Last Updated: March, 2023
You agree that upon granting us your consent, you have the legal capacity to give consent and you are aware of your privacy rights and your option to withdraw your consent at any given time.
eBanqo also automatically collects anonymous information regarding your use of the Website and eBanqo services via the Platform and/or the App. As such, eBanqo shall, for example, automatically log which sections of the Website, Platform and/or App you visit, which web browser you use and which website you visited when you obtained access to the Website. We cannot identify you through these data, but it allows eBanqo to draw up statistical data regarding the use of the Website, the Platform and/or the App.
Personal data is collected by us when you voluntarily provide data to us in the following contexts:
The personal data collected by eBanqo are therefore expressly and voluntarily provided by you.
eBanqo can use your personal data for the following legitimate business purposes:
Please note that we may still use any aggregated and de-identified personal data for legitimate business purposes.
We will ensure that all personal data disclosed by you and that is held by us will be collected, processed, and stored according to the following governing principles of data processing expressly provided by the Nigeria Data Protection Regulation 2019 ("NDPR”):
Processing takes place on the following legal grounds, as the case may be:
We limit Personal Information collection and usage to data that is relevant, adequate, and necessary for carrying out the purpose for which the data is processed. We will evaluate whether and to what extent the processing of Personal Information is necessary and where the purpose allows, anonymized data will be used.
Notwithstanding the foregoing, it is possible that eBanqo may disclose your personal data to the competent authorities that includes law enforcement agencies, public or tax authorities or other organizations for the following purposes:
In all other cases, eBanqo will not sell, hire out or pass on your personal data to third parties, except when it (i) has obtained your permission to this end and (ii) has completed a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and privacy compliance of your personal data.
Where Personal Information is to be transferred to a country outside Nigeria, we shall put adequate measures in place to ensure the security of such Personal Information. We 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 ("NDPR”). We will therefore only transfer Personal Information out of Nigeria on one of the following conditions:
We will take all necessary steps to ensure that your Personal Information is transmitted in a safe and secure manner. Below are a few ways we ensure the protection of your data when transferring it to a foreign country:
Unless a longer storage period is required or justified (i) by the law or (ii) through compliance with another legal obligation, eBanqo shall only store your personal data for the period necessary to achieve and fulfil the purpose in question.
In the cookie banner on the Website and in this notice, we will explain in clear and plain language the relevant details about their use. This includes where they are hosted, the lifespan of the cookie, and their purpose. This list is subject to change, and it may not include all such providers at any given time. The Website uses four types of cookies; strictly necessary, performance, functional and marketing, and analytics cookies. These include first and third-party cookies: first party cookies are set and controlled by eBanqo, while third party cookies are set and controlled by a third-party tool or service.
The duration of a cookie varies: session cookies disappear from your computer or browser when you logout of your account or close your browser, while persistent cookies are stored even after you have closed the page. With the exception of Strictly Necessary Cookies, cookies will only be placed on your device and/or browser after you confirm or update your preferences through the cookie banner. If you decide to not allow opt-in cookies, the Website may not function as designed. For example, you may face issues logging in or retaining set preferences.
You can accept or decline cookies by modifying your browser setting to decline cookies, if you prefer.
Even though we collect your data only for legitimate business purposes, your data stays your own. The Nigeria Data Protection Regulation 2019 ("NDPR”) grants individuals who are in Nigeria the following certain rights, with some limitations.
We will establish a system to enable and facilitate the exercise of the following data subject rights by you:
Request access to your personal data (commonly known as a “data subject access request”): This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may notify you of our refusal to comply with your request in these circumstances. Where we have reasonable doubts concerning the identity of the natural person making the request for information, we may request the provision of additional information necessary to confirm the identity of the Data Subject. Kindly note the following:
Right to limit or restrict the processing of your personal data: This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you wish to invoke or exercise your privacy rights, please contact privacy@eBanqo.com. In principle, you can exercise these rights free of charge via the above-mentioned form. In addition, you can always, via your personal account, update, modify and/or verify your personal data which you were required to submit when creating your (trial) account.
The California Consumer Privacy Act (CCPA) provides California consumers with the right to request access to their personal information, additional details about our information practices and deletion of their personal information (subject to certain exceptions). California consumers also have the right to opt out of sales of personal information, if applicable. We describe how California consumers can exercise their rights under the CCPA below. Please note that you may designate an authorized agent to exercise these rights on your behalf by providing written materials demonstrating that you have granted the authorized agent power of attorney. Please note that if an authorized agent submits a request on your behalf, we may need to contact you to verify your identity and protect the security of your personal information. We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the consumer about whom we collected personal information. We will not discriminate against you if you choose to exercise your rights under the CCPA.
eBanqo undertakes to take reasonable, physical, technological and organizational precautions in order to avoid:
Your personal data is safeguarded against loss, access, use, modification, disclosure, or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your personal data including without limitation firewalls, virus scan tools, employee training, and physical office security measures.
Please note that despite these reasonable measures no security can absolutely guarantee the complete safety of your personal data.
eBanqo is located in the US and adheres to the laws of the US. Personal data collected by eBanqo may be transferred to the US. eBanqo shall store all personal data which it has collected in the cloud (with data center(s)) within the US. You expressly consent to your data being transferred to the US. Notwithstanding eBanqo’s security policy, the checks it carries out and the actions it proposes in this context, an infallible level of security cannot be guaranteed. Since no method of transmission or forwarding over the internet, or any method of electronic storage is 100% secure, eBanqo is, in this context, not in a position to guarantee absolute security.
Finally, the security of your (trial) account will also partly depend on the confidentiality of your password in obtaining access to the Platform and/or the App. eBanqo will never ask for your password, meaning that you will never be required to communicate it personally. If you have nonetheless communicated your password to a third party – for example because this third party has indicated that it wishes to offer additional services – this third party shall have access to your (trial) account and your personal data via your password. In such cases, you are liable for the transactions which occur as a result of the use made of your (trial) account. eBanqo therefore strongly advises you, if you observe that someone has accessed your (trial) account, to immediately change your password and contact us.
We will retain and store your personal data only for as long as necessary to fulfill the legitimate business purposes(s) for which it was collected and to comply with applicable laws and your consent to such purpose remains valid after termination of our relationship with you. When we no longer need information, we will take reasonable steps to destroy the information.
We are concerned about the safety and privacy of children who use the Internet. We encourage the viewing of our website by children to be done with parental supervision. Consistent with section 8 of the Nigeria Child Rights Act (“the Act”), Cap C50, Laws of the Federation of Nigeria 2010, Article 3.1 and 2.4 of the Nigeria Data Protection Regulation 2019 ("NDPR”) and Article 5.5 of the NDPR Implementation Framework, we will never knowingly request Personally Identifiable Information from anyone below the age of 18 under the Act and any person below 13 years for the purposes of the NDPR without prior verifiable parental consent. If we become aware that a child below the age of 18 under the Act and any person below 13 years for the purposes of the NDPR has provided us with personal data without verifiable parental consent, we will use our best efforts to remove such information from our files. If a parent or guardian becomes aware that his or her child has provided us with personal data without verifiable parental consent, he or she should contact us at privacy@eBanqo.com. If you access our Services or Platform and you are below 18 years, you represent and warrant that you have obtained consent from your parent(s) or legal guardian(s). If you have inadvertently provided personal data of a child to us, please notify us at privacy@eBanqo.com and we will delete such personal data.
The Website may potentially contain hyperlinks to other websites. When you click on one of these links, you may be redirected to another website or internet source that could collect information about you through cookies or other technologies. eBanqo does not bear any responsibility, liability or control authority over these other websites or internet resources, nor about their collection, use and disclosure of your personal data. You must check the privacy policies of these other websites and internet sources in order to be able to judge whether they act in accordance with the privacy legislations.
Please note that, the complaint and resolution procedure is not prejudicial to your right to complain to the data protection authorities (in this case, you should contact the National Information Technology Development Agency (NITDA) or Nigeria Data Protection Bureau (NDPB)) using the following contact details:
Email: email@example.com, firstname.lastname@example.org