Privacy Policy

1.1 Protection of Privacy

KYRIARCHIA SYSTEMS LTD (“avivpay”, the “Company”, or “we” or “us”) values your Personal Data and we are committed to protecting your privacy whenever you interact with us. Please read this Privacy Notice (the “Notice”) to understand our policies, processes, and procedures regarding the processing of your personal data.

By this Notice, we explain to you how your Personal Data is collected, used, managed, transferred, and or deleted by avivpay and also explain how you can update your Personal Data with us and exercise your rights in respect of the Personal Data provided to us

1.2. The Information We Collect

To access the avivpay Services and for optimal use of this application/website, we may collect personally identifiable information such as your IP address, and standard web log information, such as your browser type and the pages you accessed on our website. We also may collect Geolocation Information (defined below). If you do not agree to our collection of this information, you may not be able to use the Services.

• Personally identifiable information - refers to the personal information you submit when you sign up or any information that can be used to identify or contact you e.g. email address, password, name, address, telephone number, business name, camera sensor data, bank details, and other unique identifiers. For ease of transacting, we may also collect your contact details, only if your permission to do so is granted.
• Device Information - information about you from your mobile device or computer such as your device type, machine or mobile device identification number, Geolocation Information, time zone, language setting, browser type, MAC address, IMEI number, IMSI number, SIM and others, and IP address, and information from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes. For fraud prevention purposes, we also may link your machine ID with the machines of others who use your same payment cards.
• Geolocation Information - information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. We will collect this data for fraud and risk purposes. In addition, we may ask you for permission to share your current location within your device settings to enhance our Services. If you do not agree to our collection of Geolocation Information, our Services may not function properly when you try to use them.

We also collect non-personally identifiable information including but not limited to dynamic IP address, geolocation data, screen size, and cookies data. We use technical methods to collect and store personal information such as cookies, JWT, web beacons, etc. We will not share or disclose this information with third parties except as a necessary part of providing our users access to our website and services. By visiting and using our website, you agree to our use of cookies in line with avivpay's policies.

1.3. Uses of Information

We use your personally identifiable information to:

• provide our services and customer support
• profile avivpay users and administer avivpay accounts
• resolve disputes, collect fees and troubleshoot problems
• prevent potentially prohibited or illegal activities and enforce our User Agreement
• to manage risk, detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities
• to detect, prevent or remediate violations of policies or applicable user agreements;
• customise, measure and improve our services
• customise and improve the layout of our website
• compare information for accuracy and verify with third parties
• update our databases and provide user support
• provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about.

What Constitutes Your Consent?

Where the processing of Personal Data is based on consent, avivpay shall obtain the requisite consent at the time of collection of the Personal Data. In this regard, you consent to avivpay processing your Personal Data when you access our platforms or use our services, content, features, technologies, or functions offered on our website or other digital platforms. You can withdraw your consent at any time, but such withdrawal will not affect the processing of your data which we carried out lawfully based on consent given before your withdrawal.

We may retrieve Personal Information about you from third parties and other identification/verification services such as your financial institution, payment processor, and verification services. With your consent, we may also collect additional Personal Information in other ways including emails, surveys, and other forms of communication. Once you begin using our services through your avivpay account, we will keep records of your transactions and collect information on your other activities related to our services. We will not share or disclose your Personal Information with a third party without your consent. We will not use your information or seek your consent to use your information for the propagation of atrocities, hate, child rights violations, criminal acts, and anti-social conduct.

1.4. Sharing of Information

avivpay assures you that it shall only obtain your data with your consent and that your data shall only be used for the purpose for which it was obtained. However, we may share your Personal Data with companies within the avivpay eco-system, service providers engaged by us to provide services to avivpay subject to appropriate data security and protection. In addition, we may transfer your Personal Data out of Nigeria in line with the requirements of the Nigeria Data Protection Act, 2023. avivpay shall also share your Personal Data with third parties directly authorized by you to receive Personal Information, such as when you authorize a third-party service provider to access your account. The use of your personal information by an authorized third party shall be subject to the privacy policy of the third-party and avivpay shall not bear any liability for any breach which might arise due to your authorization. avivpay shall also share your Personal Information if it is believed that such sharing is required to satisfy any applicable laws, regulations, or government requests.

Our website may contain third-party links or links to other websites. Please be advised that we are not responsible for the privacy practices or contents of these sites and shall not be responsible for your use of such websites. We encourage our users to be aware of when they leave our website and to read the privacy statements of these sites. You should evaluate the security and trustworthiness of any other site connected to this site or accessed through this site before disclosing any personal information to them. avivpay shall not be liable for any loss or damage in whatever manner resulting from your disclosure of your personal information to third parties. However, avivpay shall also make all reasonable efforts to ensure that adequate safeguards have been put in place to prevent unauthorized access and to ensure confidentiality of your personal information.

1.5. Acknowledgment

You acknowledge that by using the avivpay services, some of your personal information will be passed on to any person whom you receive avivpay money from, or send avivpay money to, and will be available to any third party involved in the operation of the services including but not limited to avivpay IMPs and partner banks.

1.6. Your Rights

You can exercise the following rights with respect to your Personal Data with avivpay:

• request for and access your Personal Data collected and stored by avivpay;
• withdraw consent at any time. For example, you can withdraw your consent to receiving our marketing or promotional materials or unsubscribe to our newsletters;
• request rectification and modification of Personal Data kept by avivpay;
• request for deletion of your Personal Data;
• be informed of and entitled to provide consent prior to the processing of Personal Data for purposes other than that for which the Personal Data were collected;
• request that avivpay restricts processing of your Personal Data; and
• request for information regarding any specific processing of your personal data.

You may exercise any of these rights by sending an email to support@avivpay.com where your requests will be treated promptly.

1.7. Account Monitoring

You accept that avivpay shall have the right to monitor your account usage and if required, will disclose personal information to local enforcement or investigative agencies or any competent regulatory or governmental agencies to assist in the prevention, detection or prosecution of money laundering, fraud or criminal activities.

1.8. avivpay Employee Obligation

avivpay employees who handle Personal Information are under an obligation to treat it confidentially and shall not disclose it to third parties. avivpay employees are also responsible for the internal security of the information. Employees who violate avivpay's privacy policies are subject to the company's disciplinary procedures.

1.9. Submitting Information Through avivpay

Any person submitting information to avivpay through our platform may be granted access rights to that information. avivpay has developed systems that enable users to access and correct their personal information submitted to it. avivpay is committed to ensuring that personal data processed by the company is accurate and up to date in line with the provisions of the Nigeria Data Protection Act (NDPA) 2023. In order to ensure that your personal data with the company is current, complete, and accurate, please update us if there are changes to your personal information by informing the company’s DPO via the stated contact details or the Human Resources Unit. We shall take it that your records with the company are current, complete, and accurate if we do not receive any update from you.

1.10. Privacy Policy Updates

avivpay may at any time amend, delete, or add to its Privacy Policy by giving notice of such changes or posting a revised version of our Privacy Policy on avivpay’s online portals. Any change(s) shall be made unilaterally by avivpay and you will have been deemed to have accepted these changes by your continuous use of avivpay’s services after the revised Privacy Policy is uploaded. You further agree that it shall be your sole responsibility to check for updates to the Privacy Policy.

1.11. Correspondence

Should you send us correspondence including chats, calls, emails, and letters, we will retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from avivpay to you. The rationale for this retention is to keep records of our relationship, measure and improve customer service, and investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.

1.12. Questionnaires & Surveys

From time to time, avivpay may offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users' interests and needs. The use of information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.

1.13. Security

avivpay is committed to managing customer information with the highest standards of information security. We protect your personal information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. We use computer safeguards such as firewalls and data encryption, enforce physical access to our buildings and files, and only grant authorised employees access to personal information when required to fulfil their job responsibilities.

The security of your avivpay account also rests on the protection of your password and transaction PIN. You should not share either your password or transaction PIN with anyone and no employee of avivpay will ever ask you for either of these so any email or correspondence requesting such information should be treated as unauthorised and suspicious and forwarded tosupport@avivpay.com. We will endeavour to respond to such emails as soon as possible.

Should you share your password or PIN with any third party, such third party will have access to your account and your personal information, and you may be responsible for any actions taken using this information. In the event you suspect a third party has access to your password or PIN, please log into your avivpay profile to change or modify the password or PIN promptly.

1.14. Retention of your personal data

avivpay will not retain your personal data for longer than is necessary for the purposes for which such personal data is processed. This means that your personal data will only be retained for as long as it is still required to provide you with our Services or is necessary for legal reasons. When calculating the appropriate retention period of your personal data we consider the nature and sensitivity of the personal data, the purposes for which we are processing such personal data, and any applicable statutory/regulatory retention periods. Using these criteria, we regularly review the personal data that we hold and the purposes for which such is held and processed.

When we determine that personal data can no longer be retained (or when you request that we delete your personal data in accordance with your rights contained in the NDPA) we ensure that such personal data is securely deleted, anonymized, or destroyed. However, please note that, in some circumstances, we may decide to retain your personal data as may be reasonably necessary in accordance with the provisions of the NDPA. In such circumstances, we will anonymize your personal data before retaining the same.

Please see details of our data retention and disposal process below:

1.15. Accuracy of your data

It is important that the personal data avivpay holds about you is accurate and current. Please keep avivpay informed if any aspect of your personal data changes at any time during your relationship with us. On our customer-facing products, you can easily update your personal data yourself or alternatively contact our Data Protection Officer via support@avivpay.com when you want to exercise your right of rectification.

1.16. Inquires

avivpay is responsible for ensuring that our day-to-day procedures are aligned with this Privacy Policy. Should you have any questions about this privacy statement, avivpay's information services, or your transactions on avivpay, you can contact us via our customer helplines or by email to support@avivpay.com

1.17. Fraud Prevention

We may process your personal data on the basis that we have a legitimate interest to prevent fraud and money laundering, and to verify your identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services you have requested.

We may carry out fraud prevention checks using a fraud prevention database. If false or inaccurate information is provided, and/or fraud is identified, details will be passed to the Central Bank of Nigeria and the Economic and Financial Crimes Commission. Additionally, law enforcement agencies may access and use this information.

1.18. Data Analytics and Benchmarking

We may use information generated and stored during your use of our Services for our legitimate activities to enable us to give you the best service and/or solutions and the best experience. These purposes include, to:

• Deliver advertising or information to you which may be useful to you, based on your use of preferences;
• Carry out research and development to improve our Services;
• Develop and provide new and existing functionalities and Services (including statistical analysis, benchmarking and forecasting Services); and
• provide you with location-based Services (for example location relevant content) where we collect geo-location data to provide a relevant experience.

Whenever we use your information for our legitimate interests, we will ensure that your information is processed on a pseudonymised basis and displayed at aggregated levels, which will not be linked back to you or to any living individual.

You have the right to object to processing based on our legitimate activities but if you object, this may affect our ability to provide certain Services and/or solutions for your benefit.

DISCLAIMER

We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction, or damage. We will do our best to protect your personal data, but we cannot guarantee the security of your personal data which is transmitted to other websites via an internet or similar connection. If we have given you (or you have chosen) a password to access certain areas of the Sites please keep this password safe, we will not share this password with anyone.

As a user of our Services, you understand and agree that you assume all responsibility and risk attached to safeguarding your account with us. You shall at no time whatsoever disclose your password to anyone, nor shall you allow anyone to make use of your account.