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Privacy Policy

INTRODUCTION

This Privacy Policy applies to Oystr Finance Limited’s online interface (i.e., website or mobile application) and any Oystr Limited affiliate or subsidiary online interface that links to this Policy, (individually referred to as a 'site', and, collectively, 'sites'). The term 'the company' or 'Oystr' or 'we' or 'us' or 'our' in this Policy refers to Oystr Limited and any affiliates or subsidiaries of Oystr Limited that link to this Policy. This Policy describes how the Sites may collect, use, and share information from or about you, and explains how information may be collected and used for advertising purposes.


Oystr Finance Limited recognizes your privacy rights as guaranteed under the 1999 Constitution of the Federal Republic of Nigeria, the Nigeria Data Protection Act 2023, Nigerian Data Protection Regulation 2019, and other applicable privacy laws in Nigeria. Thus, it is important to us as a law-abiding organization that your Personal Data is managed, processed, and protected in accordance with the provisions of the applicable laws. In the course of our business and/or your engagement with us and third parties through our Platforms (this includes but is not limited to our websites, digital platforms, mobile applications, and physical operations/offices, amongst others), we may process your Personal Data, subject however to the terms of this Policy. This Privacy Policy (the “Policy”) therefore explains our privacy practices with respect to how we collect, and process your Personal Data and describes your rights as a user of any of our services and Platforms.

As a user of any of our Platforms, you accept this Privacy Policy when you sign up for or use our products, services, content, technologies, or functions offered on our Platforms and all related sites and services (“Services”).


Our Privacy Policy explains our user’s privacy rights regarding:

  1. a. What information we collect.
  2. b. Why we collect such information.
  3. c. The use of such information.
  4. d. The storage, sharing, and protection of such information.

DEFINITIONS

For the purpose of this Policy:

Personal Data/Information means information relating to you, including your name, location data, online identifier address, email address, pins, passwords, bank details, and other unique identifiers such as but not limited to IP address, IMEI number, Bank Verification Number, IMSI Number, SIM and others.


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.


PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how the Company collects and processes your personal data through your use of this website, including any data you may provide through this website when providing your financial information.


This Policy is intended to govern the use of the Site by users. Users reserve the right to exercise their data protection rights as listed under the Customer Rights. For any access request, questions, or inquiries about how we use your Personal Information, please contact us at Kayode Otitoju Street, Off Admiralty Road, Lekki, Lagos State, Nigeria or write to us at our office at [email protected].


CONSENT

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.


AGE

You must be at least 18 years old to use our services or any of our Platforms. Individuals under the age of 18, or the applicable age of maturity, may utilize our Platforms services only with the involvement of a parent or legal guardian, under such person’s account. Regardless, all Personal Data which we may process shall be in accordance with this Policy and other applicable laws.


THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit


COLLECTION OF DATA

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:


  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender. We may collect and process your information when you create and/or update your account on our Platform, complete forms, questionnaires, surveys, etc.
  • Contact Data includes delivery address, email address, and telephone numbers.
  • Financial Data includes bank account, payment card details and other relevant information.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
  • Usage Data includes information about how you use our website, products and services.
  • Social Media: includes your engagements with the Company 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.
  • Third Parties: includes information from third parties such as, guardians, financial institutions, identity verification services, vendors, and service providers etc.

Although it is not compulsory to give us this information if you do not then, we may not be able to provide you with the full range of services that the Site has to offer. Information is collected electronically and manually when you visit our website and register to use any of our services Information is collected electronically with exchanges between your system or service provider's system and our system.

We collect your information manually when you complete our product and services registration forms in registering to use any of our services. Similar information is also collected when customers or visitors' visit our physical locations for inquiries or business relationship.


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.

We may offer you the ability to connect with our Platforms using a mobile device, either through a mobile application (App), computer, mobile optimized website, or by any other means. The provisions of this Privacy Policy apply to all such mobile access and use of mobile devices.
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, application 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 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;
  • Improve 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;
  • Identify or address a violation and administer our policies and terms of use;
  • 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.

If we intend to use any Personal Information in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal information is required and obtain your consent.


SECURITY OF DATA

Oystr protects your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Oystr runs a secure security architecture from applications, software, and processes to secure data from outsiders and abuse from insiders.

Oystr uses advanced tools to secure data at rest and data in transit. Oystr complies with a management system for business continuity, quality management, information security, and payment cards.
Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. We have also taken additional measures by ensuring our system complies with industry information security standards.


STORAGE AND PROTECTION OF DATA

We protect your personal information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, unauthorised disclosure, and alteration. Some of our safeguards include firewall protection, Virtual Private Network (VPN) protection, encryption of data, authorization keys for authorised access, and strong passwords. Access to our various platforms is restricted to authorized users only. Your Information is also stored on our secure servers as well as secure physical locations and cloud infrastructure (where applicable). Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your personal information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law. To dispose of personal data, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time. 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.


DATA RETENTION

We will keep your data for as long as we have a relationship with you. Once our relationship with you has come to an end (e.g., following the closure of your account or following the termination/expiration of a transaction), or your application for a product is declined or you decide not to go ahead with it, we will only retain information on our servers for as long as is reasonably necessary to fulfill the purposes we collected it for, including for the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Where you close your Account, your information is stored on our servers to the extent necessary to comply with regulatory obligations and for the purpose of fraud monitoring, detection, and prevention. Where we retain your Information, we do so in compliance with limitation periods under the applicable law while the retention period will be in line with the requirements of regulatory bodies in the Federal Republic of Nigeria.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal regulatory, tax, accounting or other requirements.


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; our subsidiaries and affiliates; Regulatory or judicial authorities; or other third parties pursuant to a subpoena, court order, or other legal process or applicable requirement. 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.


YOUR RIGHTS

You have several rights regarding your personal information collected by us. The rights include:


  • Right to access your personal information being held by us. Request for such information may be sent to [email protected].
  • 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.

DISCLOSURES

We may share your personal information with:


  • a. Members of Oystr to 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.
  • b. Credit bureaus and collection agencies to report account or credit information, as permitted by law.
  • c. Companies that we plan to merge with or are acquired by. (Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to your personal information. If your personal information could be used contrary to this policy, you will receive prior notice).
  • d. Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Oystr 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:


  • a. Fraud Prevention and Risk Management: to help prevent fraud or assess and manage risk.
  • b. Customer Service: for customer service purposes, including to help service your accounts or resolve disputes.
  • c. Legal Compliance: to help them comply with anti-money laundering and counter-terrorist financing verification requirements.
  • d. 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.

CHANGES TO YOUR INFORMATION

Keeping your account information accurate and up to date is very important. If your account information is incomplete, inaccurate, or not current, please use the Contact Us option on our Site, or call or write to us at the telephone numbers or appropriate address for changes listed on your account statements, records, online, or other account materials. You can also speak to a customer representative from the Company.


SHARING THIS INFORMATION

Certain services available on this Site are offered in conjunction with one or more of our business partners. For those services to be provided we provide some necessary details about you to our business partners.
We inform you about this at the point we collect that information on the Site. Please note that certain services may be unavailable if you do not want to disclose the personal information you are asked for. We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganization, but we will take steps with the aim of ensuring that your privacy rights continue to be protected.

In addition, we may pass your information onto one of our carefully selected business partners or to other carefully selected third parties to enable them to send you information that may be of interest to you but only if you have permitted us to do so. You can tell us to stop this at any time by sending an email. Other than as set out above, we will not disclose any of your personal information without your permission unless we are required by law to do so (for example, if required to do so by a court order or for the prevention of fraud or other crime).


SOFTWARE

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 utilize your personal information to internally evaluate our software.


EXCEPTIONS

Please note that this Policy does not apply to Information that is already in the public domain through no fault of ours.


VIOLATION

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 Oystr 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 take such a decision.


DISPUTE RESOLUTION

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.


CONTACT US

If you have questions regarding your data privacy rights or would like to submit a related data privacy rights request, kindly contact us via the information below:

Address: Kayode Otitoju Street off Admiralty Road Lekki, Lagos State, Nigeria Email: [email protected] Phone number: +234 8142360264.

Please allow up to 3 (three) working days for requests to be processed. We reserve the right to charge a reasonable fee to process excessive or repeated requests.


AMENDMENT

We may amend or revise this Policy at any time by posting a revised version on our website. Notice of the amendment shall be posted on our website and the revised version will be effective from the date of publication. Kindly, note that your continued use of our Platform after the publication of the revised version constitutes your acceptance of our amended terms of the Policy.