1. Personal Data: Means any information relating to you, including your name, identification number, location data, online identifier address, photo, email address, pins, passwords, bank details, posts on our Platforms, religion, date of birth, health, race/tribe, nationality, ethnicity, political views, trade union membership, criminal records, medical information, and other unique identifiers such as but not limited to MAC address, IP address, IMEI number, Bank Verification Number, IMSI number, SIM and others. It also includes factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.
2. Process/Processing: Means any operation or set of operations which is performed on your Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
3. Consent: We kindly request that you carefully read through this Policy and click on the ‘Agree’ icon below, if you consent to the terms of this Policy, particularly with respect to the processing of your Personal Data. That notwithstanding, if you proceed to use any of our Platforms and services, it will deemed that you have provided your express consent to the terms of this Policy.
4. Age: You must be at least 18 years old to use our services or any of our Platforms. Individuals under the age of 18, or applicable age of maturity, may utilize our Platforms services only with involvement of a parent or legal guardian, under such person’s account. Regardless, all Personal Data which we may process shall be in accordance with this Policy and other applicable laws.

In the course of your engagements with us or through our Platforms, we collect Personal Data for various legal reasons, largely to enable us to personalize your experience and to provide a more efficient service to you. Some of the reasons we collect Personal Data are to:

1. provide services and customer support;
2. process transactions, payment requests, and send notices about transactions;
3. create an account with us for the provision or use of our services;
4. communicate with you about your account or transactions with us and send you information or request feedback about features on our website and applications or changes to our policies;
5. send you periodic emails and updates pertaining to our products and services;
6. verify customers’ identity, including during account creation and password reset processes;
7. manage your account and provide you with efficient customer service,
8. send you offers and promotions for our services and investment opportunities
9. resolve disputes, process payments and troubleshoot problems;
10. detect, investigate and prevent activities that may violate our policies or be illegal;
11. manage risks, or to detect, prevent, and/or remediate fraud, violation of policies and applicable user agreements or other potentially prohibited or illegal activities;
12. execute our contractual obligations to you;
13. improve our services and functionality by customizing user experience;
14. measure the performance of our services and improve their content and layout;
15. manage and protect our information technology infrastructure;
16. provide targeted marketing and advertising, provide service or transaction update notices, and deliver promotional offers based on communication preferences;
17. obtain a means by which we may contact you; either by telephone, text (SMS), email messaging, social media, etc;
18. conduct background checks, compare information for accuracy and verify same with third parties;
19. identify or address a violation and administer our policies and terms of use;
20. comply with legal, contractual and regulatory obligations;
21. execute your specific requests or use same for a specific purpose as you may instruct;
22. investigate and respond to your complaints or enquiries;
23. process your access to our services, Platforms, or functions from time to time;
24. If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is required and obtain your consent.

We can only use your Personal Data if we have a lawful basis for doing so. We consider that the lawful basis for processing your Personal Data are as follows:

• to comply with our legal and regulatory obligations
• to perform a contract with you or to take steps at your request before entering into a contract
• if we have your consent for specific processing of your Personal Data for one or more specific purposes
• to use your Personal Data in our business interest to enable us to give you the best services
• for the performance of a task or function carried out in the interest of the public.
• when it is required for the protection of your vital interests.

• Fraud Prevention and Risk Management: to help prevent fraud or assess and manage risk.
• Customer Service: for customer service purposes, including to help service your accounts or resolve disputes.
• Legal Compliance: to help them comply with anti-money laundering and counter-terrorist financing verification requirements.
• Service Providers: to enable service providers under contract with us to support our business operations, such as fraud prevention, marketing, customer service and technology services. Our contracts dictate that these service providers only use your Personal Data in connection with the services they perform for us and not for their own benefit.

Please allow up to 1 (One) month for requests to be processed. The Company reserves the right to charge a reasonable fee to process excessive or repeated requests.