PRIVACY POLICY

Effective from the 19th of September, 2022

Dewallet (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used, and disclosed by Dewallet. This Privacy Policy applies to our Mobile app, and its associated subdomains (collectively, our “Service”) alongside our website and is. By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

Definitions and key terms

To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are referenced, are strictly defined as:

  • Cookie: small amount of data generated by a website and saved by your web browser. It is used to identify your browser, provide analytics, and remember information about you such as your language preference or login information.
  • Company: when this policy mentions “Company,” “we,” “us,” or “our,” it refers to Dharmochy Tech LTD, situated at OFF SEYE NUGA STREET, ASHI BODIJA IBADAN NIGERIA that is responsible for your information under this Privacy Policy.
  • Country: where Dewallet or the owners/founders of Dewallet are based, in this case is Nigeria
  • Customer: refers to the company, organization or person that signs up to use the Dewallet Service
  • Device: any internet connected device such as a phone, tablet, computer or any other device that can be used to visit Dewallet and use the services.
  • IP Address: Every device connected to the Internet is assigned a number known as an Internet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet.
  • Personnel: refers to those individuals who are employed by Dewallet or are under contract to perform a service on behalf of one of the parties.
  • Personal Data: any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
  • Service: refers to the service provided by Dewallet as described in the relative terms (if available) and on this platform.
  • Third-Party Service: refers to advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we think may interest you.
  • Website: Dewallet's site, which can be accessed via this URL: dewallet.app
  • You: a person or entity that is registered with Dewallet to use the Services.

What Information Do We Collect?

We collect information from you when you visit our website/app, register on our site, place an order, subscribe to our newsletter, respond to a survey or fill out a form. This information includes the following:

  • Name / Username
  • Phone Numbers
  • Email Addresses
  • Password
  • Phone Contacts

We collect this information through your mobile device operating system, by requesting your express consent to your device’s permissions on the App. We are committed to safeguarding the privacy of your information at all times. To this end, we have appointed a data protection officer (“DPO”). If you have any questions about this Policy or our data protection practices, please contact the DPO. Contact Details Full name of legal entity: Dewallet limited Name or title of DPO:

How Do We Use The Information We Collect?

Any of the information we collect from you may be used in one of the following ways:

To personalize your experience (your information helps us to better respond to your individual needs) To improve our website/app (we continually strive to improve our website/app offerings based on the information and feedback we receive from you) To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs) To process transactions To administer a contest, promotion, survey or other site feature To send periodic emails

We use aggregated information to analyze the effectiveness of the App, to improve the same, and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users participating in the App ,and may share aggregated information with third parties. We may collect aggregated information through the features of the software that supports the App, through cookies, and through other means described in this Policy. To enable us to better understand the characteristics of our users and/or to provide services tailored to your needs, we may combine your personal information with certain automatically-collected information that would not otherwise be personally identifiable. If we combine or link any automatically collected, non-individually identifiable information with your personal information, the resulting combination will be treated as personal information under this Policy. The processing or use of your information for the reasons specified above is legally permissible under Section 2.1 and 2.2 of Nigerian Data Protection Regulation (NDPR) and necessary for the purposes of the legitimate interests pursued by Dewallet

Purpose of collecting personal data

We collect and use your personal data:

to process your membership application or renewal; to verify your identity; for direct marketing purposes to send you information, newsletters and other materials about us and assist with your queries; and to make such disclosures as required by applicable laws. While the supply of your Personal Data is voluntary, if you choose not to provide your Personal Data to us, we may not be able to provide you with the information or our services you require.

Purpose of collection phone contacts data

You may provide us with various information in connection with your interaction with our Dewallet services or feature. For example, You may through creating a customer, associate a phone number, that is not registered in the Dewallet database or belongs to a the User or a business. Dewallet will collect the information You provide in connection therewith, as well as any other information You provide through the services or when You communicate or interact with us using the service.

When does Dewallet use end user information from third parties?

Dewallet will collect End User Data necessary to provide the Dewallet services to our customers. End users may voluntarily provide us with information they have made available on social media websites. If you provide us with any such information, we may collect publicly available information from the social media websites you have indicated. You can control how much of your information social media websites make public by visiting these websites and changing your privacy settings .

Do we share the information we collect with third parties?

We may share the information that we collect, both personal and non-personal, with third parties such as advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we think may interest you. We may also share it with our current and future affiliated companies and business partners, and if we are involved in a merger, asset sale or other business reorganization, we may also share or transfer your personal and non-personal information to our successors-in-interest. We may engage trusted third party service providers to perform functions and provide services to us, such as hosting and maintaining our servers and the website/app, database storage and management, e-mail management, storage marketing, credit card processing, customer service and fulfilling orders for products and services you may purchase through the website/app. We will likely share your personal information, and possibly some non-personal information, with these third parties to enable them to perform these services for us and for you. We may share portions of our log file data, including IP addresses, for analytics purposes with third parties such as web analytics partners, application developers, and ad networks. If your IP address is shared, it may be used to estimate general location and other technographics such as connection speed, whether you have visited the website/app in a shared location, and type of the device used to visit the website/app. They may aggregate information about our advertising and what you see on the website/app and then provide auditing, research and reporting for us and our advertisers. We may also disclose personal and non-personal information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate in order to respond to claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations.

Where and when is information collected from customers and end users?

Dewallet will collect personal information that you submit to us. We may also receive personal information about you from third parties as described above.

How Long Do We Keep Your Information?

We keep your information only so long as we need it to provide Dewallet to you and fulfill the purposes described in this policy. This is also the case for anyone that we share your information with and who carries out services on our behalf. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we’ll either remove it from our systems or depersonalize it so that we can’t identify you.

How Do We Protect Your Information?

We implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information. We offer the use of a secure server. We cannot, however, ensure or warrant the absolute security of any information you transmit to Dewallet or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or managerial safeguards.

We do not sell personal information

Building services and tools for the businesses means we have a responsibility to keep your data safe. We do not sell our users’ names or phone numbers to third parties because it is against our ethics. So that our users are able to use our app for free, we work with advertising partners such as Google and others listed in our app and provide trusted partners with caller ID services. Period.

Could my information be transferred to other countries?

Where Personal Information is to be transferred to a country outside Nigeria, Dewallet shall put adequate measures in place to ensure the security of such Personal Information. In particular, Dewallet shall, among other things, confirm whether the country is on the National Information Technology Development Agency (“NITDA”) White List of Countries with adequate data protection laws. Transfer of Personal Information out of Nigeria would be in accordance with the provisions of the Nigeria Data Protection Regulation. Dewallet will therefore only transfer Personal Information out of Nigeria on one of the following conditions: The consent of the Data Subject has been obtained; The transfer is necessary for the performance of a contract between Dewallet and the Data Subject or implementation of pre-contractual measures taken at the Data Subject’s request; The transfer is necessary to conclude a contract between Dewallet and a third party in the interest of the Data Subject; The transfer is necessary for reason of public interest; The transfer is for the establishment, exercise or defense of legal claims; The transfer is necessary in order to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent. Dewallet will take all necessary steps to ensure that Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside Nigeria shall be provided to you upon request by Dewallet.

Is the information collected through the Dewallet Service secure?

We take precautions to protect the security of your information. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes or fail to follow policies. Therefore, while we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If applicable law imposes any non-disclaimable duty to protect your personal information, you agree that intentional misconduct will be the standards used to measure our compliance with that duty.

Can I update or correct my information?

Under the NDPR, you have the right to request access to, correct or delete any personal information that you have provided to us. You may send us an email to effect any of these. Please note that we cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. You also have to right to data portability. In addition, you may also lodge a complaint with NITD Dewallet’s Customers have the right to request the restriction of certain uses and disclosures of personally identifiable information as follows. You can contact us in order to (1) update or correct your personally identifiable information, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personally identifiable information maintained about you on our systems (subject to the following paragraph), by cancelling your account. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. Promptly after receiving your request, all personal information stored in databases we actively use, and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and technically practicable. If you are an end user and wish to update, delete, or receive any information we have about you, you may do so by contacting the organization of which you are a customer.

Objection to Processing of Your Personal Information

You can object to the processing of your personal information, where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;

Request for Transfer of Your Personal Information

You can request for the transfer of your personal information to you or to a third party. We will provide you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Please note that this request may also attract an administrative fee

Withdrawal of Consent

You can withdraw your consent anytime where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Governing Law

Through your use of the Site or Services, You agree that the laws of the Federal Republic of Nigeria shall govern any matter or dispute relating to or arising out of this Agreement. The courts in Nigeria shall have jurisdiction over all matters arising from the use of the Website portal or the Services. By using Dewallet or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not engage with our website, or use our services. Continued use of the website, direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal information will mean that you accept those changes.

Your Consent

By using our website/app, registering an account, or making a purchase, you hereby consent to our Privacy Policy and agree to its terms.

Links to Other Websites

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by Dewallet. We are not responsible for the content, accuracy or opinions expressed in such websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us. Please remember that when you use a link to go from the Services to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our platform, is subject to that website’s own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.

Cookies

Dewallet uses “Cookies” to identify the areas of our website that you have visited. We use Cookies to enhance the performance and functionality of our website/app but are non-essential to their use. However, without these cookies, certain functionality like videos may become unavailable or you would be required to enter your login details every time you visit the website/app as we would not be able to remember that you had logged in previously. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our website correctly or at all. We never place Personally Identifiable Information in Cookies.

Blocking and disabling cookies and similar technologies

Wherever you’re located you may also set your browser to block cookies and similar technologies, but this action may block our essential cookies and prevent our website from functioning properly, and you may not be able to fully utilize all of its features and services. You should also be aware that you may also lose some saved information (e.g. saved login details, site preferences) if you block cookies on your browser. Different browsers make different controls available to you. Disabling a cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your browser, you should visit your browser’s help menu for more information.

Changes To Our Privacy Policy

We may change our Service and policies, and we may need to make changes to this Privacy Policy so that they accurately reflect our Service and policies. Unless otherwise required by law, we will notify you (for example, through our Service) before we make changes to this Privacy Policy and give you an opportunity to review them before they go into effect. Then, if you continue to use the Service, you will be bound by the updated Privacy Policy. If you do not want to agree to this or any updated Privacy Policy, you can delete your account.

Third-Party Services

We may display, include or make available third-party content (including data, information, applications and other products services) or provide links to third-party websites or services (“Third- Party Services”).You acknowledge and agree that Dewallet shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof. Dewallet does not assume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services. Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely at your own risk and subject to such third parties’ terms and conditions.

Contact Us

Don’t hesitate to contact us if you have any questions regarding our privacy policy.

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