RENNDAAR TECHNOLOGY LTD PRIVACY POLICY
1. INTRODUCTION
a. Welcome to Renndaar Technology Ltd and its affiliates (together referred
to as ("Company", “we,” “our,” or “us”). Our Mobile Application
(Renndaar) offers basic information about our products and services as we
are committed to protecting your privacy. This Privacy Policy explains how
your personal information is collected and used by Renndaar Technology
Ltd.
b. This Privacy Policy applies to our Mobile Application and services
available therein, (collectively, our “Services”) and to all forms of systems,
operations, and processes within our environment that involve the
collection, storage, use, transmission, and disposal of Personal Information.
By accessing or using our Services, you signify that you have read,
understood, and agree to our collection, storage, use, and disclosure of your
personal information as described in this Privacy Policy and our Terms of
Use.
c. This Privacy Policy is strictly restricted to our Services and therefore does
not apply to services that are not owned or controlled by us, including third-
party Mobile Applications. We are committed to handling all Personal
Information provided to us in compliance with both applicable and model
data protection and privacy laws.
2. DEFINITION AND INTERPRETATION
a. To ensure that you understand the terms used within this Privacy Policy,
these terms are referenced and defined below:
i. “Cookie” is a small text file that is sent to and stored in the browser
directories of your device (smartphone or PC).
ii. “Company”, “we,” “us,” or “our” means Renndaar Technology
Ltd and any person or legal entity to whom the rights and/or
obligations of Renndaar Technology Ltd have been assigned.
iii. “Content” means the Service and any content, materials, graphics,
audiovisual files, processes and code, features, functionality, and
products available on our Mobile Application.
iv. “Device” means any device connected to the internet that a person
(natural or legal) used to access our Mobile Application, mobile
application, and services. It could be a phone, tablet, computer, or
any other device capable of connecting to the internet and accessing
our services.
v. “Product” refers to Renndaar, an innovative financial well-being
product designed primarily for African employees and employers.
vi. “Personal information” means any information that belongs to any
identifiable living individual. Such information includes (such as
name, telephone number, address, PIN, email address, Bank
Verification number, etc.) of individuals making them easily
identifiable.
vii. “PIN” means Personal Identification Number.
viii. “Policy” means this Privacy Policy.
ix. “Services” means our Mobile Application, services, products, and
user experiences offered through our Mobile Application.
x. “User” or “You” or “Customer” “Your” means any person
including entities that access our Services through any of our
Platforms. This includes both current and past registered users and
any and all other persons who in one way or another interact with
our Services.
xi. “Country” means Nigeria.
3. CONSENT
a. By using our Services in any manner, you confirm to us that you have read
and accepted this Policy and consent to the data practices described in this
Policy. If you do not intend to accept this Policy or do not meet or comply
with the provisions set forth herein, immediately exit the use of our
Services.
4. INFORMATION WE COLLECT
a. Personal Information
i. We collect personal information that you voluntarily provide to us
when you register to access our Services, express an interest in
obtaining information about us or our Services, or when you contact
us.
ii. We collect and process certain types of information such as your:
name, telephone number, address, National Identification Number
(NIN), PIN, email address, usernames, passwords, contact
preferences, contact or authentication data, emergency contact, etc.
of our users that makes them easily identifiable. These users include
both current and past registered users, any and all other persons that
in one way or the other interact with our Services (“users”), and
other individuals whom we communicate or deal with.
iii. We also collect anonymous information that may be linked to you
specifically such as your IP address, browser, device characteristics,
operating system, language preferences, referring URLs, device
name, country, location, information about how and when you use
our Services, and other technical information.
b. Payment Data
i. We may collect data necessary to process payments you make for
the use of our Services or purchase of products available on our
Mobile Application such as your payment instrument information.
All payment data is stored by our third-party payment processor and
as such, you are advised to review their Privacy Policy and other
relevant policies.
c. Cookies
i. We use cookies to identify you as a user and make your user
experience easier, customize our Mobile Application, content, and
advertisements, and where applicable help you ensure that your
account security is not compromised. We also use cookies to
mitigate risk and prevent fraud, promote trust and safety on our
Mobile Application. Cookies allow our servers to remember IP
addresses, date and time of visits, monitor web traffic, and prevent
illegal activities perpetuating through our Services. Our cookies do
not store personal or sensitive information. They simply hold a
unique random reference to you so that once you visit our Mobile
Application, we can recognize who you are and provide certain
content to you. If your browser or browser add-on permits, you have
the choice to disable cookies on our Mobile Application, however,
this may impact your experience while accessing and using our
Services.
d. Log and Usage Data
i. Log and usage data are service-related, diagnostic, usage, and
performance information our servers automatically collect when you
access or use our Services and which we record in log files.
Depending on how you interact with us, this log data may include
your IP address, device information, browser type, browser settings,
and information about your activity on our Mobile Application (such
as the date/time stamps associated with your usage, pages, and files
viewed, searches, and other actions you take such as which features
you use), device event information (such as system activity, error
reports sometimes called "crash dumps", and hardware settings).
e. Device Data
i. We collect device data such as information about your computer,
phone, tablet, or other device you use to access our Services.
Depending on the device used, this device data may include
information such as your IP address (or proxy server), device and
application identification numbers, location, browser type, hardware
model, Internet service provider and mobile carrier, operating
system, and system configuration information.
f. Location Data
i. We collect location data such as information about your device's
location. How much information we collect depends on the type and
settings of the device you use to access our Services. For example,
we may use GPS and other technologies to collect geolocation data
that tells us your current location (based on your IP address). You
can opt out of allowing us to collect this information either by
refusing access to the information or by disabling your location
setting on your device. However, if you choose to opt-out, you may
not be able to use certain aspects of our Services.
5. PURPOSE LIMITATION
a. We collect personal information only for certain identified purposes and for
which consent has been obtained. Such personal information cannot be
reused for another purpose that is incompatible with the original purpose
unless we obtain your consent for such use.
6. DATA MINIMIZATION
a. We limit data collection and usage to information that is relevant, adequate,
and absolutely necessary for carrying out the purpose for which the data is
processed. We will evaluate to what extent the necessity of processing your
data is required and where the purpose allows, anonymized data will be
used.
7. WHY WE COLLECT YOUR INFORMATION
a. We use your personal information to do the following:
i. Provide you with the required services;
ii. Create and manage your user profiles;
iii. Personalize the Services, i.e. identifying your interests and
recommending offers that might be of interest to you;
iv. Respond to your questions or requests;
v. Improve features, and Mobile Application content and analyze data
to develop our Services;
vi. Address inappropriate use of our Services;
vii. Prevent, detect, and manage risk against misinformation, wrong use,
fraudulent and illegal activities using internal and third-party
screening tools;
viii. Send you marketing content, newsletters, and service updates
curated by us, however, we will provide you with an option to
unsubscribe if you do not want to hear from us;
ix. Verify your identity and the information you provide in line with our
statutory obligations using internal and third-party tools;
x. Maintain up-to-date records;
xi. Carry out troubleshooting, data analysis, testing, and for statistical
purposes;
xii. Resolve disputes that may arise, including investigations by law
enforcement or regulatory bodies, and for any other purpose that we
disclose to you while providing our Services to you.
8. LEGAL BASIS WE RELY ON TO PROCESS YOUR INFORMATION
a. We only process your personal information when we have a valid legal
reason (i.e legally basis) to do so under applicable laws, e.g. with your
consent, to comply with these laws, to provide you with our Services, to
enter into and/or fulfill our contractual obligations, to protect your rights, or
to fulfil our legitimate business interests.
b. We may rely on the following legal basis to process your personal
information:
i. Consent- We may process your information if you have given us
permission (i.e. consent) to use your personal information for a
specific purpose. You can withdraw your consent at any time by
notifying us.
ii. Legal Obligations- We may process your information where we
believe it is necessary for compliance with our legal obligations,
such as but not limited to: Cooperating with a law enforcement body
or regulatory agency, complying with relevant regulations and
policies that apply to our Services and Company businesses.
iii. Exercising or defending our legal rights, or disclosing your
information as evidence in a competent court, or tribunal, or in
compliance during an investigation (internal or external),
compliance with any court and/or tribunal order, or compliance with
relevant regulatory and government authorities (both local and
international bodies).
iv. Vital Interests - We may process your information where we
believe it is necessary to protect your vital interests or the vital
interests of our users, such as situations involving potential threats to
the safety of our users.
9. HOW WE SHARE YOUR PERSONAL INFORMATION
a. In the course of providing our Services to you, we may engage the Services
of third parties to process your personal information. The processing by
such third parties shall be governed by a written contract with us to ensure
adequate protection and security measures are put in place by the third
party for the protection of your personal information in accordance with the
terms of this Privacy Policy.
b. We do not sell or trade personal information with third parties. However, to
enable us to render our Services to you, we may share your information
with trusted third parties. We may disclose your personal information in
compliance with applicable law or a legal obligation to which we are
bound. Please note that third-party sites you engage with through our
Services will have their privacy policies, and we are therefore not
responsible for their actions, including their information protection
practices. The use of your information by such third parties will be subject
to their applicable Privacy Policy, which you should carefully review.
c. We may be required to retain or disclose personal information in order to:
i. Comply with applicable laws and regulations;
ii. Comply with a court and/or tribunal order, subpoena, or other legal
processes; Comply with an investigation (internal or external);
iii. Respond to a lawful request by a government authority, law
enforcement agency, or similar government body (whether situated
in our user jurisdiction or elsewhere);
iv. Engage with third-party service providers and/or subcontractors who
provide services for the Company's business operations, a list of
which can be received upon request.
10. DATA RETENTION
a. We will retain your Personal Information for as long as is needed to
provide our Services to you, comply with our legal and statutory
obligations, or verify your information with the required verification
authorities. Therefore, even after your discontinuance of our Services, We
will retain certain personal information and data to comply with our legal
and regulatory obligations. All Personal Information shall be destroyed by
us where we have satisfied the legal retention timeframe.
b. For all Personal Information and records obtained, used, and stored by us,
We shall perform periodical reviews of the data retained to confirm the
accuracy, purpose, validity, and requirement to retain. The length of storage
of your Personal Information shall, amongst other things, be determined by
the following:
i. The contract terms agreed between us or as long as it is needed for
the purpose for which it was obtained;
ii. Whether the transaction or relationship has statutory implication or a
required retention period;
iii. Whether there is an express request for deletion of the Personal
Information by you, provided that such request will only be treated
where you are not under any investigation which may require us to
retain such Personal Information or there is no subsisting contractual
arrangement with you that would require the processing of the
Personal Information;
iv. Whether We have another lawful basis for retaining that information
beyond the period for which it is necessary to serve the original
purpose.
c. When we have no ongoing legitimate business need to process your
personal information, we will either delete or anonymize such information,
or, if this is not possible (for example, because your personal information
has been stored in backup archives), then we will securely store your
personal information and isolate it from any further processing until
deletion is possible.
11. HOW DO WE KEEP YOUR INFORMATION
a. We shall continually put in place mechanisms to protect the integrity and
confidentiality of your personal information, both in digital and physical
format and to prevent your personal information from being accidentally or
deliberately compromised. We are committed to managing your personal
information in line with global industry best practices. We protect your
personal information using technical and organizational measures to reduce
the risks of loss, misuse, unauthorized access, disclosure, and alteration.
b. We also use industry-recommended security protocols to safeguard your
personal information. Other security safeguards include but are not limited
to: data encryption, firewalls, and physical access controls to our building,
files, cloud storage, and granting access to your personal information to
only our employees who require it to fulfil their job responsibilities. No
personal information processing will be undertaken by our employee who
has not been authorised to carry out such as part of their legitimate duties.
12. PRIVACY RIGHTS
a. Once your personal information is held by us, you are entitled to reach out
to us to exercise the following rights:
i. Request a rectification and modification of your personal
information which we keep;
ii. Request the movement of your data from us to a third party (this is
the right to portability of data);
iii. Object to and request that we restrict the processing of your personal
information. We shall inform you of the effect of such restrictions
and how they will affect our Services to you. Your request will be
reviewed by us and carried out except as restricted by law or our
statutory obligations. You may review and update your personal
information directly on our Mobile Application, or product or by
contacting us via email.
iv. Opt out of receiving newsletters and other non-essential messages by
using the unsubscribe link included in all such messages. However,
you will continue to receive notices and essential transactional
emails;
v. Disable browser cookies before visiting our Mobile Application.
However, if you do so, you may not be able to use certain features of
the Mobile Application properly;
vi. Request access to the personal information we collect from you,
change that information, or delete it.
b. To request for a review, update, or deletion of your personal information,
please send us an email on hello@renndaar.com
13. DO-NOT-TRACK FEATURES
a. Most web browsers and some mobile operating systems and mobile
applications include a Do-Not-Track ("DNT") feature or settings which you
can activate to signal your privacy preference not to retain data about your
online browsing activities monitored and collected. At this stage, no
uniform technology standard for recognizing and implementing DNT
signals has been finalized. As such, we do not currently respond to DNT
browser signals or any other mechanism that automatically communicates
your choice not to be tracked online. If a standard for online tracking is
adopted that we must follow in the future, we will inform you about that
practice in a revised version of this Privacy Policy.
14. AGE RESTRICTION
a. Our Services are directed to persons from the ages of 18 years and above.
If you are below the age of 18 you must obtain the consent of your parent
or guardian to use our Services. If we become aware that a child (“minor”)
under 18 years has provided us with personal information, we will take
steps to delete such information and shall NOT be held liable for the
actions of minors who access our Services.
b. If as a parent or guardian, you become aware that your child or ward has
provided us with any personal information without your consent, please
contact us via email at hello@renndaar.com
15. CHANGE OR TRANSFER OF BUSINESS OWNERSHIP
a. In the event that we sell our company or get acquired or merged with
another entity, we will ensure that the acquiring entity is legally bound to
honour our commitments to you. We will notify you via email or through a
notice on our Mobile Application of any change in ownership or in the use
of your personal information or service data. We will also notify you about
any choices you may have regarding your personal information and service
data. This Policy may be updated to accommodate such transactions.
16. UPDATES
a. We may update this Privacy Policy from time to time. The updated version
will be indicated by an updated "Revised" date and the updated version
will be effective as soon as it is uploaded on our Mobile Application. If we
make material changes to this Privacy Policy, we may notify you either by
prominently posting a notice of such changes or by directly sending you a
notification. We encourage you to review this Policy frequently in order to
be informed of how we are protecting your information.
17. GENERAL TERMS
a. Your access to and use of our Services is subject to Renndaar Technology
Ltd Terms of Use and such other terms, which may be made available to
you in connection with your use of our Services.
18. CONTACT US
a. You may contact us upon becoming aware of any breach of Personal
Information or if your access to our Services has been compromised, to
enable us to take the necessary steps toward ensuring the security of your
Personal Information.
b. You may also contact us if you have any questions relating to this Privacy
Policy or would like to find out more about exercising your data protection
rights. All questions and inquiries may be sent to us via email at
hello@renndaar.com.
This Privacy Policy was last updated on 10th March 2024.