direct collection: You may give us your data by filling in forms (e.g., the contact form on our website); creating your profile; by correspondence and conversations (including via email and telephone); or through contracts we may enter with you.
• Automated technologies: As you interact with our website, we will automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We collect such data to be able to properly provide you with our Services.
• Third parties or publicly available sources: We also receive your personal data from third parties to whom you have legally provided such data to, such as your employer, benefactors, etc. To the extent that such data is disclosed by third parties, different rules may apply to their use or disclosure of your information. We do not control how they use or share your data and we cannot make any representations or warranties as to these. We however have control over data that you have voluntarily shared to us directly or through your usage of our website. With your consent, we use your information to fulfill requests to receive information or materials from us, to carry out Services for your benefit and to process applications and requests from you. We do not use your data for any other purpose than for the purposes listed out in this policy, however, in cases of default of the salary advanced to you, we may share your personal data to third parties to assist in the recovery of the amounts owed.

LAWFUL BASIS FOR OUR USE OF YOUR PERSONAL DATA

We will use your personal data only to the extent permitted by law. Under the Nigeria Data Protection Regulation 2019 (NDPR), personal data may be processed under any of the following lawful basis:

• Where you consent to our use of your personal data
• Where your personal information is necessary for the performance of the contract to use our Services
• Where we need to comply with a legal obligation.
• Where we need to protect your vital interest or the vital interest of another individual
• Where it is in the interest of the general public to process your data

While we mostly collect and process your data with your consent, we may collect and process your data under any of the identified lawful bases depending on the circumstance. We do not always need your consent to process your data. However, we do need your consent before we can process your data for purposes such as direct marketing communications. You are at liberty to withdraw your consent to such kinds of processing at any time. Where such withdrawal makes us unable to proceed with providing you with certain Services, we will inform you accordingly.

By using our Services, you agree to the terms of this Privacy Policy, as to allow us to utilize your data to service you more accurately.

OUR ROLE AS DATA CONTROLLER

A “controller” is a person or organization who alone or jointly determines the purposes for which, and the way any personal data is, or is likely to be, processed. With respect to any information provided to us by any users of Incash, Accelerate Nigeria Limited is the data controller.

DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information to any of our affiliates. We may also disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect our rights, property, or safety or those of other users our clients or others.

DATA SECURITY

We will take reasonable steps to protect personal information disclosed to us from loss, modification, misuse, unauthorized access and/or disclosure. While we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us over the internet as transmission over the internet is not completely secure; therefore, we note that any such transmission is at your own risk. However, we will use strict procedures and security features to try to prevent unauthorized access once we have collected your information. We are bound by international standards and best practices on information and cyber security as may be issued from time to time.

DATA RETENTION

We retain your data for such a period as is necessary for the purpose for which it was collected. Storage of your data is also determined by legal, regulatory, administrative, or operational requirements. We only retain information that allows us to comply with legal and regulatory requests for certain data, meet business and audit requirements, respond to complaints and queries, or address disputes or claims that may arise. When data is no longer required for the purposes for which it was collected, we securely destroy it.

THIRD PARTY SITES

Our website, and Services may contain links to third-party websites, products, and services. Our products and Services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details are governed by their privacy practices and we will not be liable for any breach of confidentiality or privacy of your information on such third-party websites. We encourage you to learn about the privacy practices of those third parties.

PRIVACY POLICY CHANGE

We may modify this Privacy Policy from time to time without prior notice by publishing a new version of the Privacy Policy on our website. Any changes to the Privacy Policy will be reflected on the website and will become effective immediately upon publication. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personally identifiable information we collect. If changes to the Privacy Policy are material, we will do our best to notify you via email or through a notification on our website.

ACCESS, CONSENT AND CORRECTION

We will take reasonable steps to ensure that the personal information we collect remains accurate, up to date and complete. We will also provide you with access to your personal information held by us on your request unless we are otherwise permitted by applicable laws. If you wish to access or correct personal information that we hold about you, please contact us through the contact details provided below. You have the right to withdraw consent previously given for processing your data or restrict the processing of your personal data. We might however continue to process your data if there are valid legal or operational reasons.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Furthermore, if you discover any inaccuracies in your personal information, please promptly notify us by contacting us through the contact details provided below.

YOUR LEGAL RIGHTS

In addition to being able to control the data your directly provide to us, you may exercise any of the below rights with respect to your data:

1. Request information about any of your personal data which we are processing, and request access to your personal information which we process.
2. Request correction of personal information that we hold about you to make them more accurate or to reflect change in circumstances.
3. Request us to refrain from doing certain things with your data or restrict the extent of our collection or processing of your data.
4. Request partial or complete erasure of your personal information.
5. Object to our processing of your personal information where we are processing your personal information for direct marketing purposes.
6. Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
7. Request the transfer of your personal information to another party. If you wish to exercise any of the rights set out above, please contact us using the contact details provided below.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact us using the details provided below: Full name of legal entity: ACCELETE NIGERIA LIMITED

Telephone number: +234(0)8122109900