Privacy policy.

This policy is effective as of 28th Octoer 2022 and was last updated on 28th October 2023.

Landpay Investment Limited (“Landpay”, “we”, “us”, “our”), recognizes your privacy rights as guaranteed under the 1999 Constitution of the Federal Republic of Nigeria; The Nigerian Data Protection Regulation, and other applicable privacy laws in Nigeria. Thus, it is important to us as a law-abiding organisation 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 are not limited to our websites, digital platforms, mobile applications, physical operations/offices, amongst others), we may process your Personal Data, subject however to the terms of this Policy.

This Privacy Policy (“Policy”) therefore explains our privacy practices with respect to how we collect, process your Personal Data and describes your rights as a user of any of our services and Platforms. This Policy applies to all our Platforms, and all related sites, applications, services and tools regardless of how they are accessed or used. In this Privacy Policy, “we”, “us” or “our” refers to Landpay and its successors, agents and assigns, while “you”, “your” refers to you and/or any person who subscribes for, uses or authorises the use of the Service.

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. What information we collect
• 2. Why we collect such information
• 3. The use of such information
• 4. The storage, sharing and protection of such information

Definitions

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.

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 applicable age of maturity, may utilise our Platforms services only with 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.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You. We collect names; phone numbers; email addresses; usernames; passwords; contact or authentication data; debit/credit card numbers; mailing addresses; date of birth; and other similar information.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

**Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).

**Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.

Information collected through our App

In Short: We collect information regarding your mobile device, push notifications, when you use our App.

If you use our App, we also collect the following information:

**Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, contacts, sms messages, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

**Mobile Device Data. We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID and information about the features of our App you accessed.

**Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings. This information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g. Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

**To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. See the section below headed “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” for further information.

**To post testimonials. We post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at privacy@landpay.ng and be sure to include your name, testimonial location, and contact information.

**Request feedback. We may use your information to request feedback and to contact you about your use of our Services.

**To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent. To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

**To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

**To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).

**To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.

**To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

**Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

**Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.

**To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.

**To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

**To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS?” below).

**Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

**For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

**We access your contact list information to enable you send digital assets to other users in your contact list.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

**Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.

**Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

**Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

**Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

**Vital Interests: We may disclose your 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.

More specifically, we may need to process your data or share your personal information in the following situations:

**Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

**Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data on our behalf about how you interact with our Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

**Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

In Short: We only share information with the following categories of third parties.

We only share and disclose your information with the following categories of third parties. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”.

We may share your personal information with:

** Members of Landpay, 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.

** 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 Landpay 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.

**Communication & Collaboration Tools

**Data Analytics Services

**Data Storage Service Providers

**Government Entities

**Payment Processors

**User Account Registration & Authentication Services

**Website Hosting Service Providers

Other unaffiliated third parties, for the following purposes

• 1. Fraud Prevention and Risk Management: to help prevent fraud or assess and manage risk.
• 2. Customer Service: for customer service purposes, including to help service your accounts or resolve disputes.
• 3. Legal Compliance: to help them comply with anti-money laundering and counter-terrorist financing verification requirements.
• 4. 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.

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Services offers you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such social media platforms.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

If you have questions or comments about your privacy rights, you may email us at privacy@landpay.ng

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Log in to your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may Contact us using the contact information provided.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

10. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at privacy@landpay.ng

12. HOW CAN YOU REVIEW. UPDATE. OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact: privacy@landpay.ng

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 Landpay 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 endeavour 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 arbitration.

Miscellaneous

Our working hours are between 8am to 5pm on Mondays to Fridays (excluding weekends and public holidays). All payouts are made to your wallet at the end of the investment term/maturity date. Withdrawal requests are processed within 48 hours. Any request made after the official business hours will be attended to on the next working day