User reserves the right to exercise their privacy and data protection rights under any applicable law or regulation.
Furthermore, if any revised version includes a substantial change in terms, Users shall be informed via email (sent to the email address specified in your account), by means of a notice on the Narms Digital Platform.
Narms Digital is the controller and responsible for the privacy of your personal data on the Narms Digital Platform.
Customer Service Desk
Email address: email@example.com
The Data We Collect About You
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).
Further details are provided below.
1. Identity Data
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, signature, billing address, delivery address, email address, BVN etc.
We may collect and process your Identity Data in order to provide our Services, comply with applicable laws and regulatory requirements, detect and prevent fraud, protect our vital interests and that of others, provide Service communications, provide customer service, maintain data and information security, facilitate corporate reorganisations, implement direct marketing campaigns
2. Formal Identity Documentation
Formal Identity Documentation includes government issued identity documents such as International Passport, Driver's License, National Identity Card.
We may collect and process your Formal Identity Documentation in order to provide our Services, comply with applicable laws and regulatory requirements, detect and prevent fraud, protect our vital interests and that of others, provide Service communications, provide customer service, maintain data and information security, facilitate corporate reorganisations, implement direct marketing campaigns.
3. Transaction Data
Transaction Data includes details about payments to and from you, bank account details and other details of Services you have received from us.
We may collect and process your Transaction Data in order to provide our Services, comply with applicable laws and regulatory requirements, detect and prevent fraud, protect our vital interests and that of others, provide customer service, ensure quality control, maintain data and information security, research and development purposes, enhance customer experience and implement direct marketing campaigns.
4. Communication Data
Communication Data includes all messages, communications, requests, files etc which you send to us while using or interacting with our Services for the purposes of making customer care enquiries, completing a feedback etc.
We may collect and process your Communication Data in order to provide customer service, ensure quality control, maintain data and information security, research and development purposes, comply with applicable laws and regulatory requirements, enhance customer experience and implement direct marketing campaigns.
5. Technical Data
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, browser fingerprint, authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.
We may collect and process your Technical Data in order to provide our Services, comply with applicable laws and regulatory requirements, detect and prevent fraud, research and development purposes, enhance customer experience and implement third party marketing campaigns.
6. Anonymised and Aggregated Data
Disclosure Of Your Personal Data
We may share your personal data with certain third-party which we deem necessary in order to provide our Services effectively or comply with applicable laws and regulatory requirements.
Our engagement terms with these third parties shall strictly require them to only use your information in connection with the services they perform for us and prohibit them from selling your information to anyone else. Such engagements shall also be subject to professional duty of confidentiality where applicable.
Further information are set out below –
(a) Third party identity verification service providers – In order to detect and prevent fraudulent transactions and comply with applicable laws and regulatory requirements, we may share your personal data with third party identity verification service providers who shall verify your identity against available public records and other third-party databases.
(b) Banks and other financial institution partners – In order to process payments and withdrawals and comply with applicable laws and regulatory requirements we may share your personal data with banks and financial institutions.
(c) Service providers – We may share your personal data with service providers that we engage their services to execute different business functions. Examples of these service providers include – cloud storages, network infrastructure providers, marketing, data analytics etc.
(d) Professional advisors – We may share your personal data with professional advisors in order to avail ourselves with technical, financial or legal consulting services or in compliance with our legal obligations.
(f) Law enforcement agents and officials – We may share your personal data with law enforcement agents and officials if we are bound by law or any legal procedure to share same or when we believe in good faith that the disclosure of your personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our Terms of Services or any other applicable policies.
When you access our websites or use our Services, we may place small data files on your
computer or other device. These data files may be cookies, pixel tags, "Flash cookies," or other local storage provided by your browser or associated applications (collectively referred to as "Cookies"). These technologies are used to –
(a) recognise Users as customers;
(b) customise the Service, content, and advertising; measure promotional effectiveness;
(c) help ensure that account security is not compromised;
(d) mitigate risk and prevent fraud; and
(e) promote trust and safety across the Service and related sites.
Users can freely decline our Cookies if the web browser or browser add-on permits unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with your use of our websites and the Service.
Third Party Websites
Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information.
We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Narms Digital Platform.
We have put in place appropriate security measures (and contractually require third parties we share your information with to maintain) appropriate physical, technical and administrative safeguards to prevent the personal data from being accidentally loss, misuse or in an unauthorised access, alteration or disclosure of your personal data. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
The security of your personal information it is instructive to note that no method of electronic transmission or storage of data guarantees 100% security. Thus, we strive to use commercially acceptable means to protect your personal information and we cannot guarantee its absolute security.
Based on the foregoing, we have established appropriate procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Retention Of Personal Data
We will only retain your personal information for as long as reasonably necessary to –
(a) provide our services to you,
(b) archiving purposes to detect and investigate fraudulent transactions,
(c) comply with our legal obligations under financial or anti-money laundering laws
(d) satisfying any tax, accounting or reporting requirements; and
(e) upon our reasonable belief that there is a prospect of litigation in respect to our relationship with you.
Under certain circumstances, you can exercise certain rights provided under applicable laws and regulations in relation to the personal information we hold. These rights include the right to –
(a) give and withdraw consent;
(b) request access to your personal information;
(c) request the rectification of your personal information;
(d) request erasure of your personal information;
(e) object to the processing of your personal information;
(f) request that we restrict the processing of your personal information;
(g) request the transfer of your personal information to you or a third party; and
(h) complain at any time with any relevant authority for data protection issues.