1. INTRODUCTION

This website/Application (“Platform”), is operated by SHELI Limited (hereinafter referred to as “we”, “our”, “us” or “SHELI”) and SHELI respects your privacy and is committed to protecting your personal data.

We are committed to the protection of all personal information that you may provide to us. This Privacy Notice (“Notice”), together with our Cookie Policy [insert link to the cookie policy] Terms of Use, [insert link to 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.  It is important that you read this Privacy Notice together with any other Privacy Notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.  This Privacy Notice supplements other notices is not intended to overrride them.

By visiting and accessing our Platform, you are accepting and consenting to the terms and conditions in this Notice. If you do not agree to this Notice, please do not access our Platform.

Please note that this Platform is not intended for children and we do not knowingly collect data relating to children.  If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration.

1. THE INFORMATION THAT WE COLLECT FROM YOU

When you signup to utilise our Platform, we may receive, use, store and transfer different kinds of personal data about you, including the following:

• 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].

• Transaction Data: includes [details about your transactions].

• Profile Data: includes [your username and password, picture, transaction history, your interests, preferences, feedback and survey responses].

• Payment Data: includes [your payment bank account and debit card details]

• 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].

The information we collect helps to enhance the Platform and verify our Users. Registration Information such as your name and username may be visible to other Users who view your profile page.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Platform feature.

1. INFORMATION FROM OTHER SOURCES

This is information we receive about you if you use any of the other platforms we operate or the other services we provide.

When you create an account with us, we may collect information, including non public 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.

1. COOKIES

We use cookies to distinguish you from other users of our Platform and to remember your preferences. This helps us to provide you with a good experience when you access our Platform and allows us to improve our site. Please see our Cookie Policy for further details on our use of cookies.

1. THE PURPOSE FOR WHICH WE WILL USE YOUR DATA

The information that we collect from you may be used in the following ways:

• to enable you to access, view and utilise our Platform and our services

• to provide you with the information, products and services that you request from us;

• to contact you with information about the Platform (e,g updates and new features);

• to provide you with information about other services we offer that are similar to those that you already use;

• to provide you, or permit selected third parties to provide you, with information about services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;

• to ensure that content from our Platform is presented in the most effective manner for you and to notify you about changes to our service;

• to investigate fraud, protect our legal rights, and to enforce our Terms of Use.

• to administer our Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• to make suggestions and recommendations to you and other users of our Platform 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).

1. LAWFUL BASIS FOR PROCESSING

We shall only process your data:

• where you have given and not withdrawn consent for the processing;

• where the processing is necessary for the performance of a contract to which the you are a party;

• where the processing is necessary for the compliance with a legal obligation;

• where the processing is necessary to protect your vital interest or the vital interest of another person;

• where the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;

• where the processing is necessary for the purposes of our legitimate interests.

1. 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 another user, when you sign up for our services via a referral link. The User that referred you may receive information indicating that you have enrolled with us;

• with another User, where you consent to it, for the purpose of utilising our platform;

• 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, 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.

1. TRANSFER TO THIRD PARTIES

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.

1. THIRD PARTY LINKS

Our Platform may, from time to time contain links, to and from the platforms of our partner networks, advertisers and affiliates. Please note that these platforms and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data, such as contact and location data, which may be collected through these Platforms or services. Please check these policies before you submit any personal data to these Platforms or use these services.

1. 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.

Once you register, you will be able to review and change this information at any time just by logging in to the Platform.  It is your responsibility to ensure that your account details are kept up to date.

1. 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. Where the retention of your personal data is no longer necessary or there is no other lawful basis to retain it, we will completely erase your personal data from our Platform.

1. 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.

  You have the right to ask us to delete or remove your 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 for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. [Erasure request]

  Additionally, please note that we temporarily retain deleted data for 90 days before full deletion.

   

• 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 override 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 were 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.

• Complaint to the regulatory authority upon breach. You have the right to make a complaint at any time to the Nigeria Data Protection Commission (NDPC), the Nigerian Supervisory authority for data protection issues (www.ndpc.gov.ng). We would, however, appreciate the chance to deal with your concerns before you approach the NDPC so please contact us in the first instance.

1. CHANGES TO THIS NOTICE

We may periodically update this Notice and we will notify you by displaying a conspicuous notice on this Platform to inform you of any significant changes to our Notice.

Please check back frequently to see whether there are any updates or changes to this Notice.

CONTACT US

If you have any questions about this Privacy Notice or our privacy practices, please contact our data protection officer  in the following ways:

SHELI TECHNOLOGIES LIMITED

Name of contact person: Opeyemi Adeyeye

Email address: creatorope@sheli.social