Building the Next-Generation Payment Service in Africa

Introduction

At Breezepay Limited a registered company under the Corporate Affairs Commission with the number RC. 1887394, a subsidiary of Brizz Limited Inc., we are committed to protecting the privacy and security of our customers' personal information.

We are provider of the Breezepay services, an API service and mobile application software (referred to as the “Breezepay APP”) and all affiliated products such as Breezepay Transfer, Breezepay code and other services listed on our website.

"Partners" are selected companies whom we choose to work with to offer services such as APIs, Terminals, Utilities that are used for the functionality of a variety of services.

“Service” or “Services” include promotions, advertorials, wallet creation, wallet funding, Breezepay code generation, Breezepay transfer, Virtual accounts, Virtual wallets

This Privacy Policy outlines how we collect, use, disclose, and protect your information when you use our mobile payment and API platform. By accessing or using our services, you agree to the terms of this Privacy Policy.

1. Information We Collect:

We collect the following types of information from our users:

• Personal Information: This may include your name, address, email address, phone number, date and place of birth, gender and other contact information provided when you register for an account or make a transaction.
• Financial Information: We collect payment card information, bank account details, bank verification number, identification documents, address and pictures and transaction history necessary to facilitate payments and transactions date
• Usage Information: We gather information about how you interact with our platform, including device information, IP address, browser type, and usage patterns.
• Location Information: With your consent, we may collect location data to provide location-based services.
• AML/CFT checks: We collect information that we need to support our regulatory obligations such as information about transaction details.

2. How We Use Your Information

We use the information we collect for the following purposes:

• To process transactions and provide payment services.
• To verify your identity and prevent fraud.
• To improve and personalize our services, including customer support and marketing.
• To communicate with you about your account, transactions, and updates to our services.
• To comply with legal and regulatory requirements.
• We may also use personal information we have about you such as your email address to deliver advertising to you directly or on our websites, provide updates on special deals and offers that might interest you (unless you tell us otherwise).
• We may send you general announcements or important news about your account, request your feedback and we believe you should be able to select what kinds of information you receive from us via email.
• We may need to record conversations you have with us including phone calls, face-to-face meetings, letters, emails and any other kinds of communication. These recordings may be used to check your instructions to us and improve on our product and service delivery.

3. Data Sharing and Disclosure:

Towards enhancing our service delivery, we may share data with our technical support service providers, partners, associates, and subsidiaries in the group. However, we execute compliant data sharing agreements or data processing agreements to provide an extra layer of protection for personal information shared in the process.

We may share your information with third parties under the following circumstances:

• With your consent or at your direction.
• To our affiliates and service providers who assist us in providing our services.
• With merchants or other parties involved in transactions initiated by you.
• In response to legal requests or to protect our rights, property, or safety.

Please note that we will not share the video of your face that we collect during a liveness check with advertisers or anyone else other than the third-party service provider that facilitates the liveness check process or authenticates our KYC/AML/ATF process.

If at any time you choose to withdraw your consent for us to use this video for your liveness check, we will delete it.

However, please note that this would affect your ability to use your account as certain services are dependent on us processing your video for the liveness check.

Your Rights.

• The right to be informed
  BreezePay will only use your information when you have provided your consent or when the company is required by the law to do so.
• The rights to access
  Individuals have the right to access information the Bank holds, access their personal data and other supplementary information and obtain information about how we process it
• The right to restrict processing
  Individuals have a right to block or withdraw their consent to our processing of your information, which you can do at any time. When processing is restricted, we are permitted to store personal data, but not further process it.
• The right to rectification
  Individual is entitled to have personal data rectified if it is inaccurate or incomplete. If this personal data in question has been disclosed to third parties, they must be informed of the rectification where possible. The Bank must also inform the individuals about the third parties to whom the data has been disclosed where appropriate.
• The right to erasure
  Individuals have the right to request the deletion or removal of personal data where there is no compelling legal or regulatory requirement for its continued processing. The company will make sure that this right is protected.
• The right to data portability
  We will ensure that personal data is moved, copied or transferred easily from one IT environment to another in a safe and secure way, without hindrance to usability.
• The right to object
  Individuals has the right to object to our processing of their information in some circumstances.

Children's Protection

Our services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children. If you believe that we have inadvertently collected information from a child, please contact us immediately.

Breezepay understands and acknowledges the importance of safeguarding children’s privacy, hence, our sites are not intentionally designed for or directed at children under the age of 18. It is our policy never to knowingly collect or maintain information about anyone under the age of 18, except as part of an engagement to provide child-categorized services which require parental guardianship.

4. Data Security and Integrity:

We implement appropriate technical and organizational measures to protect the security and confidentiality of your information from unauthorized access, data loss, misuse, alteration or destruction. To the best of our ability, access to your personal information is limited to those who have a need to know and are required to always maintiain the confidentiality of such information. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security against all threat actors. Hence, we also make reasonable efforts to retain personal information only for so long:

• as the data subject asks that the information be deleted
• as necessary to comply with legal, regulatory, internal business or policy requirements, or
• the information is necessary to comply with an individual's request.

5. Your Choices:

You can manage your account settings and preferences through our platform. You may choose to opt-out of certain communications or data sharing practices, although this may affect your ability to use our services

For certain information, we'll ask for your consent. We'll ask for your consent to:

• Market and communicate our products and services. You can always unsubscribe from receiving these if you want to.
• Help protect you against fraud by tracking the location of your phone if you've authorized it.
• View your contact list for airtime purchases.

You have the right to ask Us not to process Your Personal Information at any time.

You have the right to use Our Platforms without consenting to direct marketing and the communication services that We provide. We will inform You (before collecting Your Personal Information) if We intend to Use Your Personal Information for such purposes or if We intend to disclose Your Personal Information to any third party for such purposes. We always use the most recently submitted form to be Your current consent status. If You are a registered User, but not signed in when You submit a form, We will not be able to Use Your saved settings so will deem Your consent choice to be as per the form You submit at the time. You can exercise Your right to prevent such processing by selecting the specific options in the fields or forms when You become a registered User.

You also have a right to:

• Request access to or rectification of the Personal Information which We hold about You;
• Request erasure of Your Personal Information in certain circumstances;
• Restrict the processing of Your Personal Information;
• Receive Your Personal Information that You have provided to Us;
• Object to or restrict Our processing of Your Personal Information in certain circumstances; and
• Request that We transmit Your Personal Information to another data controller.

Where We process Your Personal Information because You have given Us Your consent to do so, You have the right to withdraw Your consent at any time.

Where We process Your Personal Information under legitimate interests, if You object to processing, this will not affect any processing which has already taken place. In some limited instances, objecting to processing of all Your Personal Information may mean You are not able to use some of Our Services or Platforms.

To exercise any of these rights, please contact the Data Protection Officer whose contact details are provided earlier in this Policy. We may need to request specific information or identification documents from You to help Us confirm Your identity and ensure Your right to access Your Personal Information (or to exercise any of Your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact You to ask You for further information in relation to Your request to speed up Our response.

We try to respond to all legitimate requests within one month. Occasionally it may take Us longer than a month if Your request is particularly complex or You have made a number of requests. In this case, We will notify You and keep You updated.

As part of Our Data Protection obligations and to help Us improve Our Service, We maintain a register of Data Subject Right Requests which contains limited Personal Information (email address, type of request, reason for request, resolution, reference number, application number etc.). These records are only available to Our Data Protection Team or those with a need to know and would only be made available to the Information Commissioner’s Office upon request. We will retain these records for up to 6 years from the conclusion of the Data Subject Right Request, after which any Personal Information will be anonymised.

Your duty to inform us of changes

It is important that the Personal Information We hold about You is accurate and current. Please keep Us informed if Your Personal Information changes during Your relationship with Us.

Cookies and tracking

Like many website and App providers, We use “cookies” to enable Us to personalise Your visits to Our Platforms, simplify the signing-in procedure, keep track of Your preferences and to track the usage of Our Platforms. We use a mixture of third- and first-party cookies. Our lawful basis for using cookies are as follows:

• Strictly Necessary Cookies: We rely on legitimate interests as Our lawful basis for collecting and processing this data;
• Functional Cookies: We rely on consent as Our lawful basis for collecting and processing this data; and
• Targeting and Tracking Cookies: We rely on consent as Our lawful basis for collecting and processing this data.

Some web browsers incorporate a “Do Not Track” feature. Currently, as there is not yet an accepted industry standard for how to respond to Do Not Track signals, Our Services and Our Platforms do not currently respond to such signals, however You can:

• Generally, manage Your Cookie settings on our Cookie page; and
• If You want to restrict ads in general on Your Devices You may opt out from ad tracking by enabling “Limit Ad Tracking” or “Opt Out of Ads Personalisation” (as applicable to Your Device) in Your Device settings.

For full details about what cookies We set and why We use them, please see Our Cookie Policy.

Third Party Advertising

As well as providing the Services on Our Platforms, We also feature advertising from third parties. We use a range of advertising partners and technologies to help deliver third party advertisements on Our Platforms which may be relevant to You. To help ensure the advertisements are relevant, We match property listings data, information from cookies and clickstream data to create audience segments. We share Our audience segments with Our advertising partners and only allow certain companies to purchase advertising space on Our Platforms. For example, third parties may wish to display advertisements to Users of Our Platforms which We deem as being renters and therefore We will offer space On Our Platforms where renters visit.

We use different technologies and practices for advertisers to purchase advertising space on Our Platforms. This includes Us selecting advertisements through a bidding process from selected companies which allows real-time advertising on Our Platforms, working with digital agencies or directly with third party advertisers. You can request a list of the partners with whom We work by contacting Our Data Protection Officer.

To help Us deliver third party advertisements on Our Platforms We do use Cookies. For more information, please see Our Cookie Policy.

Special Category Data and Criminal Offence Data

For Our tenant referencing, insurance, tenant and financial Services, We do collect special categories of Personal Information about You (this may include Your race or ethnicity, information about Your health and any criminal convictions). We rely on explicit consent to collect and process this data, the only exception being for insurance products where We rely on ‘insurance’ as Our condition of processing. We only keep this information for as long as is necessary. We employ appropriate technical and organisational measures to ensure Your Personal Information is secure.

Aggregated Data

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from Your Personal Information but is not considered Personal Information in law as this data does not directly or indirectly reveal Your identity. For example, We may aggregate Your usage data to calculate the percentage of users accessing a specific feature on Our Platforms. However, if We combine or connect aggregated data with Your Personal Information so that it can directly or indirectly identify You, We treat the combined data as Personal Information which will be used in accordance with this Policy.

Change of purpose

We will only use Your Personal Information for the purposes for which We collected it, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose. If You wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Us. If We need to use Your Personal Information for an unrelated purpose, We will notify You and We will explain the legal basis which allows Us to do so. Please note that We may process Your Personal Information without Your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Changes to this policy

We may change the terms of this Policy at any time. Any changes We may make to this Policy in the future will be posted on Our Platforms and displayed on-screen when You use Our App.

You may be required to read and accept any revised Policy to continue Your use of Our Platforms. The amended terms will be made available with new uploads or updates of the App and will be displayed in the Privacy Policy section of the App.

Please check back frequently to see any updates or changes to this Policy, as You will be deemed to accept such changes from Your continued use of Our Platforms.

6. How Long we keep you Data:

We keep your information as long as you are a Breezepay customer and for any additional period as required under applicable law or regulations. These retention requirements supersede any right to erasure requests under applicable data protection laws. We cannot therefore erase your data in relation to your Breezepay Account until after this time period, however we can assure you that your data will be held safely and securely whilst under our supervision.

When do we delete your data?

We are basically storing and processing your personal data only as long as it is necessary to fulfil our obligations under the agreement with you or as long as the law requires us to store it. That means, if the data is not required anymore for statutory or contractual obligations, your data will be deleted. If you choose to delete your Breezepay account, we will delete any data you have previously given us, including the video of your face uploaded during the liveness check. However, this is subject to the retention regulations that apply to such data as stipulated by the regulators.

7. Contact Us:

If you would like further information on anything included in this Privacy Policy, contact us at:
1216, Ibiyinka Olorunbe Close, off Amodu Ojikutu Street, Victoria Island, Lagos, support@breezepay.io
This Privacy Notice may be updated from time to time and the most recent version can be found on www.breezepay.io

Last Updated: This privacy policy was last updated 7th February, 2024

This Privacy Policy is effective as of the date indicated above and replaces any previous versions.