Privacy & Cookie Policy

Introduction

We have developed this Privacy Policy to explain how we collect, retain, process, transfer, and disclose information about you in connection with your use of our services, offered through the Made-By-Nigerians (MBN) website or mobile application (“platform”) and communications related to the service (e.g., emails, phone calls, and texts) (collectively, the “Service”). The terms “we”, “us”, and “MBN” refer to the Made-by-Nigerians platform powered by The Made-By-Nigerians Project Ltd - a company incorporated under the laws of the Federal Republic of Nigeria.

By accessing the MBN platform, you agree to the collection and use of your personal information in accordance with this policy.

What is Personal Data?

Personal Data under these terms means your personal information that can be associated with you as an identifiable person, or identifies you as a specific individual. Personal Data includes but is not limited to; your name, address, telephone number, email address, payment card number, account number, date of birth, identification card number, etc.

What personal Data do we collect?

We may collect different information from you as you access and use the service, including:

1. Onboarding Information

When you sign up to use the Services and provide your details such as email address, phone number, and other details which we may require

2. Device and Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, and the time spent on those pages amongst other diagnostic data. When you access the Service by or through a mobile device or access the Services on the mobile app or web, this Usage Data may include information such as the type of mobile device you use, your mobile device's unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Why We Collect Your Information

We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to a third party or a country without notice to you and adequate controls in place including the security of your data and other personal information.

We may disclose your Personal Data in good faith and belief that such action is necessary and will not disclose your personal information to anyone except in any of the following circumstances: To the extent permissible under applicable law, we may use your information to:

• provide, maintain, protect, and improve the MBN platform, products, services, and information that you may have requested from us;
• manage risks and protect the platform, the Services, and you from fraud by verifying your identity;
• undertake internal testing of the platform, systems, and services to test and improve their security, provision, and performance, in which case, we would pseudonymize any information used for such purposes, and ensure is it only displayed at aggregated levels which will not be linked back to you or any living individual;
• enable the use of any partner service and facilities securely and to enable us deliver the services you have requested;
• address any issue(s) or concerns you have raised;
• enable us to take your suggestion on what you may be interested in;
• contact you to see if you would like to take part in our customer research (for example, feedback on your use of the platform, products and Services);
• provide the services and any customer support you may request;
• process transactions and send notices about our products and services, including promotional messages about such products and services;
• resolve disputes, collect fees, and troubleshoot problems;
• prevent potentially fraudulent, prohibited, or illegal activities, and enforce these terms;
• create an account connection between your account and any third-party account;
• customize, personalize, measure, and improve our services and the content and layout of the platform for your bespoke user experience;
• send you updates about new products and services that we are offering to our customers.
• compare information for accuracy and verify it with third parties; and
• perform other duties as required by law

How we use the information collected

We use the collected data for various purposes such as to:

• verify your identity when you access your account information.
• respond to your requests and communicate with you
• provide and maintain the Service
• process transactions, design products and profile customers
• notify you about changes to our Service
• allow you to participate in interactive features of our Service when you choose to do so
• provide customer care and support and for internal operations, including troubleshooting, data analysis, testing, research, security, fraud-detection, and account management
• detect, prevent and address technical issues
• prevent fraud and enhance security of your account or our service platform.
• comply with and enforce applicable legal and regulatory requirements, relevant industry standards, contractual obligations and our policies
• provide you with tailored content and promotional messages such as recommending services we believe you may be interested in.
• deliver targeted advertising, promotions, and marketing (which may include in-product messaging) or information to you which may be useful to you, based on your use of our applications and services;
• Check specific information from your device or systems directly relevant to your use of the platform or Services against our records to make sure the platform or Services are being used in accordance with the terms and conditions for the use of the platform and to troubleshoot any problems;
• Obtain information relating to any technical errors or other issues with the platform and Services;
• Collect information about how you and other users use the functions of the features of the platform; and
• Gather statistical information about the operating system and environment from which you access the platform services.

Information from locations outside Nigeria

If you are located outside Nigeria and choose to provide information to us, please note that the data, including your Personal Data, will be processed in Nigeria. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Who do we share your Personal Information?

We may share your personal information with:

• Our affiliates and/or subsidiaries we control, but only for purposes allowed by this document.
• Law enforcement, government officials, or other third parties if we are compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the platform;
• Third-party Service Providers who assist us in providing services to you whether payment service or otherwise;
• Legal/Regulatory Authorities - It may be necessary by law, legal process, litigation, and/or requests from public and governmental authorities for FITC to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate
• Professional Advisers: Auditors/Legal Advisers
• Credit Agencies;

How long we will keep your information

We will keep your Personal Data for as long as we have a relationship witah you, i.e. for as long as you use the platform, remain validly subscribed to our newsletter or partake in surveys. Once our relationship with you has come to an end (e.g. following closure of your account), or cancellation of your subscription to the Service), we will not gather or collect any new information about you We will also retain your Personal Data in order to comply with any legal or regulatory requirements.

How we secure your personal information

The security of your data is important to us, for this reason, we maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, unauthorized access, disclosure, and misuse. We adopt security measures such as firewalls, data encryption, and information access authorization controls amongst other security protocols to ensure the safety of your data. We are however aware that no method of transmission over the Internet, or method of electronic storage can guarantee 100% security at all times. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security, you are responsible for securing and maintaining the privacy of your password and account/profile registration information and verifying that the Personal Data we maintain about you is valid, accurate and up to date.

We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorized. If we learn of a system's security breach, we may attempt to notify you electronically so that you can take appropriate protective steps.

Service Providers

We may employ third-party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform specific Service-related roles or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose outside of the service-specific need for which the data is required.

Links to Other Sites

Our Service may contain links to other sites not operated by us. If you click on a third-party link, you will be directed to that third-party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services. You should note the privacy policy, terms of use and security practices of the linked third-party website before providing any information on that website.

Can Minors access the Services on the platform?

Our services do not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18 years. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have erroneously collected Personal Data from children without verification of parental consent, we will promptly remove such information from our servers.

Update of your personal information

You must notify us of any change in your Personal Information by updating your account profile through our Services. Any changes 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.

Your rights under this Policy

In accordance with the Nigerian Data Protection Regulation, in certain circumstances, you have the following rights:

• the right to be told how we use your information and obtain access to your information;
• the right to have your information rectified or erased or place restrictions on processing your information;
• the right to object to the processing of your information e.g. for direct marketing purposes or where the processing is based on our legitimate interests;
• the right to give and withdraw consent to the processing of your personal information. We may however be unable to provide some services that you may request unless your consent to process your Personal Data is obtained.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time and revise these terms from time to time to reflect changes to our business, the platform, our Services, applicable laws, regulations, or market trends. The revised Privacy Statement will be effective as of the published effective date.

If the revised version includes a substantial change, we may provide you with 10 days prior notice by posting notice of the change on our website or the platform or notifying users of the change using email or other means.

Your continued use of the platform after we post any modifications to the Privacy Policy will constitute your acknowledgment of the modifications and your consent to abide by and be bound by the modified Privacy Policy.

Contact Us

We are committed to resolving your privacy complaints and concerns as quickly as possible and have procedures in place to help resolve any problems or complaints efficiently. If you have any questions about this Privacy Policy, please contact us at contact@mbn.ng