INFORMATION WE COLLECT
Our primary focus in collecting your personal data is to provide you with a safe, efficient, smooth experience tailored to suit our customer’s financial needs without compromising on the safety of their data and as such, when you open a Tribapay account, the following information may be collected from you:
Name, Residential address, Date of birth, Wireless telephone number, email address, a personal photo;
Device type, Machine or Mobile device Identification Number, Geolocation Information, Time zone, Language setting, Browser type, and IP address, MAC address, IP address, IMEI number, IMSI number;
We may ask you for permission to share your current location within your device settings to enhance our services.
We are committed to providing a safe, secure and all-around great environment to carry out your financial transactions. Hence, before having full access to Tribapay’s services, additional information which can be used for the purposes of identity or address verification, risk or fraud management, or compliance purposes throughout our relationship may be requested.
We may also obtain information about you from third parties for identity verification, fraud prevention and similar services.
While using our services, we collect information about your account transactions and may also collect Geolocation Information and/or information about your computer or other access device for fraud prevention and other similar purposes.
Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team or store results when you respond to a survey.
HOW WE COLLECT INFORMATION
We collect information you provide to us directly, for instance, when you register or log on to the Tribapay website or app, create an account, participate in any interactive features on our services, fill out a form, take part in surveys, post on our message boards, upload any documentation, request customer support, make an enquiry, communicate with us by email, phone or post, interact with us on social media among other avenues.
We will also collect your information where you partially complete and/or abandon any information inputted in the sites, and may use this information to contact you to remind you to complete any outstanding form or registration field.
We may also collect technical data from third parties/ public sources such as analytics providers, advertising networks, search information providers. We may obtain contact, financial and transaction data from providers of technical, payment, credit referencing and delivery services based both inside and outside Nigeria as we use third-party service providers to secure information related to financial crime, fraud, sanctions and politically exposed persons.
We want to inform you that whenever you use our Service, in a case of an error in the platform we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (IP) address, device name, operating system version, the configuration of the platform when utilizing our Service, the time and date of your use of the Service, and other statistics.
HOW WE USE YOUR INFORMATION
The Nigerian Data Protection Act 2023 sets out the basis upon which the processing of data shall be regarded as lawful to include: contractual or legal obligations, legitimate interest of the data controller, public interest, vital interest of the data subject or consent. Therefore, one of the aforementioned lawful basis must be established before we process your personal information.
Certain data is collected from you in a bid to either establish the contract we have with you, or to enter into a contract with you. This data is used to:
Provide services to our esteemed customers in accordance with our terms and conditions;
Establish and maintain communication with customers as regards their accounts and other Tribapay services
Exercise our contractual rights in accordance with contracts entered into with our customers
Investigate and resolve complaints among a plethora of other issues.
To ensure we are in compliance with every set law and regulation in place in order to curtail and prevent illegal activities like money laundering, terrorism financing and fraud. In a bid to achieve this, our customers data is needed to: Confirm their identity when they sign up or contact us; Prevent illegal activities like money laundering, tax evasion and fraud; Keep records of information we hold about our customers in accordance with legal requirements; Adhere to banking laws and regulations, which may require us to share customer details with regulators, tax authorities, law enforcement or other third parties.
LEGITIMATE INTEREST OF THE DATA CONTROLLER
We may use information generated and stored during a customer’s use of any of Tribapay’s services for our legitimate activities to enable us offer you the best services, solutions and the best experience. These purposes include to:
To improve our services by implementing aggregate customer preferences;
To manage and protect our information technology infrastructure; To monitor traffic patterns and usage of the Sites to help to improve the Sites design and layout;
Carry out research and development to improve our Services;
Develop and provide new and existing functionality and Services
For the purpose of certain information and provision of certain services, your consent as customer will be sought before we proceed with engaging you with such services.
Furthermore, by providing your personal data in a bid to use Tribapay and any of its services, you consent to the collection and use of the information you disclose to us in accordance with this Policy, including but not limited to your consent for sharing your personal data in line with the terms contained in this Policy. If we decide to change this Policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it. If you do not agree to give consent to the use of personal data as described in this Policy, please do not use or access Tribapay or any of its services.
WHO WE SHARE YOUR INFORMATION WITH
Tribapay does not share your personal information with third parties for its promotional or marketing purposes.
However, we may share your personal information with:
Our affiliates and subsidiaries, but only for purposes allowed by this document;
Law enforcement, government officials, or other third parties if we are compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Tribapay User Agreement, or as otherwise required by law.
These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with such personal information, please contact us so that we will be able to take necessary actions.
SECURITY OF YOUR DATA
We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.
LINKS TO OTHER SITES
YOUR RIGHT AS A DATA SUBJECT
At Tribapay, customers personal data are protected by legal rights enshrined in the Nigeria Data Protection Act 2023, and these rights include the following:
The right to be told how we use your personal data and obtain access to your personal data;
The right to have your personal data rectified or erased or place restrictions on processing your personal data;
The right to object to the processing of your personal data e.g. where the processing is based on our legitimate interests. Please note that this may prevent us from continuing to provide Services to you;
The right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another organisation, where technically feasible (“data portability”);
Where the processing of your personal data is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
The right to object to any decisions based on the automated processing of your personal data, including profiling; and
The right to lodge a complaint with the supervisory authority responsible for data protection matters.
RETENTION OF YOUR DATA
We will not retain your personal data for longer than is necessary for the purposes for which such personal data is collected and processed. This implies that your personal data will only be retained for as long as it is still required to provide you with the Services or is necessary for legal reasons. When calculating the appropriate retention period of your personal data we consider the nature and sensitivity of the personal data, the purposes for which we are processing such personal data, and any applicable statutory/regulatory retention periods.
When we ascertain that personal data can no longer be retained or where you request that we delete your personal data in accordance with your rights contained in the Nigeria Data Protection Act, 2023, we ensure that such personal data is securely deleted, anonymized or destroyed. However, please note that, in some circumstances we may decide to retain your personal data as may be reasonably necessary in accordance with the provisions of the Nigeria Data Protection Act, 2023. In such circumstances, your personal data will be anonymized before retaining same.
DELETING OF DATA
If the data is not required anymore for statutory or contractual obligations, your data will be deleted.
If you choose to delete your Tribapay account, we will delete any data you have previously given us. However this is subject to the retention regulations that apply to such data in accordance with the provisions of the h Nigeria Data Protection Act, 2023.
ACCURACY OF YOUR DATA
It is important that the personal data in custody of Tribapay about you is accurate and current. Please, ensure to keep Tribapay informed in relation to any personal data changes at any time all through your relationship with us.
HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION
You can review and update your personal information in your account settings at any time by logging into your Tribapay account.
This entails acknowledgement of the fact that the Tribapay site and apps may contain information which is designated confidential by us and that you shall not disclose such information without our prior written consent. Your information as a customer is regarded as confidential and therefore will not be divulged to any third party, unless if legally required to do so to the appropriate authorities. We will not sell, share, or rent your personal data to any third party nor use your email address for unsolicited mail. Any emails sent by us will only be in connection with the provision of agreed services.
We commit to taking all necessary precautions to protect your personal information both online and off-line. It is important for you to protect yourself against unauthorised access to your password, your mobile phone or computer. Be sure to log off from the Tribapay site or app when using a shared mobile phone or computer. We also protect your personal data off-line. Access to your personal data is limited to employees, agents or partners and third parties with whom we are working who we reasonably believe will need that information to provide the agreed services to you.
If you have any questions or suggestions about our Terms and Conditions, do not hesitate to contact us at [email protected].