This Policy describes:
- a. the nature of information we may collect or that you may provide when you use and/or access the Waza APIs & web platform (“the Platform”); and
- b. how we collect, use, maintain, process, protect, and disclose Personal Information (as described in Paragraph 2.0 below)
Accordingly, by accessing and/or using the services available on the Platform (“Services”), you agree to be bound by the terms of this Policy, and consent to the processing and handling of your Personal Information in the manner as described herein.
This Policy only applies to information we collect on the Platform, via email, and other electronic communications sent via the Platform, or in connection with the Services. This Policy DOES NOT apply to information that:
- a. we collect offline from external sources, including websites you may access through the Platform;
- b. has been made anonymous so that it does not identify a specific user; and/or
- c. you provide to or is collected by any third party (see Third-Party Information Collection)
Please read the terms of this Policy carefully before accessing the Platform or using the Services. Your continued access and/or use thereof shall be construed as consent to terms of this Policy, as well as the use and processing of your Personal Information as provided herein.
We may update this Policy from time to time and will notify you when we do so. By continuing to use the Platform and/or the Services after the changes have been made, you consent that the collection, use and processing of your Personal Information will be subject to the terms of the updated Policy.
2. Definition of Terms
Account: means either of the following:
- a. a business account registered on the Waza business website - https://waza.co/
- b. a Naira-denominated account opened, operated and maintained with one of our partner banks
Personal Information: means either of the following:
- a. any information that can be utilised for the purpose of identifying a living person, including (but not limited to) email address, company name, password, payment card, financial information, Government-issued identity card number, Bank Verification Number (BVN) and/or taxpayer identification
- b. anonymous information that is linked to you, such as your internet protocol (IP), log-in information, address, location, device or transaction data
Website: means the Waza website - https://waza.co/
3. About Waza
Waza is a duly registered company in Nigeria whose registered address is at 13a, Sola Oguntade Close, Lekki, Lagos, Nigeria.
We provide payment and financial management services to African businesses, start-ups and the emerging market, in order to inter alia manage liquidity challenges and global payment needs.
We aspire to conduct business in a responsible and sustainable manner, in compliance with industry standards, thereby ensuring the security of customer information collected, processed and stored based on business requirements.
4.1. Personal Information we may Collect
In order to improve your experience and enable us effectively deliver the Services, we collect information from/ about you when you interact with the Platform and/or access the Services. Such information will include the following:
A. Identity Data. Information such as, your name(s), government-issued identity document/ number, bank verification number (BVN), photograph, tax identification number and your date of birth
B. Contact Information. This comprises data that is needed to reach out to you, such as your contact address, email address, phone number(s), details of the device you use and billing details
C. Technical Information. This includes links you have clicked on, length of visit on certain pages, unique device identifiers, log-in information, device details (including the address used to connect your mobile phone or other device to the internet, your login information, system and operating system type and version, browser or app version, time zone setting, operating system and platform), and your location (based on your IP address)
D. Financial Information. This comprises information such as payment method information (such as credit or debit card numbers),details of transactions initiated via the Platform, and other information provided by financial institutions; If you choose to share bank account information (e.g. account owner information, account balances, account number and details, account transactions)
E. Marketing and Communications Data. This includes information relevant to customer surveys and/or offers. We will collect any information you choose to provide to us, for example, through support tickets, emails or social media. When you respond to Waza emails or surveys, we collect your email address, name and any other information you choose to include in your response(s). If you contact us by phone, we will collect the phone number you use to call us, as well as other information you may provide during the call. We will also collect your engagement data such as your registration for, attendance of, or viewing of Waza events and other interaction with Waza personnel
4.2. Use of Personal Information Collected
Personal Information provided by our customers in connection with the Services enables us to provide users with a secure, smooth, efficient, and customized experience. Furthermore, such information may be used for the following purposes:
A. Improving and Developing our Services. Personal Information enables us analyse your use of our Platform and Services and diagnose technical issues. We also utilise Personal Data for the purpose of personalising our service offerings, in order to inter alia improve your experience on the Platform and protect the security and integrity of our Services
B. Compliance with Legal Obligations. We use Personal Data to meet our contractual and legal obligations related to anti-money laundering, Know-Your-Customer ("KYC") laws, anti-terrorism, export control and prohibitions on doing business with restricted persons or in certain business areas; and other relevant legal obligations. We strive to make our Services safe, secure and compliant, and the collection and use of Personal Data is thus critical in this regard. For example, we may monitor patterns of payment transactions and other online signals and use the information obtained thereby to reduce the risk of fraud, money laundering and other activity that is harmful to Waza and other customers.
In addition to the foregoing, you agree to be bound by the terms of our AML Policy and any breach of any of the provisions therein may result in the immediate suspension of your access to our platform and our obligations thereunder or the termination of the Services with or without notice to you. This is without prejudice to our statutory obligations to report you to the appropriate regulatory authorities in accordance with the provisions of the law.
C. Fraud Prevention and Security We collect and use Personal Data for the detection and mitigation of fraudulent activities across our Services, and to ensure the security of our Services and transactions against unauthorised access, use, modification or misappropriation of Personal Information, information and funds. In addition, we may provide our partners with Personal Information about you (including your attempted transactions), where this is reasonably required for the purpose of assessing fraud risks associated with a transaction, or for the purpose of investigating fraudulent activities in relation to a transaction
D. Payments. For the purpose of processing payment transactions, your Personal Information will be shared with a number of parties in connection with your transaction
E. Third Party Data Processing. We may transfer your Personal Information to nonaffiliated third-party service providers to perform a variety of services on our behalf, including analysing data to improve our Services, as well as fulfilling our service requests. Such disclosure shall be subject to agreements that prohibit the third parties from using or disclosing the Personal Information other than for the purpose of processing; and which impose security safeguards appropriate to the sensitivity of the information. Accordingly, these third parties will be bound by strict confidentiality & data security provisions, and will only use your Personal Information in ways specified by us. 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 data will be treated as Personal Information under this Policy.
4.3. Protection and Storage of Information
We have put in place reasonable security systems designed to prevent unauthorized access to or disclosure of Personal Information, and we will take reasonable steps to secure and safeguard such information against loss, theft, and unauthorized use, disclosure, or modification on an ongoing basis.
Some of the safeguards used by Waza are firewalls and data encryption, physical access controls to our data centres, and information access authorization controls. We have also taken additional measures by ensuring our system complies with industry information security standards.
Despite our very judicious efforts, you, however, understand and acknowledge that there is still a risk to your Personal Information being accessed without authorisation due to the fact that there is no full guarantee of fidelity in relation to information transmitted across the internet. You are however advised to adhere with our security protocols at all times, and not to share your passwords and other log-in details.
If we receive an order or instruction using your information, we will consider that you have authorized the transaction. We will not be liable for any unauthorised access to your Account or Personal Information, save to the extent that such access is as a result of the willful negligence of Waza, its affiliates or authorised representatives.
4.4. Sharing Customer Information with Other Users
When transacting with third parties, we may provide those parties with information to complete the transaction, such as your name, account ID, contact details, shipping and billing address, or other information needed to promote the reliability and security of the transaction. If a transaction is held, fails, or is later invalidated, we may also provide details of the unsuccessful transaction.
We work with third parties, including merchants, to enable them to accept or send payments from or to customers using our Services. In doing so, a third party may share information about customers with us, such as email address or mobile phone number, to inform such customer that a payment has been sent. We use this information to confirm that users are Waza customers, or to send customer notification of payment status. Also, we may oblige a request to validate that a customer transacts business with Waza.
We will not disclose your credit/debit card number to anyone you have paid or who has paid you using our Services, or with the third parties that offer or use our Services, except with your express permission or if we are required to do so to comply with credit/debit card rules, a subpoena, or other legal processes.
4.5. Sharing Customer Information with a Third Party
Personal information obtained from customers may be shared as follows:
A. With our subsidiaries and affiliates, which may use the aggregated information we share in a manner consistent with this Policy.
B. With contractors, service providers and other third party partners we use to support our business and who are bound by contractual obligations to keep such aggregated information confidential and use it only for the purposes for which we disclose it to them.
C. In the event of a transaction or proposed transaction involving the transfer of substantially all of the assets of Waza or one or more of its businesses to another entity, whether an affiliate or a third party, or in connection with a bankruptcy, we may share aggregated information in furtherance of the due diligence process or to otherwise facilitate the transaction, and with individuals assisting in the transaction or in connection with a bankruptcy. Any aggregated information may also be one of the transferred assets as part of the transaction or bankruptcy, and you shall be notified accordingly.
D. To the extent we reasonably believe we are required to do so by law or to comply with any legal or regulatory requirement or request, or to protect against fraud, illegal activity, to otherwise protect Waza from liability.
E. Where we believe it is necessary or appropriate to protect the rights, property or safety of the Platform users, any third party or Waza.
F. With other third parties with your consent or direction to do so (Please note that these third parties may be in other countries where the laws on processing personal information may be less stringent than in our country of primary jurisprudence).
If customers access the Platform or any of the Services directly on a third-party website or via a third-party application, any information that are entered on such systems (and not directly on a Waza website) will be shared with the owner of the third-party website or application. These sites are governed by their own privacy policies and customers are encouraged to review their privacy policies before providing them with personal information. Waza will not be responsible for the content or information practices of such third parties.
4.6. Cross Border Transfer of Customer Information
We are committed to adequately protecting all Personal Information regardless of where the data resides and to providing appropriate data protection measures for same, where such information is transferred across borders, including outside of Nigeria.
4.7. Transfer of Information to Third Parties Upon a Sale or Change of Control
We retain the right to transfer or assign all information pursuant to a merger, purchase or other transaction relating to our Company, its affiliates and sponsors. We shall however duly notify you of this occurrence.
4.8. Cookies and Other Similar Technologies
We may place small data files on your computer or devices when you access our websites or use any of our services. 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 recognize users as customers; customize our services, content, and advertising; measure promotional effectiveness; help ensure that account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety across our Services and related sites.
You are at liberty to 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 the Platform and the Services.
4.9. Privacy Policies of Other Websites
This Policy applies to only Waza and not any other brands though they be mentioned on the Website. For the avoidance of doubt, this Policy also does nott apply to our merchants, vendors, or other related partners.
4.10. Customer Consent
Please refer to the end of this notice for providing your consent. Your consent to personal data collection and processing may be revoked by notifying us via our contact page.
5. Data Retention
We will keep your Personal Information for as long as is reasonably necessary for the purposes described in this Policy, while we have a legitimate business need to do so in connection with your account, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is longer.
6. Your Rights regarding the use of your Personal Information
6.1. You shall be entitled to:
a. request for the deletion of your personal information, subject to any overriding legitimate grounds for the use of same
b. request for, and receive free of charge, any information regarding you which has been collected on the Platform, in concise & intelligible written form. Provided that where such request is determined by us to be manifestly unfounded or excessive, we shall be entitled to charge a reasonable fee for same, taking into consideration, inter alia the administrative costs of providing such information
c. contest the accuracy of your Personal Information, and to procure the rectification of any inaccurate information
d. restrict the use of your Personal Information, pending a determination as to the overriding nature of the legitimate grounds referenced in (a) above
e. withdraw consent to the processing of your Personal Information at any time, without affecting the lawfulness of processing of your information which you previously consented to. Note that if you revoke your consent to such processing, we will be unable to provide you with the Service(s) for which such consent is required
6.2. You can review and change your Personal Information by logging into the Platform and visiting your account profile page. You may also send us an email at firstname.lastname@example.org to request access to, correct or delete any personal information that you have provided to us. We cannot delete your Personal Information except by also deleting your Account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause such information to be incorrect