PRIVACY NOTICE

Last Updated December 2024

Overview and Scope

This Privacy Notice (“Notice”) describes how MyNebor (“MyNebor,” “we,” “our” or “us”) collects, uses and discloses Personal Data about individuals (collectively, “users” or “you”) receiving our products and services, and/or using our websites, mobile applications, or other online features (collectively, our “Platform”). This Privacy Notice applies to your use of (regardless of means and purpose of access) our Platform.

At MyNebor, the privacy of our users is of utmost importance to us. This Notice provides information about our privacy practices and helps our users to understand how we handle Personal Data in compliance with the provisions of the Nigerian Data Protection Act 2023 and other applicable legislations and regulations.

This Privacy Notice does not apply to third-party services, websites, or applications that are linked to or integrated with MyNebor. These third-party services have their own privacy policies, and we recommend reviewing them separately to understand their data practices.

Deﬁnitions

“Account” means a MyNebor Account created on our Platform

“Cookies”: A cookie is a small data ﬁle that is transferred to your computer or mobile device. It enables us to remember your account log-in information, IP addresses, web traﬃc number of times you visit, browser type and version, device details, date, and time of visits.

“Data Protection Legislations” refers to the Nigeria Data Protection Act 2023 (NDPA) and all other applicable legislation and regulations.“Data Subject” (“user,” “you,” “your”) refers to any individual person who can be identiﬁed, directly or indirectly, through personal data collected about them. Essentially, as a user of our Platform and Services, you are a data subject for the purpose of this Notice.

“Personal Information/Data” means any information that relates to an identified or identifiable individual, either directly or indirectly, through reference to identifiers such as a name, identification number, location data, online identifiers, or other factors specific to the identity of that individual

"Platform" refers to our website, mobile application, or API.

“Sensitive Data” means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information on your health, and genetic and biometric data.

“Services” or “Service” refer to our products, services, information, content, functions, features, and tools provided on our Platform.

Our Privacy Principles

MyNebor is committed to maintaining the principles in the Data Protection Legislations as they relate to data controllers and processors of Personal Data in Nigeria. To demonstrate this commitment, we maintain the following data privacy principles:

User Rights: We respect users’ rights over their Personal Data, including the rights to access, rectify, erase, restrict processing, and object to the processing of their data. Users also have the right to withdraw their consent at any time, where applicable.
Lawfulness: We ensure that all Personal Data is collected, processed, and stored in a lawful and transparent manner.
Purpose Limitation: Personal Data will only be collected for specified, legitimate purposes and will not be used in a manner inconsistent with those purposes.
Data Minimization: We collect only the Personal Data that is necessary for the effective provision of our Services. We ensure that data collected is adequate, relevant, and limited to what is necessary for the purposes we define.
Accuracy: We take all reasonable steps to ensure that Personal Data is accurate and, where necessary, kept up to date. Users have the right to correct their data if it is inaccurate or incomplete.
Storage Limitation: Personal Data will not be kept for longer than is necessary for the purposes for which it was collected. We implement data retention policies to ensure that Personal Data is deleted or anonymized when it is no longer needed.
Security and Confidentiality: We adopt appropriate technical and organizational measures to protect Personal Data from unauthorized access, disclosure, alteration, and destruction. We prioritize the security and confidentiality of all Personal Data we process.
Accountability: We take full responsibility for ensuring compliance with these principles and for the proper handling of Personal Data. MyNebor is committed to being transparent about how Personal Data is processed and to providing users with the ability to exercise their privacy rights.
Abiding by local laws: MyNebor is a company with global coverage and local privacy expertise. Our privacy practices may vary among the countries in which we operate to reﬂect local practices and legal requirements.
The laws of the jurisdictions in which we operate shall apply to the procedures speciﬁed in this policy. This implies that we only use the techniques outlined in this policy in a country or region if the country's ﬁnancial technology regulations or other applicable laws authorize us to do so. Please contact us if you have any questions regarding how we operate in your location: https://MyNebor.com/

Personal Information We Collect About You

Account Registration Information: When you create an account, we collect your Personal Data, such as your full name, email address, phone number, image, your government-issued identity number and any other details you provide during registration. This information is necessary for creating and managing your user profile and enabling communication with you.
Identiﬁcation documents: (such as your passport or any Government-issued identity card), a photograph (if applicable), and any other registration information you may provide to prove you are eligible to use our services.
Log/Technical information: We may record or log information from your Devices, their software, and your activity accessing or using our Platform. This information may include the Device's Internet Protocol ("IP") address, Identification numbers associated with your Devices and other interactions with our Platform or information described in our Cookies Policy .
Location Information: With your consent, we may collect location information, which includes your current location disclosed by GPS technology or any other location territory.
Transactional Data: To comply with the regulations relating to money laundering and the ﬁnancing of crime while delivering seamless services, we keep track of your transactions when you use our services, including the services you requested. We collect information relating to a payment when you as a merchant (using one or more of our payment processing services) or as a customer, are using our services.
Marketing and Communications Data: This includes a record of your decision to subscribe or to withdraw from receiving marketing materials from us or from our third parties.
User Content: If you contact MyNebor customer support, recommend other users, or interact with MyNebor in any other manner, we may collect the data you submit, such as your name, residential address, and email address. We will keep records of your discussions with us, when we contact you and if you contact us.

We may also collect, store, use, and transfer non-personal information or anonymized data such as statistical or demographic data.

As a principle, we do not collect any Special Categories of Personal Information. If we do collect Special Categories of Personal Information, we will ensure compliance with applicable laws and international best practices in handling sensitive data.

In general, we collect Personal Information you give us by filling in forms on our Platform or by corresponding with us by phone, email, social media posts & messages, or otherwise.

By providing your Personal Information and any other kind of information or data to us, you expressly agree to our collection, use, storage, and disclosure of such information as described in this Privacy Policy.

How We Collect Your Personal Information and Why We Have It

The Personal Information we have about you is directly made available to us when you:

Sign up for a MyNebor Account;
Use any of our services;
Contact our customer support team; or
Contact us.

Lawful Basis

We may process your Personal Information under any of the bases provided below as recognised by Data Protection Legislations:

Consent: We may process your Personal Data if you have specifically granted us permission to use your personal information for a specific purpose.
Contractual Obligation: We may process your Personal Information to fulfil our contractual obligations such as providing our Services to you or to take necessary actions at your request before providing our Services to you.
Legal Obligation: In order to comply with applicable legislation, governmental demands, a judicial procedure, court order, or legal process, such as in response to a court order or a subpoena, we may process your Personal Information (including in response to public authorities to meet national security or law enforcement requirements).
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests, provided that such processing does not outweigh your rights as a Data Subject. This includes improving the functionality of our app, sending service-related communications (such as notifications and updates), and preventing fraud or misuse of the platform.
Vital Interests: We may process your Personal Information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

These lawful bases may be extended to cover any additional grounds for the processing of Personal Data as may be recognised by Data Protection Legislations in force from time to time

How We Use Your Personal Information

We may use your Personal Information we collect to:

Create and manage any accounts you may have with us, verify your identity, provide our Services, and respond to your inquiries;
Process your payment transactions (including authorization, clearing, chargebacks, and other related dispute resolution activities);
Provide, administer, and communicate with you about products and services of MyNebor, subject to your consent;
We may use your anonymized data to conduct research, evaluate and improve our business, including developing new products and services;
To use data analytics to improve our Website, Products or Services, and user experiences; and
For other purposes, we provide speciﬁc notice at the time of collection.

Data Security and Retention

The security of your Personal Information is important to MyNebor. We are committed to protecting the information we collect. We maintain administrative, technical, and physical controls designed to protect the Personal Information you provide, or we collect against loss or theft, as well as against any unauthorized access, risk of loss, disclosure, copying, misuse, or modiﬁcation.

Other security measures include but are not limited to, secure servers, ﬁrewalls, data encryption, access controls, security audits, data backup and recovery.

Where you use a password for any of your Accounts, please ensure you do not share this with anyone, and that the password is kept conﬁdential at all times.

We are committed to conducting our business in accordance with these principles in order to ensure that the conﬁdentiality of your Personal Information is protected and maintained. Despite our best efforts, it is important to note that no method of transmission over the internet or electronic storage is entirely foolproof. Therefore, while we strive to maintain the highest standards of data security, we cannot guarantee its absolute security. If you have any concerns about the security of your personal information or suspect any unauthorized access or misuse, please contact us immediately using the information provided in the "Contact Us" section below. We will promptly investigate the matter and take appropriate measures to address it.

We will retain your personal information only for as long as your Account is active or as necessary to fulfill the purposes outlined in this Notice, unless a longer retention period is required or permitted by law. If you are no longer an active user of our Platform or Services and your account is inactive for a certain period, we may anonymize or delete your personal information in accordance with our data retention policies and applicable laws.

When We Disclose Your Personal Information

We may disclose and/or share your information under the following circumstances:

Service Providers

We may share your Personal Information with third-party service providers and business partners who help us operate, maintain, and improve our Platform. These service providers may include payment processors, hosting services, marketing platforms, and customer support providers. We ensure that these third parties are bound by data protection obligations to safeguard your Personal Data.

Business Transfers

In the event of a merger, acquisition, or sale of all or part of our business, your Personal Data may be transferred as part of the transaction. We will ensure that any such transfer complies with applicable privacy laws, and users will be notified of any changes to the control or use of their data.

Aﬃliated Companies

We may disclose your information with current or future aﬃliated companies.

Consent

We may disclose your information to any third parties based on your consent to do so.

Public and Social Features

If you engage in public or social features within the app, such as community forums, reviews, or shared resource pooling activities, certain aspects of your profile and activity may be visible to other users. You have control over what information is shared through these features.

Aggregate/De-identiﬁed Information

We may disclose de-identiﬁed and/or aggregated data for any purpose to third parties, including advertisers, promotional partners, and/or others.

Online Analytics

We may use third-party web analytics services (such as Google Analytics) on our Services to collect and analyze the information discussed above and to engage in auditing, research, or reporting. The information (including your IP address) collected by various analytics technologies will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services, including by noting the third-party website from which you arrive at our Site, analyzing usage trends, and providing certain features to you. To prevent MyNebor Google Analytics from using your information for analytics, you may install the oﬃcial Google Analytics Opt-out Browser Add-on.

Your Choices and Data Subject Right

MyNebor may transfer Personal Information that we maintain about you to recipients outside the country in which the Personal Information was originally collected. The data protection regulations of these countries may be diﬀerent from those of your country. Where Personal Information is to be transferred to a country outside Nigeria, MyNebor shall put adequate measures in place to ensure the security of such Personal Information.

Transfer of Personal Information out of Nigeria would be under the provisions of the Nigeria Data Protection Act 2023 (the “NDPA”) and other applicable regulations. MyNebor will therefore only transfer Personal Information out of Nigeria on one of the following conditions:

The transfer is necessary for the performance of a contract between MyNebor and the Data Subject or the implementation of pre-contractual measures taken at the Data Subject’s request.
The transfer is necessary to conclude a contract between MyNebor and a third party in the interest of the Data Subject.
The consent of the Data Subject has been obtained.
The transfer is necessary for reasons of public interest.
The transfer is for the establishment, exercise, or defense of legal claims.
The transfer is necessary to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent.
MyNebor will take all necessary steps to ensure that Personal Information is transmitted safely and securely. Details of the protection given when your Personal Information is transferred outside Nigeria shall be provided to you upon request.

Your Rights as a Data Subject

We respect your rights regarding your personal information and are committed to ensuring that you have control over how your information is collected, used, and shared. As a user of our Platform, you have the following rights:

Right to Request to Access: You have the right to request access to the personal information we hold about you. Upon request, we will provide you with information about whether we hold any of your personal information and, if so, the categories of information, the purposes for which it is being used. Before sending you any Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information we hold about you
Right to Objection: You have the right to object to the processing of your personal information.
Right to object to automated decision-making.
Right to Request Rectiﬁcation of Personal Information: We respect your wishes to correct inaccurate information and as such you must notify us of any change in your Personal Information. If you are a user, you can change some of your Personal Information by updating your Account profile through our Platform. If you are not a User, you can contact us as indicated at the end of this Notice to make any changes or request on Personal Information we hold about you. Any changes will affect only future uses of your Personal Information and we may need to verify the accuracy of the new data you provide to us.
Right to request for deletion: You have the right to request the deletion of your personal information from our systems under certain circumstances, such as when it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent for its processing.

However, there might be requirements under applicable law, or other compelling reasons, that prevent us from immediately erasing your Personal Data. In such case, we will stop using your Personal Data for any other reasons than to comply with the applicable law, or the relevant compelling reason.
Right to Data Portability: You can request to receive a copy of your personal information in a structured, commonly used, and electronic format and to transmit you Personal Information to a third party without hindrance from us, where technically feasible.
Right to object to, and to request MyNebor to restrict the processing of their information.
Right to Withdraw Consent: If we rely on your consent as the legal basis for processing your personal information, you have the right to withdraw that consent at any time. However, please note that withdrawing consent may affect the availability and functionality of our Services.

Your request will be reviewed by the MyNebor Data Protection Oﬃcer (DPO) and carried out except as restricted by law or MyNebor’s statutory obligations. You may decline to provide your Personal Information when it is requested by MyNebor, however, certain services or all the services may be unavailable to you. You may review your account settings and update your Personal Information directly or by contacting us.

You have various rights for the collection and use of your information through the Services. Those choices are as follows:

Email Unsubscribe

You may unsubscribe from our marketing emails at any time by clicking on the “unsubscribe” link at the bottom of each newsletter or by emailing www.MyNebor.com with your request.

Account Preferences

If you have registered for an account with us through our Platform, you can update your account information or adjust your email communications preferences by logging into your account and updating your settings.

Children

The Services are intended for users over the age of 18 and are not directed at children as contemplated under the NDPA. If we become aware that we have collected personal information from children or personal data (as deﬁned by the NDPA), we will take reasonable steps to delete it as soon as practicable.

Updates to our Privacy Notice

From time to time, we may change, amend, or review this Privacy Notice from time to time to reﬂect new services or changes in our Privacy Notice and place any updates on this page. All changes made will be posted on this page and where changes will materially aﬀect you, we will notify you of this change by placing a notice online or via mail. If you keep using our Services, you consent to all amendments of this Privacy Notice.

Contact Us

Should we require additional details, we may contact you. All access requests, questions, comments, complaints, and other requests regarding our privacy practices should be sent to: https://mynebor.com