Flashchange Privacy Policy

Introduction

Welcome to Flashchange !

We work hard to safeguard your personal information and ensure your information is kept private and secure. This Privacy Policy outlines the type of personal information that is required to operate on the Flashchange Platform (the “Platform”). The privacy of your personal data is extremely important to us. This Privacy Policy covers the personal information we collect or process from users (each, a “User”) of the Platform.
Please note that this Privacy Policy applies to all products and services offered on the Platform and we urge you to read the whole Notice to understand how we process your personal information.

Information that we collect from you

Personal information is any information that identifies or can identify you. The personal information we process about you depends on your interaction with us. For the services we render, we process the following information:

• Registration data: These are information we collect when you sign into our platform either as a merchant or customer or when you register or subscribe for our newsletter. This information includes your name, email address, account details, BVN, photo, country, phone number, location and time zone.
• Marketing/Communication: We use this data to provide information about our services or new product to you. We also use this information to communicate with you in order to provide inquiry and support. The information includes phone number, call log, email address and email content.
• Contact data: This may include your name, email address, house address. We collect this information to provide inquiry and support.
• Technical data: When you visit our website our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the location and other details about your visit.
• Contract or Business Data: includes information collected in the course of providing services or contractual relationships such as information about the contracts such as date of conclusion, the type of contract, its duration and the services to be provided, complaints, signatures and names, feedback. It also includes incorporation documents, Tax ID number, country of operations, details of Directors and shareholder with valid means of identification, signature, utility bills, photographs of promoters their phone numbers, emails, and home addresses.
• Employment data: These are information we collect for recruitment purposes, and it includes professional data such as your education qualification, work experience and history, identity and contact data such as your name, email address, phone number and social media accounts.
• Information about other People: If you provide information to us about any person other than yourself, your employees, counterparties, your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their consent for you to disclose it to us and for you to allow us, and our outsourced service providers to use it.
• Other Data: we may collect data from you to be processed in relation to administrative or judicial proceedings.

Facial Recognition data

For certain authentication functions, the Platform may enable the use of your device’s built-in facial recognition or other biometric verification features (such as Face ID). The Platform itself does not collect, store, process, or share your facial recognition data or other biometric identifiers. All biometric authentication is performed exclusively on your device through your device’s operating system. The Platform only receives confirmation from your device that authentication has been successful, without any access to or retention of the underlying biometric information.

Why we collect your personal information

We use your personal data to manage your account, offer quality service, and improve your overall customer experience. We use aggregate personal information and non-personal information to enhance the Platform and safeguard the security of our service.

How We Use Your Registration Information

We use your registration information to enhance your customer experience, operate and maintain your account in accordance with Nigerian law, investigate and understand how the Platform is used, monitor and protect the security and integrity of the Platform, and better market and advertise our services. We may occasionally consolidate some of your personal information as part of this process for use in reports, statistical analyses, or other interpretations of investment trends for both internal and external purposes. We take care to ensure that no specific client can be identified when we aggregate personal data.

Who we share your personal information with

We do not sell, rent, or trade your personal information with any third parties except as provided in this Privacy Policy, with your consent, or as required by law. We disclose your personal data to the following third parties:

• To our vendors, agents, and service providers that assist us with certain services.
• To financial institutions to enable payment processing.
• To our subsidiaries, and partners.
• To judicial authorities where necessary to litigate, establish and defend legal rights.
• To our legal counsel where the need arises.

When We Share Your Information

Your personal information is not shared with any third parties without your permission or unless as required by law. In order to provide financial services, we may share your registration information with third parties, such as consumer identification verification services, for the purpose of serving you as a User. We have entered into agreements that require that these third parties keep your information confidential.

We also may disclose some of the registration information we collect to service providers, companies that perform marketing and analytics services on our behalf, or to other financial institutions.

We may disclose your registration information in response to service of legal process, such as a court order, summons, subpoenas, or as permitted or required by law when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding legal activities, suspected fraud, front-running or scalping, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use or customer agreements. Personal information about our users may be shared or transferred to our affiliated companies now or in the future, or as part of a merger, acquisition, change of control, debt financing, insolvency, bankruptcy, or asset sale. Any firm that receives such information may use it for business purposes.

Cookies & Pixels

Cookies are small pieces of data that are stored on your computer, mobile phone, or other device. Pixels are small code blocks on a website that allow for another server to measure viewing of a webpage and often are used in connection with cookies. These technologies are used by us to personalize the Platform and enhance your experience. Cookies hold anonymous data, such as whether you accessed the Platform from a computer, tablet, or mobile device. In order to improve your user experience and for marketing purposes, we may keep some personal information in a cookie and/or pixel, such as the website you visited just before accessing the Platform and important financial data. In order to better tailor our marketing and advertising activities, we may also employ a cookie and/or that only keeps anonymous information to follow visitors across the Platform. Cookies, pixels, and similar technologies are not required for the Platform functionality. You are not required to accept any cookies or pixel to use the Platform. However, if you reject cookies or pixels, some features available on the Platform may be less accessible. You can set your web browser to notify you when cookies are being sent or to reject cookies altogether. If they do, be aware that some Platform components might not operate properly.

Your Rights As a User

Users of the Platform possess the following rights:

• Right to request access to and rectification or erasure of your Registration Information.
• Right to withdraw consent at any time which shall not affect the processing of your Registration Information provided with consent before its withdrawal.
• Right to object to the processing of your Registration Information for the purpose of marketing.
• Right to request for the deletion of your personal data.
• Right to request for your Registration Information which will be provided in a structured, commonly used, and machine-readable format.

In addition, further to the provisions of the Nigeria Data Protection Act 2023, your Registration Information shall be:

• Collected and processed in accordance with specific, legitimate, and lawful purpose as consented to by you.
• Adequate, accurate and without prejudice to the dignity of human person.
• Stored only for the period within which it is reasonably needed and secured against all foreseeable hazards and breaches such as theft, cyberattack, viral attack, dissemination, manipulations of any kind, damage by rain, fire, or exposure to other natural elements

Third Party Websites

On our platform, users could come across additional content that contains links to the websites and products of our partners or other third parties. We have no control over the information or links that appear on these websites, and we disclaim any liability for any actions taken by websites that are linked to or from the Platform. Additionally, the links and content of these websites and services may change often. These websites and services can have their own terms of service and privacy policies. Any other website you visit or interact with, including ones that link to the Platform, is governed by its own terms and regulations.

Advertising

Advertising partners, who may also establish cookies, may serve advertisements to Users that display on the Platform. Through the use of these cookies, the ad server can identify your computer each time it sends you an online advertisement, allowing them to gather non-registration-related data on you or anyone else using your computer. Ad networks can use this information, among other things, to offer tailored adverts that they think you’ll find most interesting. The use of cookies by any advertising is not covered by this Privacy Policy.

Children

We do not aim any of our products or services directly at children or persons under the age of eighteen (18) years and we have put appropriate measure in place to block a person below the age of 18years from registering on our platforms. In the event that need arises for us to process personal information of a person below 18years we will obtain a verified consent of the parent or guardian.

How You Can Access or Change Your Registration Information That We Have Collected

Once you have registered on the Platform, you can access your profile, review the information that is stored, and revise that information. If you have any problems, you may also contact us.

Data Security

We work diligently to protect the security of your registration information. We employ several physical and electronic safeguards to keep your information safe. We establish methodical systems and procedures for safeguarding and storing data, use the strongest browser encryption currently offered, and save all of our data on servers in a secure location. Only authorized employees have access to your personal and financial data, and we demand confidentiality agreements from any third-party companies rendering services to us. Furthermore, if you choose to close your account or your account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here.

Legal Bases for Processing Your Personal Data

We may process your personal data on one or more lawful grounds depending on the specific purpose for which we are using your personal data. Kindly contact us if you need further details or clarity about the specific legal ground, we are relying on to process your personal data where more than one ground has been stated. We will rely on any of the legal bases listed below depending on the processing activities:

• We will ask you for your consent in certain processing activities, especially where it involves collection of sensitive personal data. Where we obtain your consent, kindly note that you can withdraw the consent at any time, and we will comply by not further processing your personal data.
• We may process your personal data in order to fulfil the contract you have entered with us or we have entered with your company or take pre-contractual steps at your instruction.
• We may rely on our legitimate interest to process your personal data to tailor our services to suit your need.
• We may process your personal data where law mandates us to do so.

Changes to the Policy

We may modify this Privacy Policy over time. Any changes to the Privacy Policy will be reflected on this page and will become effective immediately upon posting. If the changes are significant, we will do our best to notify you via email or through a notification on the Platform or via email. Please check the effective date below to determine if there have been any changes since you have last reviewed the our Privacy Policy. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications.

International Visitors

This Service is hosted in Nigeria. If you are an international visitor, you should note that by providing your personal information, you are:

• permitting the transfer of your personal information to Nigeria which may not have the same degree of data protection laws as the country in which you reside; and
• permitting the use of your personal information in accordance with this Privacy Policy.

Your Acceptance of These Terms

By using the Platform, you signify your acceptance of this Privacy Policy and you hereby consent to the processing of your Registration Information. If you do not agree to this Privacy Policy, please do not sign up as a User on the Platform. Your continued use of the Platform following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes.

Right to Complaint

Kindly note that you have the right to make a complaint at any time to the Nigeria Data Protection Commission (NDPC), the Regulator for data protection in Nigeria at -ndpb.gov or approach competent court of law to enforce your data protection rights. We would, however, appreciate the chance to deal with your concerns before you approach the NDPC or the Court, so please contact us in the first instance.

Contacting Us

If you have any questions about this Privacy Policy, the practices of the Platform, or your dealings with the Platform, please contact us.