PRIVACY POLICY

This Privacy Policy discloses the privacy practices for (www.wakanow.com). This privacy policyapplies to personal information collected by the company and to all types ofsystems, operations and processes within our environment that involve thecollection, storage, use, transmission, and disposal of Personal Information(described below). It is provided to help you understand what information wecollect about you, how the information collected is used, how we protect it,and your rights to it, among others. 

This Privacy Policy is strictly restricted to only our services andtherefore does not apply to services that are not owned or controlled by us,including third-party platforms/websites. We are committed to handling allpersonal data provided to us in compliance with both applicable and model dataprivacy and protection laws.

 It will inform you of thefollowing:

1.   What personally identifiable information is collected from you throughthe web site, how it is used and with whom it may be shared.

2.    What choices are available to you regarding the useof your data.

3.    The security procedures in place to protect themisuse of your information.

4.    How you can correct any inaccuracies in theinformation.

INFORMATIONCOLLECTION, USE, AND SHARING 

We are the sole owners of the information collected on this site. Weonly have access to collect information that you voluntarily give us via emailor other direct contact from you. We will not sell or rent this information toanyone.

We will use your information to respond to you, regarding the reason youcontacted us. We will not share your information with any third party outsideof our organization, other than as necessary to fulfill your request.

Unless you ask us not to, we may contact you via email in the future totell you about specials, new products or services, or changes to this privacypolicy.

PERSONALINFORMATION

As part of our operations, we collect and process certain types ofinformation (such as names, telephone numbers, addresses etc.) of individualsthat makes them easily identifiable. These individuals include current, past,and prospective employees, guarantors, referees, suppliers/vendors, customersor former customers, and other individuals whom we communicate or deal with,jointly and/or severally (“Data Subject(s)”).

You may voluntarily provide us with certain Personal Information, toenable you to gain access to and use our services. This information relates toan identified person or information that can be used to identify you.

We will always solicit for your consent before sharing or disclosingyour Personal Information with a third party except as may be required for thepurpose of providing you with our services or under applicable legislations.The following are the information that we collect and process:

                   i.             Individual personal information (e.g., name,previous names, date, and place of birth, etc.);

                  ii.             Individual personal contact details (e.g.,address, email address, mobile numbers);

                 iii.             Identifying information (e.g., photo ID,nationality, utility bill, national ID card and/or number, guarantor’s details,referee details, vendor’s personal data,);

                iv.             Information about the ways you interact with thecompany (e.g., channels used, geographic information, software used andinformation concerning your complaints);

                  v.             Information captured in customer documentationor data exchange such as application forms or advisory documents or viatelephone (e.g., records of advice);

                vi.             Information from cookies and similartechnologies used to remember your preferences and tailor content;

               vii.             Data or records of correspondence related torelevant exchanges of information (e.g., emails);

              viii.             Information to fulfill regulatory obligations(e.g., transaction details, user activity);

                ix.             Information from other entities (e.g., relevanttransaction information)

                  x.             Information from third parties providinginformation to identify and manage fraud;

                xi.              Data fromclosed circuit television (CCTV) in and around the company’s facilities (thesemay collect photos or videos of you); and

               xii.             Other information about you that is voluntarilyprovided by filling in online forms or by communicating with us, whetherface-to-face or via other available channels (e.g., by phone, email, oronline).

.

WE USE YOURPERSONAL INFORMATION TO:

a)   provide you with the requiredservices;

b)   respond to your questions or requests;

c)    improve features, platform and website contentand analyse data to develop services;

d)   address inappropriate use of our Services;

e)   prevent, detect and manage risk against fraudand illegal activities using internal and third-party screening tools;

f)     verify your identity and the information youprovide in line with our statutory obligations using internal and third-partytools;

g)   maintain up-to-date records;

h)   resolve disputes that may arise, includinginvestigations by law enforcement or regulatory bodies; and

i)     any other purpose that we disclose to you in thecourse of providing our Services to you.

PURPOSELIMITATION

We collect Personal Information only for identified purposes and forwhich consent has been obtained. Such Personal Information cannot be reused foranother purpose that is incompatible with the original purpose, except consentis obtained for such purpose.

DATA PROCESSINGPRINCIPLES

Your personal data will be:

a)   collected and processed inaccordance with specific, legitimate, and lawful purposes, consented to by you;

b)   adequate, accurate and withoutprejudice to the dignity of the human person;

c)    stored only for the period withinwhich it is reasonably needed; and

d)   secured against all foreseeablehazards and breaches such as theft, cyberattack, viral attack, dissemination,manipulations of any kind, damage by rain, fire, or exposure to other naturalelements.

OUR LAWFUL BASIS FOR PROCESSING PERSONAL INFORMATION

We will only use and process your personal dataas permitted by the Nigerian Data Protection Act, 2023. We have set out below adescription of all the legal bases we may rely on to process your personaldata:

a)   Where you have given us consent tothe processing of your personal data for one or more specific purposes;

b)   where processing is necessary forthe performance of a contract to which you are a party or to take steps at yourrequest prior to entering into a contract;

c)    where processing is necessary forcompliance with a legal obligation to which we are subject;

d)   where processing is necessary toprotect your vital interests or the vital interests of another natural person,and

e)   where processing is necessary forthe performance of a task carried out in the public interest or in exercise ofan official public mandate vested in us.

f)     For the purpose of the legitimateinterests pursued by us as data controller or data processor, or by a thirdparty to whom the data is disclosed.

            Note that we may process yourpersonal data for more than one lawful ground depending on the specific purposefor which we are using your personal data. Please contact us by sending anemail to: legal@wakanow.com ifyou need details about the specific legal ground we are relying on to processyour personal data where more than one ground may have been used to processyour personal data.

  For thepurpose of this Privacy Policy, consent means any freely given, specific,informed, and unambiguous indication of the Data Subject's wishes by whichthey, through a statement or a clear affirmative action, signify theiragreement to the processing of Personal Information relating to them.

DATAMINIMIZATION

We limit Personal Information collection and usage to data that isrelevant, adequate, and necessary for carrying out the purpose for which thedata is processed. We will evaluate whether and to what extent the processingof Personal Information is necessary and where the purpose allows, anonymizeddata will be used.

DATA RETENTION

We will retain your Personal Information for as long as is needed toprovide our services to you, comply with our legal and statutory obligations orverify your information with the required verification authorities.

            Weare statutorily obligated to retain the Personal Information and data youprovide us with to carry out our services and in compliance with laws andregulatory guidelines applicable to us and our partners. Therefore, even afterdiscontinuance of our services, we will retain certain Personal Information andtransaction data to comply with these obligations.

For all Personal Information and records obtained, used, and stored byus, we shall perform periodical reviews of the data retained to confirm theaccuracy, purpose, validity, and requirement to retain.

Thelength of storage of your Personal Information shall, amongst other things, bedetermined by:

a)   the contract terms agreed between us and theData Subject or as long as it is needed for the purpose for which it wasobtained; or

b)   where the relationship has statutory implicationor a required retention period; or

c)    where there is an express request for deletionof the Personal Information by the Data Subject, provided that such requestwill only be treated where the Data Subject is not under any investigationwhich may require us to retain such Personal Information or there is nosubsisting contractual arrangement with the Data Subject that would require theprocessing of the Personal Information; or

d)   where we have another lawful basis for retainingthat information beyond the period for which it is necessary to serve theoriginal purpose.

YOUR ACCESS TO AND CONTROL OVERINFORMATION

Once your Personal Information is held by us, you are entitled to reachout to us to exercise the following rights which are guaranteed by the NigeriaData Protection Act with some limitations.

a)    Request access to your personal data (commonly known as a “datasubject access request”): This enables you to receive acopy of the personal data we hold about you and to check that we are lawfullyprocessing it. You will not have to pay a fee to access your personal data (orto exercise any of your other rights). However, we may charge a reasonable feeif your request is clearly unfounded, repetitive, or excessive. Alternatively,we may notify you of our refusal to comply with your request in thesecircumstances. Where we have reasonable doubts concerning the identity of thenatural person making the request for information, we may request the provisionof additional information necessary to confirm the identity of the DataSubject. Where data is held electronically in a structured form, such as in aDatabase, as the Data Subject, you have a right to receive that data in acommon electronic format;

b)    Right to request correction of the personal data that we holdabout you: This enables you to have anyincomplete or inaccurate data we hold about you corrected, complete or updated,though we may need to verify the accuracy of the new data you provide to us.

c)    Right to request erasure or deletion of your personal data: This enables you to ask us to delete or remove personal datawhere there is no good reason for us continuing to process it. You also havethe right to ask us to delete or remove your personal data where you havesuccessfully exercised your right to object to processing (see below), where wemay have processed your information unlawfully or where we are required toerase your personal data to comply with local law. Note, however, that we maynot always be able to comply with your request of erasure for specific legalreasons which will be notified to you, if applicable, at the time of yourrequest.

d)    Right to object to the processing of your personal data: Where we are relying on a legitimate interest (or those of athird party) there maybe something about your situation which could justify anobjection to processing on this ground as you may feel it impacts on yourfundamental rights and freedoms. You also have the right to object where we areprocessing your personal data for direct marketing purposes. In some cases, wemay demonstrate that we have compelling legitimate grounds to process yourinformation which override your rights and freedoms.

e)    Right to request restriction of processing of your personal data: This enables you to ask us to suspend the processing of yourpersonal data in the following scenarios:

                             i.      If you want us to establish thedata’s accuracy;

                           ii.      Where our use of the data isunlawful but you do not want us to erase it;

                          iii.      Where you need us to hold the dataeven if we no longer require it as you need it to establish, exercise or defendlegal claims; or

                          iv.      You have objected to our use of yourdata but we need to verify whether we have overriding legitimate grounds to useit.

f)     Request the transfer of your personal data to you or to a thirdparty: We will provide to you, or a thirdparty you have chosen, your personal data in a structured, commonly used,machine-readable format. Note that this right only applies to automatedinformation which you initially provided consent for us to use or where we usedthe information to perform a contract with you.

g)    Right to withdraw consent at any time where we are relying onconsent to process your personal data:This will not affect the lawfulness of any processing carried out before youwithdraw your consent. If you withdraw your consent, we may not be able toprovide certain services to you. We will advise you if this is the case at thetime you withdraw your consent. Your request will be reviewed by us and carriedout except as restricted by law or our statutory obligations. You may declineto provide your Personal Information when it is requested by us, however,certain services or all services may be unavailable to you. You may review andupdate your Personal Information directly or by contacting us.

SECURITY

We take precautions to protect your information. When you submitsensitive information via the website, your information is protected bothonline and offline. Wherever we collect sensitive information (such as creditcard data), that information is encrypted and transmitted to us in a secureway. You can verify this by looking for a closed lock icon at the bottom ofyour web browser, or looking for "https" at the beginning of theaddress of the web page.

While we use encryption to protect sensitive information transmittedonline, we also protect your information offline. Only employees who need theinformation to perform a specific job (for example, billing or customerservice) are granted access to personally identifiable information. Thecomputers/servers in which we store personally identifiable information arekept in a secure environment.

UPDATES,MODIFICATIONS AND AMENDMENTS

We reserve the right to update, modify, change, or revise this PrivacyPolicy from time to time. The changes will not be retroactive, and the mostcurrent version of this Privacy Policy which will always be on this page andwill continue to govern our relationship with you. We advise that you checkthis page often, referring to the date of the last modification on the page. Wewill also try to notify you of any material changes which could be done viaemail associated with your account or service notification. By continuing touse our services after the changes become effective, you agree to be bound bythe revised Privacy Policy.

If you feel that we are not abiding by this privacy policy, you shouldcontact us immediately via email at legal@wakanow.com.

REGISTRATION 

For effective use of this website, users are advised to complete theregistration form. During registration a user is required to give certaininformation (such as name and email address). This information is used tocontact you about the products/services on our site in which you have expressedinterest. At your option, you may also provide demographic information (such asgender or age) about yourself, but it is not required.

COOKIES

We use "cookies" on this site. A cookie is a piece of datastored on a site visitor's hard drive to help us improve your access to oursite and identify repeat visitors to our site. For instance, when we use acookie to identify you, depending on your browser settings you would not haveto log in a password more than once, thereby saving time while on our site.Cookies can also enable us to track and target the interests of our users toenhance the experience on our site. Usage of a cookie is in no way linked toany personally identifiable information on our site.

Some of our business partners may use cookies on our site (for example,advertisers). However, we have no access to or control over these cookies.

SHARING 

We share aggregated demographic information with our partners andadvertisers. This is not linked to any personal information that can identifyany individual person. We use a credit card processing company to bill usersfor products and services. These companies do not retain, share, store or usepersonally identifiable information for any secondary purposes beyondfulfilling your order.

We partner with other parties to provide specific services. When theuser signs up for these services, we will share names, or other contactinformation that is necessary for the third party to provide these services.These parties are not allowed to use personally identifiable information exceptfor the purpose of providing these services.

Using the Wakanow mobile phone and tablet Apps (the "MobileApps")

When you use the Mobile App, we collect and use information about you inthe same way and for the same purposes as we do when you use our website.

In addition to this, we also use some other information that we collectautomatically when you use our Mobile Apps e.g. we collect information aboutMobile App functionality that you access and use. This allows us to identifythose areas of the Mobile App that are of interest to our customers so that wecan refine and continuously improve the Mobile App. The information we collectfor this purpose does not enable us to directly identify you.

When you use our Mobile App, you can choose to allow access to yourcurrent location – provided by your mobile device using GPS or similartechnologies – in order to identify nearby hotels or airports. If you choose toallow access, this location data may be collected anonymously as part of searchrequests logged by our servers. You can switch off the Mobile App’s access toyour location at any time through your phone settings menu.

Each Mobile App will also send us error-reporting information in theevent that it crashes or hangs. This enables us to investigate the error and toimprove the stability of the Mobile App for future releases. We do not use thisinformation for any purpose other than investigating and remedying the error.

You always have the ability to control what information a Mobile Appsends to us. You can exercise this control either by changing the settings ofthe Mobile App under its setting menu or changing the settings of your mobiledevice. Alternatively, you can remove the Mobile App from your mobile deviceentirely and access our services through our website.

We may share your information with law enforcement agencies, public ortax authorities or other organizations if legally required to do so, or if wehave a good faith belief that such use is reasonably necessary to:

a)   comply with a legal obligation,process, or request (including tax and related reporting requirements);

b)   enforce our Terms of Service andother agreements, policies, and standards, including investigation of anypotential violation thereof;

c)    detect, prevent, or otherwiseaddress security, fraud, or technical issues; or

d)   protect the rights, property orsafety of us, our users, a third party or the public as required or permittedby law (including exchanging information with other companies and organizationsfor the purposes of fraud protection and credit risk reduction).

Please seethe list and details of categories of third-party processors we share yourpersonal data with below: Flutterwave- payment gateway

TRANSFER OFPERSONAL INFORMATION TO FOREIGN COUNTRY

Where Personal Information is to be transferred to a country outsideNigeria, we shall put adequate measures in place to ensure the security of suchPersonal Information. In particular, we shall, among other things, confirmwhether the country is on the Nigeria Data Protection Commission ("NDPC”)Whitelist of Countries with adequate data protection laws.

Transfer of Personal Information out of Nigeria would be in accordancewith the provisions of the Nigeria Data Protection Act ("NDPA”) 2023. Wewill therefore only transfer Personal Information out of Nigeria on one of thefollowing conditions:

a)   the consent of the Data Subject hasbeen obtained;

b)   the transfer is necessary for theperformance of a contract between us and the Data Subject or implementation ofpre-contractual measures taken at the Data Subject’s request;

c)    the transfer is necessary toconclude a contract between us and a third party in the interest of the DataSubject;

d)   the transfer is necessary for reasonof public interest;

e)   the transfer is for theestablishment, exercise, or defense of legal claims;

f)     the transfer is necessary to protectthe vital interests of the Data Subjects or other persons, where the DataSubject is physically or legally incapable of giving consent.

We will take all necessary steps to ensure that your PersonalInformation is transmitted in a safe and secure manner. Details of theprotection given when your Personal Information is transferred outside Nigeriashall be provided to you upon request.

LINKS 

This web site contains links to other sites. Our website includeshyperlinks to, and details of, third party websites.

Please be aware that we are not responsible and have no control over thecontent or privacy practices of such other sites. We encourage our users to beaware when they leave our site to read the privacy statements of any other sitethat collects personally identifiable information.

VISITINGOUR WEBSITE FROM OUTSIDE NIGERIA

If you are visiting our website from outside Nigeria, please be awarethat your information may be transferred to, stored, and processed in Nigeriafrom where our central database is operated. The data protection law and otherlaws of Nigeria may vary in content or may not be as comprehensive as those inyour country, but please be assured that we take steps to ensure that yourprivacy is protected. By using our services, you understand that yourinformation may be transferred to our facilities and to those third partieswith whom we share it as described in this Policy.

SURVEYS& CONTESTS/PROMOTIONS 

From time-to-time our site requests information via surveys or contests.Participation in these surveys or contests is completely voluntary and you maychoose whether or not to participate and therefore disclose this information.Information requested may include contact information (such as name andaddress), and demographic information (such as post code, age level etc).Contact information will be used to notify the winners and award prizes. Surveyinformation will be used for purposes of monitoring or improving the use andsatisfaction of this site.

 PRIVACY POLICY

This privacy policy applies  topersonal information collected through our website and personal informationcollected offline.

TERMSAND CONDITIONS

Please also visit our Terms and Conditions section establishing the use,disclaimers and limitations of liability governing the use of our websiteat http://www.wakanow.com

YOURCONSENT

By accessing or using our services in any manner, you suggest to us thatyou have read and adopted this Privacy Policy and consent to the data practicesdescribed herein.

You agree that upon granting us your consent, you have the legalcapacity to give consent and you are aware of your privacy rights and youroption to withdraw your consent at any given time.

If you do not accept thisPrivacy Policy and do not meet or comply with the provisions set forth herein,then you may not use our services.

AGE RESTRICTION

If you access our services or platform and you are below 18 years, yourepresent and warrant that you have obtained consent from your parent(s) orlegal guardian(s).  If you haveinadvertently provided personal data of a child to us, please notify us at Alma@wakanow.comand we will delete such personal data.

Consistent with Section 8 of the Nigeria Child Rights Act (“the Act”),Cap C50, Laws of the Federation of Nigeria 2010, Section 31 of the Nigeria DataProtection Act 2023, we will never knowingly request Personally IdentifiableInformation from anyone below the age of 18 under the Act without priorverifiable parental consent. If we become aware that a child below the age of18 under the Act has provided us with personal data without verifiable parentalconsent, we will use our best efforts to remove such information from ourfiles. If as a parent or guardian, you become aware that your child or wardchild has provided us with any information without your consent, please contactus through the details provided in this Privacy Policy.

COMPLIANCE

Please note that the collection, processing, security, storage, anderasure of your personal data including any updates to this privacy policy willbe in accordance with existing or new privacy and data protection provisionsand laws in Nigeria which includes but not limited to the following:

a)   Constitution of the Federal Republicof Nigeria 1999 (as Amended);

b)   Nigeria Data Protection Act 2023("NDPA”); 

c)    Nigeria Data Protection Regulation2019 ("NDPR”); 

d)   NDPR 2019 Implémentation Framework ;

e)   Nigeria Cybercrimes (Prohibition,Prevention, Amendement) Act 2024 ;

f)     Nigeria Money Laundering (Preventionand Prohibition) Act, 2022;

g)   Nigeria Federal Competition andConsumer Protection Act, 2018 (FCCPA);

h)   Nigeria Freedom of Information Act2011;

i)     Central Bank of Nigeria Risk-BasedCybersecurity Framework and Guidelines for Other Financial Institutions 2022.

COMPLAINTS ANDREMEDIES

You may file a complaint in accordance with this Privacy Policy if youbelieve that any provision of this Privacy Policy or your privacy rights havebeen violated in respect of your personal information or if your access to ourServices have been compromised, to enable us to take the necessary stepstowards ensuring the security of your Personal Information. All complaints mustbe addressed to the company by sending an email to our Data Protection Officerusing the following contact details:

Email: Alma@wakanow.com

Please note that, the complaint and resolution procedure is notprejudicial to your right to complain to the data protection authorities (inthis case, you should contact the Nigeria Data Protection Commission (NDPC)using the following contact details: 

Address:

NDPC: No. 5, Donau Crescent,

Off Amazon Street, Maitama,

 Abuja, Nigeria.

Email:  info@ndpc.gov.ng

We will notify you of any breach and also notify Nigeria Data ProtectionCommission (NDPC) within 72 hours of becoming aware of such breach. 

You may also seek redress in a court of competent jurisdiction. Wewould, however, appreciate the chance to deal with your concerns before youapproach the data protection authorities. Kindly contact us in the firstinstance by sending an email to: Alma@wakanow.com

QUESTIONS ANDINQUIRIES

You may also contact us if you have any questions, comments and requestsrelating to this Privacy Policy or would like to find out more about exercisingyour data protection rights.  Pleasecontact us via Alma@wakanow.com

If you are in Lagos, we can also be reached at:

WAKANOW.COM  LIMITED

Plot 8 Elegushi Beach Road

Off Ikate Roundabout

Lekki/Epe Expressway

Lagos State, Nigeria.