PRIVACY POLICY

Please read our Privacy Policy before you may become a business or personal user of the WalNG platform. The onus is on you to access our Terms & Agreements, as well as any amendments made thereto and to contact WalNG Payment Services Limited (“WALNG, We, Us, Our”) in the event of any queries you may have. By using any part of the WALNG service, you acknowledge and agree to the processing of your personal data under the terms and conditions set out in this privacy policy.

1.0 Your Privacy Rights

This Privacy Policy describes your privacy rights regarding our collection, use, storage, sharing and protection of your personal information. It applies to the WalNG platform (which comprises of the WalNG website and/or mobile applications), its applications, services, tools and content regardless of how you access or use them.

2.0 Consent

You accept this Privacy Policy when you sign up for, access, or use our products, services, content, features, technologies or functions offered on our WalNG platform, all related sites, applications, and services (collectively known as “WalNG” or the “Platform”). This Policy governs the use of WalNG by registered and non-registered users, unless otherwise agreed through a written contract. We may amend this Privacy Policy at any time (and without recourse to you) by posting a revised version on our Platform and/or through email notification. The revised version will be effective seven (7) days after posting or any other date as may be communicated by us.

3.0 Your Personal Information

3.1 When you use WalNG services either as a registered or non-registered user, we collect information sent to us by your computer, mobile phone, Point of Sale (“POS”) terminal or other electronic access devices. The information shall be collected automatically and shall include but not limited to data about the pages on the Platform which you access, your computer IP address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral Uniform Resource Locator (URL), ad data, and standard web log data.
3.2 We may also collect information you directly provide to us including but not limited to information on web forms, account update information and correspondence with WalNG support services. We also collect information about your transactions and your activities. In addition, we collect your contact information such as; name, address, phone number, email, etc. We also collect your Bank Verification Number (BVN), National Identification Number (NIN), bank account name and numbers and these may be linked to your WalNG profile, where applicable. Information obtained through survey responses, telephone conversations, user enquiries and other means may also be collected and used by us.
3.3 We may also use information provided by third parties like social media sites and verification agencies. Information about you which are provided by you or any person to other websites or platforms are not controlled by WalNG, and we are therefore not liable for how they use it.
3.4 If the information you have supplied to us is wrong, you can put in a request to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes, and when responding to a request to update your personal information, we may ask you to verify your identity before we can act on the request. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems). Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.
3.5 You can also let us know if you feel that your personal information is being processed in any way other than how you have consented to it being used. We will take reasonable steps to ensure that your personal information is processed in the manner in which you have consented to it, or we may delete it based on your instruction. However, we may not accede to your request if it is unrealistic, impractical or inimical to our compliance with applicable regulation or laws.

4.0 What we do with your personal information

Our purpose for collecting your personal information is to give you an efficient, enjoyable and secure customer experience. We may use your information to:

4.1 Provide WalNG Services and support;
4.2 Process transactions, and send notices about your transactions to requisite parties;
4.3 Verify your identity;
4.4 Resolve disputes, collect fees, and troubleshoot problems;
4.5 Manage risk, or detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
4.6 Detect, prevent or remediate violations of policies or applicable user agreements;
4.7 Improve WalNG Services by implementing aggregate user preferences;
4.8 Measure performance of WalNG Services and improve content, technology and layout;
4.9 Manage and protect our information technology infrastructure;
4.10 Contact you at any time through your provided telephone number, email address or other contact details;
4.11 Notify you about your account, troubleshoot problems with your account, resolve a dispute, collect fees or monies owed, poll your opinions through surveys or questionnaires, enforce our policy, or as otherwise necessary to service your account, we may contact you through information provided. WALNG will not request for your Personal Identification Number (PIN), Account Identification Number (AIN), Dynamic Personal Identification Number (Dynamic PIN) or Bank Verification Number (BVN) from you either through email, telephone call, SMS or written documents. You are solely responsible for safeguarding any Personal Identification Number (PIN), Account Identification Number (AIN) or Dynamic Authentication Number (Dynamic PIN) you generate in the course of using WalNG.
4.12 Notify you of new products, services and/or offerings, newsletters and similar messages (“promotional messages”); or any enhancements/amendments to existing products services and/or offerings that we think may be of interest to you. If you do not want to receive such promotional materials from us, you may opt out at any time by sending an email to dpo@wal.ng.
4.13 To create stores of value and/or bank accounts for you and in your name with CBN licensed financial institution(s) to enable you transact seamlessly on the platform
4.14 Carry out other activities permitted by law including; the fulfillment of our contract with you, compliance with legal and/or regulatory requirements, to protect your vital interest or that of any other natural person, and so on.
4.15 If we intend to process your personal information for any purpose other than those listed in this policy, we shall provide you with relevant information on the further processing and seek your consent before the processing commences.

5.0 Cookies

5.1 Cookies are small files placed on your computer’s hard drive that enables the platform or website to identify your computer as you view different pages. Cookies allow websites and applications to store your preferences in order to present content, options or functions that are specific to you. Like most interactive websites, and online platforms, WalNG uses cookies to enable the tracking of your activity for the duration of a session. WalNG uses only encrypted session cookies which are erased either after a predefined timeout period or once the user logs out of WalNG and closes the browser. Session cookies do not collect information from the user’s computer. They will typically store information in the form of a session identification that does not personally identify the user.
5.2 We do not have access or control over the cookies of our partners, affiliates, and service providers. We are therefore not responsible for their use of their cookies.

6.0 How we protect your personal information

6.1 We store and process your personal information on our computers in Nigeria, Africa and elsewhere in the world where our facilities are located. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. You have a right (upon your request) to be informed of the appropriate safeguards for data protection in the foreign country.
6.2 We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls.
6.3 Furthermore, in the event of an actual or suspected breach of your personal information, we will:
- 6.3.1 Furthermore, in the event of an actual or suspected breach of your personal information, we will:
- 6.3.2 use best effort to remedy the breach within one (1) month from the date we report the breach to you.

7.0 Access to Your Data

7.1 If you are a registered user on WalNG, you may access your personal information using your secure login credentials to access the relevant system features for such purpose. If you are a non-registered user, you may request for your personal information by sending an email to support@wal.ng
7.2 This information should only be used for your own purposes and not to circumvent the platform, or to be distributed to other parties who may use such information to the disadvantage of WALNG.
7.3 You will be able to access reports of your previous transactions up to seven years after the transaction date, subject to a continuous period of use. The applicability of the seven year period will re-commence if there has been a break in use for a period of more than three months. WALNGwill advise you on any applicable fees to request access to data in such events.
7.4 You have the right to request that we stop using your data or return your data to you, or transmit the data directly to another data controller. The withdrawal of your consent at any time shall not affect the lawfulness of the processing based on your consent before its withdrawal. In the event you intend to exercise your right in this regard, kindly notify us through support@wal.ng and your request shall be treated promptly.

8.0 How We Share your information with other Relevant Parties

8.1 During your transaction, we may provide the corresponding party with information such as your name, account identification details, contact details, shipping and billing address, or other information needed to promote the integrity and security of the transaction. We may also provide details of unsuccessful transactions.
8.2 We work with third parties, including but not limited to merchants, to enable them to accept or send payments from or to you, using WalNG. In doing so, a third party may share information about you with us, such as your email address or mobile phone number, to inform you that a payment has been sent to you or when you attempt to pay a merchant or third party. We use this information to confirm that you are a WalNG customer and that WalNG as a payment and collection platform can be enabled. We also validate your status as a WalNG customer to third parties on your instruction.
8.3 We enter into contracts with third parties to perform certain business-related functions necessary to ensure the optimal provision of the service to you, including but not limited to payment processing, data storage, security, identity verification, fraud prevention, etc. We disclose relevant portions of your information to these third parties where reasonably necessary. With respect to the confidentiality of your personal information, these third parties are bound by extant laws and regulations on data protection, including the provisions of NDPA 2023 (including amendments or supplemental provisions).
8.4 Except in instances relating to clause 8.3 above, upon receiving your clear and unequivocal instruction, we may also share your personal information with third parties in a manner deemed reasonable and convenient for us, either physically or through any digital channel available at any point in time.
8.5 You accept that your pictures and testimonials on all social media platforms about WalNG can be used for limited promotional purposes by WALNG or its agents. This does not include your trademark or copyright protected materials.
8.6 We may also divulge data about you if, in our opinion, the disclosure is reasonable and legally permissible for the purpose of ensuring the integrity of our business operations. Additionally, in the event of a merger or corporate restructuring, we may also divulge your personal information to applicable parties.
8.7 Where your employee, as part of the process of application for a service from WALNG or a third party, requires his/her data to be provided in support of such an application to WALNG or a third party, WALNG is obligated to avail such request, upon the employee giving the requisite authorisation as the Data Owner/Data Subject, in the form prescribed by WALNG or the third party.
8.8 From time to time we may send you relevant information such as product updates, new functionalities, tips on how to use WalNG and new service offerings.
8.9 We may also share your personal information in compliance with local or international regulatory requirements, with fraud prevention and risk management agencies, with our service providers or in compliance with a court order.
8.10 We may also share your personal information with our affiliate entities, particularly members of the SystemSpecs Group (i.e., SystemSpecs Holdings Limited and other entities in which SystemSpecs Holdings Limited holds considerable influence and control), to enable us to provide you with information and services which we believe may be beneficial or may be of interest to you and/or members within your organisation. The affiliate entities may use the personal information for marketing and non-marketing activities. You may opt out at any time by sending an email to dpo@wal.ng
8.11 We recognise the privacy of minors, and we do not knowingly collect personal information belonging to minors.

9.0 Security

We will always hold your information securely. To prevent unauthorized access to your information, we have implemented controls and security safeguards at technical and operational levels. This site uses Secure Sockets Layer/Transport Layer Security (SSL/TLS) to ensure secure transmission of your personal data. You should see the padlock symbol in your URL address bar when accessing the site, www.wal.ng. The URL address will also start with “https://” depicting a secure webpage. SSL applies encryption between two points such as your personal computer (PC) or any other electronic device used by you to access WalNG, and the connecting server. Any data transmitted during the session will be encrypted before transmission and decrypted at the receiving end. This is to ensure that data cannot be read during transmission.

10.0 Data Confidentiality Rights

Your information is regarded as confidential and will not be divulged to any third party except under legal and/or regulatory conditions. You have the right to request for copies of all information we keep on you, provided that you give us reasonable notice of such a request in writing. While WALNG is responsible for safeguarding the information entrusted to us, your role in fulfilling confidentiality duties includes but is not limited to adopting and enforcing appropriate security measures such as non-sharing of passwords and other platform login or transaction authentication details. You are ultimately responsible for the security of your platform login and transaction authentication details.

11.0 Links to Other Websites

11.1 Certain transaction processing channels on WalNG may require links to other websites. Please note that WALNG is not responsible for, and has no control over third party websites. We do not monitor or review the content of other parties’ websites which are linked from this website. Opinions expressed or materials appearing on such websites are not necessarily shared or endorsed by us, and WALNG should not be regarded as the publisher of such opinions or materials, and you agree that we shall not be liable for any liability arising from your interpretation of any information on any third party website linked to WalNG. Please be aware that we are not responsible for the privacy practices, or content of any third party sites and we encourage our users to read the privacy statements of these third party sites. You should evaluate the security and trustworthiness of any other site connected to this site or accessed through this site yourself, before disclosing any personal information to it. WALNG will not accept any responsibility for any loss or damage in whatever manner, howsoever caused, resulting from your disclosure to third parties of your personal information.
11.2 We reserve the right to modify our Policy at any time and without any prior notice to you. Ensure you check this Policy regularly to stay updated with any amendment and understand how we use your information.

12. Limitation of Liability

12.1 WALNG will not be liable for loss of income, profits, business, opportunity, goodwill, contracts or any indirect, special, incidental or consequential damages arising out of or in connection with the Service, any computation or failed transaction on WalNG, arising out of any breach of this Policy.
12.2 We will not be liable for any loss or damage arising as a result of unauthorized access to the Service if (a) you intentionally or negligently fail to take reasonable precautions to protect your security, access codes, login details or any device used to access the Service, (b) you failed to promptly notify us that the Service was being accessed in an unauthorised way after becoming aware of it, or (c) you acted fraudulently.
12.3 Our liability to you or any third party in any circumstance of proven liability by us, shall not exceed the fees paid to us in respect of the specific transaction that gave rise to the claim or liability, unless otherwise specified by a court of competent jurisdiction.
12.4 Notwithstanding any provision in clauses 12.1, 12.2 and 12.3, limitation of liability shall not apply if we breach any provision of the Nigeria Data Protection Regulation 2019 (“NDPR

13. QUERIES AND QUESTIONS

13.1 You have the right to request that we stop using your data or return your data to you. In the event you intend to exercise your right in this regard, kindly notify us via support@wal.ng and your request shall be treated promptly.
13.2 Any other complaints, questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our Data Protection Officer through support@wal.ng, and where your complaints are not sufficiently addressed, you may lodge a complaint with a relevant data protection authority.

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