This privacy policy gives a detailed explanation on how personal information is collected, used, stored and disclosed by Enricher Capital Trust Limited RC Number: 1753940 and Enricher Cooperative Society LTD RN 15826 (“Enricher”, “we”, “us”, and “our”). This Privacy Policy applies to consumer users (individually referred to as “you”) of our websites, applications, and online services to which this Privacy Policy is posted (collectively, our “services”).

By accessing our making use of our services, you agree with this Privacy Policy. The provisions contained within this Privacy Policy overrides all previous notices and statements regarding our privacy practices with respect to our services. If you do not comply with every provision of this Privacy Policy and our Terms and Conditions, you may not access or use any of our services.

Application of this Privacy Policy

This Privacy Policy applies to your use of (irrespective of your means of access; a desktop, a laptop, a tablet, mobile phone, or other consumers’ electronic device.) our Services.

Collection of information

You can visit our website, without revealing any information about yourself. When you make an inquiry on our platform via our services or register for a Enricher account, we may collect personal information from you which may include your name, email address, mobile phone number, banking information, BVN, and other information that identifies you (collectively, “Personal Information”).

By providing your Personal Information to us, you expressly agree to our collection, use, storage, and disclosure of such information as described in this Privacy Policy. We may also ask you to create login information for your Enricher account, such as a username and password. When you provide your mobile phone number, we may ask for your consent to receive text messages relating to our Services at that number. The collection and processing of your personal data are in accordance with the National Information Technology Development Agency Act 2007 (the “Act”), Nigeria Data Protection Regulation 2019 (the “Regulations”) and the provisions and prescriptions of Section 5; Part 1 and Part 2 of National Information Systems and Network Security Standards and Guidelines.

Information about your transaction with Us

When you use Enricher to carry out financial transactions, we collect nonpublic personal information in connection to each transaction; this includes transaction time, naira amount, merchant details, and biller details. We may also collect photos, memos, or other information that you attach to your transactions.

Information we automatically collect

We (or our service providers acting on our behalf) may collect information about your use of our Services. This information may include:

• Personal Information as well as statistical information that does not identify you (“Analytics”). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy.

Information that we automatically collect in connection with your access or use of our Services may include:

• Information: We may obtain Device-specific information (such as hardware model, operating system version, unique device identifiers, mobile network information, and your mobile phone number). We may associate your Device identifiers or mobile phone number with your Enricher account.
• Log Information: We may collect your location information from your mobile device with your prior consent. We may record or log information from your Devices, their software/hardware, and your activity accessing or using our Services. This information may include:

– The Device’s Internet Protocol (“IP”) address

– Date and time stamps of transactions

– System configuration information.

– Other interactions with our Services

– Identification numbers associated with your Devices (IMEI,etc.)

– Device event information, such as crashes, system activity, and hardware settings

– Location preferences (GPS)

Information collected by cookies and other technologies

We use various technologies to collect information on our Services and other websites. These technologies may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in any device memory that enables us to improve our services, your experience, to see which areas and features of our services are popular and to keep track of visits to our site. For more information about cookies and how they function, visit www.allaboutcookies.org.

The cookies we use in connection with our Services include:

• Session cookies: Session cookies are temporary cookies that expire and are automatically erased whenever you close your browser window. We use session cookies to grant users access to content and for actions to be carried out, they must be logged into their Enricher account.
• Persistent cookies: Persistent cookies usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We use persistent cookies to keep track of usage patterns so we can improve our Services. For instance, we may use a persistent cookie to associate you with your Enricher account or to remember your choices for our Services.
• Third-party cookies We permit certain third parties to place cookies through our Services to provide us with better insights into the use of our Services and user demographics and to advertise our Services to you. These third parties may collect information about your online activities over time and across different websites when you access or use our Services. For instance, we utilize Google Analytics to analyze usage patterns for our Services. Google Analytics generates a cookie to capture information about your use of our Services, which Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify its cookie, but this will not be associated with any other data held by Google. We may also permit third-party service providers to place cookies for our Services, as previously stated to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties.

By accessing or utilizing our Services, you consent to the placement of cookies on your Devices as described in this Privacy Policy. If you decide not to receive cookies through our Services, you may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser on your device. Unless you set your browser settings to refuse all cookies, our system may issue cookies when you access or use our Services. If you set your browser settings to refuse all cookies, the performance of certain features of our Services may be limited or not work at all.

How we use your information:

• We may use Your Analytics (as described elsewhere in this Privacy Policy) for research and commercial purposes, in order to improve our Services.
• We may use Personal Information for the purposes described elsewhere in this Privacy Policy and internally for our general commercial purposes, including, among other things, to offer our products and services and products and services of third parties that we think you might find of interest, but only Enricher and our third-party service providers involved in distributing the offers or providing the products or services will have access to your Personal Information. Our third-party service providers will only be permitted to use Personal Information for that intended purpose.
• We may use your email address to respond to your inquiries and to provide you information about our Services. You may decide not to receive promotional emails from us either by “unsubscribing” to an email you receive from us or by contacting us. If you decide to unsubscribe from receiving emails from us, we may still send you non-promotional emails; such as emails about your Enricher account or our ongoing business relations, unless you withdraw your consent to receive electronic communications as provided in our Terms of Use.
• We use the information you provide us to verify your identity and prevent fraud
• We may use the information you provide to process and deliver contest or promotion entries and rewards.

Enricher is a Nigerian based company, and the information we collect is governed by Nigerian law. By accessing our Services or otherwise providing information to us, you agree to the processing and transfer of information in and to Nigeria and other countries.

How we disclose information:

We do not share your Personal Information with (1) other financial companies for joint marketing purposes; (2) affiliated companies for their everyday business purposes; or (3) any third parties so they can market to you.

We may share your Personal Information with unaffiliated third parties:

• if you request or authorize it;
• if the information is provided to help complete a transaction for you;
• if the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets);
• if the information is provided to our third-party service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); for our everyday business purposes; or as permitted by applicable law or otherwise described in this Privacy Policy. When you are no longer our customer, we continue to share your information as described in this Privacy Policy.

We may disclose Analytics with third parties as described elsewhere in this Privacy Policy and for our commercial purposes.

Opt-Out Rights

You can opt-out if you do not wish to receive offers from us in the future. You can do this by either contacting us via email or our number or by following the unsubscribe instructions in any communication you receive from us.

Please note that you are not able to opt-out of receiving communications about your Enricher account or related transactions with us.

Account Information:

You must notify us of any change in your Personal Information by updating your Enricher account profile through our Services. Any change you make will affect only future uses of your Personal Information.

Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information. Otherwise, we will hold your Personal Information for as long as we believe it will help us achieve our objectives as detailed in this Privacy Policy.

You can make inquiries from us about our storage of your personal information, you can also ask to see a copy of that information. Before we send any personal information to you, we will ask for your proof of identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. Please note, that will respond as quickly as we can to your requests for details of Personal Information we hold about you.

Sharing your information socially:

Our Services may give you permission to connect and share your actions, comments, content, and information publicly or with friends. We are not responsible for maintaining the confidentiality of any information you share publicly or with friends.

Our Services may also allow you to connect with us on, share on, and use third-party websites, applications, and services. Please be careful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. We do not have control over the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those sites and services directly if you want to learn about their privacy practices.

Security:

We have, and require the third-party service providers that receive Personal Information from us to have, a comprehensive written information security program that contains administrative, technical, and physical safeguards for our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, or alteration.

When your bank account information is transmitted via our Services, it will be protected by encryption technology, such as Secure Sockets Layer (SSL).Our Services may also allow you to connect with us on, share on, and use third-party websites, applications, and services. Please be careful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. We do not have control over the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those sites and services directly if you want to learn about their privacy practices.

Do note, that no method of electronic transmission or storage is 100% secure. Therefore, we cannot absolutely guarantee the safety of your personal information. You also play a role in protecting your Personal Information. Please protect your username and password for your Enricher account and do not share them with others. If we receive instructions using your Enricher account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Enricher account or any other breach of security. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate Enricher accounts, and to remove or edit content.

Alterations to our privacy policy

We may revise this Privacy Policy at any time and at our sole discretion. When we revise this Privacy Policy, we will post the revised version via our Services and will update the date at the top of this Privacy Policy. The revised Privacy Policy will be effective and we post it on our Services, unless otherwise set forth therein or as otherwise required by applicable law.

You are free to decide whether or not you accept a revised version of this Privacy Policy. But accepting this Privacy Policy, as revised, it is expected for you to continue accessing or using our Services. If you do not agree to the terms of this Privacy Policy or any revised version of this Privacy Policy, you can terminate your access and use of our Services. Except as otherwise expressly stated by us, your access and use of our Services are subject to the version of this Privacy Policy in effect at the time of access or use.

How can I contact Enricher?

For more information, concerns, and comments regarding this policy, please contact us at 0708 330 0760 or email us info@theenricher.org.