What information we collect
Why we collect such information
The use of such information
The storage, sharing and protection of such information
For the purpose of this Policy:
Personal Data/Information means any information relating to you, including your name, identification number, location data, online identifier address, photo, email address, pins, passwords, bank details, posts on our Platforms, religion, date of birth, health, race/tribe, nationality, ethnicity, political views, trade union membership, criminal records, medical information, and other unique identifiers such as but not limited to MAC address, IP address, IMEI number, Bank Verification Number, IMSI number, SIM and others. It also includes factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.
Process/Processing means any operation or set of operations which is performed on your Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
We kindly request that you carefully read through this Policy and click on the ‘Agree’ icon below, if you consent to the terms of this Policy, particularly with respect to the processing of your Personal Data. That notwithstanding, if you proceed to use any of our Platforms and services, it will be deemed that you have provided your express consent to the terms of this Policy.
You must be at least 18 years old to use our services or any of our Platforms. Individuals under the age of 18, or applicable age of maturity, may utilize our Platforms services only with involvement of a parent or legal guardian, under such a person’s account. Regardless, all Personal Data which we may process shall be in accordance with this Policy and other applicable laws.
Collection of Personal Data
In the course of your engagement with us or with third parties through our Platforms, we may collect your Personal Data in the following ways:
Automatic Information collection:
We may automatically collect Information upon your engagement with us or our Platforms through your computer, mobile phones, forms, documents made available to us and other access devices. The information sent includes, but is not limited to, data about our pages you access, geo-location information; statistics on page views; traffic to and from our Platforms.
Information from downloads:
When you download or use our digital Platforms or access our site, we may receive non personal information from your mobile device about your location, number of downloads, geo location of downloads. You may disable your location in the settings menu of the device.
Physically or Digitally Provided Information:
We may collect and process your information when you create and/or update your account on our Platform; complete forms, questionnaires, surveys etc. We may also collect Information from data you provide to us through documents, letters, e-mail, agreements, correspondence, ID cards, passports, or through any other means by which you wilfully provide information to us. When you use Smile Planet Services, we may also collect information about your transactions and your activities. In addition, when you open an account on our Platform, we may collect information such as your contact information, which includes your name, address, phone number, email or other similar information; financial information such as your full bank account numbers and/or credit card or debit card numbers.
We may also receive your information from third parties such as, guardians, financial institutions, identity verification services, vendors, and service providers etc.
We also receive Information through your engagements with us on social media sites (e.g., Facebook, Instagram, LinkedIn, Twitter, etc). This includes but are not limited to your replies to our posts, your comments, enquiries, messages to us, etc. We may also collect information from your public profile and updates on social media.
Accessing your Personal Information
When accessing our Platforms, we may collect information about you and your interactions with the Services to which we undertake to keep secure and confidential.
When you download or use our mobile applications, or access one of our mobile optimized sites, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices allow you to control or disable location services in the device’s setting’s menu. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or the manufacture of your particular device.
Using Your Personal Information
In the course of your engagements with us or through our Platforms, we collect personal information for various legal reasons, largely to enable us to personalize your experience and to provide a more efficient service to you. Some of the reasons we collect Information are to:
provide services and customer support;
process transactions, payment requests, and send notices about transactions;
create an account with us for the provision or use of our services;
communicate with you about your account or transactions with us and send you information or request feedback about features on our website and applications or changes to our policies;
send you periodic emails and updates pertaining to our products and services;
verify customers’ identity, including during account creation and password reset processes;
manage your account and provide you with efficient customer service,
send you offers and promotions for our services and investment opportunities
resolve disputes, process payments and troubleshoot problems;
detect, investigate and prevent activities that may violate our policies or be illegal;
manage risks, or to detect, prevent, and/or remediate fraud, violation of policies and applicable user agreements or other potentially prohibited or illegal activities;
execute our contractual obligations to you;
improve our services and functionality by customizing user experience;
measure the performance of our services and improve their content and layout;
manage and protect our information technology infrastructure;
provide targeted marketing and advertising, provide service or transaction update notices, and deliver promotional offers based on communication preferences;
obtain a means by which we may contact you; either by telephone, text (SMS), email messaging, social media, etc;
conduct background checks, compare information for accuracy and verify same with third parties;
comply with legal, contractual and regulatory obligations;
execute your specific requests or use same for a specific purpose as you may instruct;
investigate and respond to your complaints or enquiries;
process your access to our services, Platforms, or functions from time to time;
Storage and protection of your Data
We will take all necessary measures to ensure that your personal Data is safe, however, you are also required to ensure that access codes, PINs, passwords, usernames, and all other information or hints that may enable third party access to your accounts on our Platforms are secure. We therefore strongly advise you to keep such information secure and confidential. If you use a third party’s device (laptops, phones, public internet, etc.) to access your account, kindly ensure that you always log out. Kindly note however that certain devices are programmed to save passwords or usernames, as such, we advise that you use third party devices with extreme caution. If you believe that an unauthorized person has accessed your information, please contact us immediately.
Processing your Information
In order to execute our obligations to you or process your transactions, we may be required to process your Information, such as your name, account number, account ID, contact details, shipping and billing address, or other information needed to complete the transaction. We also work with third parties, including financial institutions, vendors, service providers, who at one point or the other facilitate transactions executed on our Platforms. For completeness, in the course of your engagement with us or use of our services and Platforms, we may share your information with different stakeholders, including but not limited to Financial institutions; service providers; Credit bureaus and collection agencies to report account or credit information; Smile Planet’s subsidiaries and affiliates; Regulatory or judicial authorities; or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Smile Planet. Please note that the aforementioned parties may be within or outside Nigeria.
We may also process your Information when we believe, in our sole discretion, that the disclosure of your Information is necessary to comply with applicable laws and judicial/regulatory orders; conduct investigations; manage existing or imminent risks, prevent fraud, crime or financial loss, or for public safety or to report suspected illegal activity or to investigate violations of our Terms and Conditions.
In all cases, we will ensure that your Information is safe, and notify the receiving party of the confidential nature of your Information, particularly the need to maintain the confidentiality of same and prevent unlawful or unauthorised usage.
You have the following rights regarding your personal information collected by us:
Right to access your personal information being held by us. Requests for such information may be sent to firstname.lastname@example.org.
Right to request that your personal data be made available to you in an electronic format or that it should be sent to a third party (Kindly note that we have the right to decline such request if it is too frequent, unreasonable, and likely to cause substantial cost to us. In any event, we will communicate the reason for our refusal);
Right to rectify any inaccurate, incomplete information. As such, if you discover any inaccuracy in your personal information, kindly notify us promptly and provide us with documentary evidence to enable us to update the requisite changes.
Right to withdraw consent for the processing of your information, provided that such withdrawal shall not invalidate any processing hitherto done based on the consent previously given by you;
Restrict or object to the processing of your personal data provided that we may be compelled to process your data where required under law, regulatory authorities, or court of law.
Right to request that your personal data be deleted. We may however continue to retain the information where required under law, contract, regulatory authorities, or court of law.
We may share your personal information with:
Members of the Smile Planet provide joint content, products and services (such as registration, transactions and customer support), to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about their products, services, and communications. Members of the group will use this information to send you marketing communications and opportunities only if you have requested their services.
Credit bureaus and collection agencies to report account or credit information, as permitted by law.
Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Smile Planet or one of its agents; when we need to do so to comply with law; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement.
Other unaffiliated third parties, for the following purposes
Fraud Prevention and Risk Management: to help prevent fraud or assess and manage risk.
Customer Service: for customer service purposes, including to help service your accounts or resolve disputes.
Legal Compliance: to help them comply with anti-money laundering and counter-terrorist financing verification requirements.
Service Providers: to enable service providers under contract with us to support our business operations, such as fraud prevention, marketing, customer service and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
If you download or use our software, such as a stand-alone software product, an app, or a browser plugin, you agree that from time to time, the software may download and install upgrades, updates and additional features from us in order to improve, enhance, and further develop the software. We may utilise your personal information to internally evaluate our software.
Period of Storage
We retain your information for as long as necessary for the purpose(s) for which it was collected. The period of data storage is also subject to legal, regulatory, administrative and operational requirements.
Please note that this Policy does not apply to Information that is already in the public domain through no fault of ours.
If you violate the letter or spirit of this Policy, or otherwise create risk or possible legal exposure for us or attempt to violate the privacy rights of Smile Planet and/or its other users, we reserve the right to restrict your access to our Platforms. We will notify you in the event that we are constrained to make such a decision.
We are dedicated to ensuring that you are satisfied with our management of your Information. However, in the unlikely event that you have a complaint, please contact us via the details below, stating your name and details of your complaint. Upon receipt of your complaint we will endeavor to contact you within 3 (three) working days with a view to amicably resolving such dispute within the shortest possible time. The foregoing notwithstanding, all disputes arising from this policy shall first be resolved by negotiation. However, if parties fail to resolve the disputes amicably by such mutual consultations, parties shall further attempt to resolve the dispute by mediation.