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1. The Information we Collect
The personal data we collect depends on how you interact with us, the services you use, and the choices you make. We may collect information from different sources and in various ways, including information you provide directly, information collected automatically, third-party data sources, and data we infer or generate from other data.
1.1 Personal Data You Provide Directly
We collect personal data you provide to us. For example:
- Contact information. As part of our operations, Paystack may collect information such as your name, telephone number, address etc.
- Payment information. If you make a purchase or other financial transaction, such as when you checkout with Paystack on a Merchant’s website, we collect credit card numbers, financial account information, and other payment details.
- Communications. If you contact us directly, for example with an inquiry or a support request, we may receive additional personal data about you, including your email address and the content of your communications.
1.2 Personal Data We Collect Automatically
- Device Information.We receive information about the device and software you use to access our Services, including Internet Protocol (IP) address, web browser type, operating system version, and device identifiers.
- Location Information. When you use our Services, we may collect or infer your general location information. For example, your IP address may indicate your general geographic region.
1.3 Personal Data That We Receive from Others or Infer
- Partners. We may retrieve additional personal data about you from third parties and other identification/verification services such as your financial institution and payment processor. We may combine that data with other information we have about you.
- Publicly available sources Public sources of information such as open government databases.
- Inferences. We may infer additional Personal Data based on the Personal Data described above. For example, for site visitors, we may infer your interests based on the web pages you view.
When you are asked to provide personal data, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional.
2. How We Use Personal Information
We use the Personal Data we collect to:
- Provide you with the required services.
- Respond to your questions or requests
- Improve features, website content and analyse data to develop products and services
- Address inappropriate use of our website
- Prevent, detect and manage risk against fraud and illegal activities using internal and third party screening tools
- Send you marketing content, newsletters and service updates curated by Paystack (only with your explicit consent)
- Target advertisements to you based on your visits to our website
- Verify your identity and the information you provide in line with Paystack’s statutory obligations using internal and third party tools
- Maintain up-to-date records
- Resolve disputes that may arise, including investigations by law enforcement or regulatory bodies
- Any other purpose that we disclose to you in the course of providing Paystack services to you
3. How We Share Personal Data
- Financial services & payment processing. When you provide payment data, for example to make a purchase, we will share payment and transactional data with banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, or other related financial services.
- Affiliates. We enable access to personal data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access is needed to provide our services and operate our business.
- Corporate transactions. We may disclose personal data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
- Legal and law enforcement. We may access, disclose, and preserve personal data in accordance with applicable law and when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
- Security, safety, and protecting rights. We will disclose personal data if we believe it is necessary to:
- protect our customers and others, for example to prevent fraud, or to help prevent the loss of life or serious injury of anyone;
- operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or
- protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies.
Third party analytics and advertising companies also collect personal data through our website and apps including, transaction details, account information, marketing and communications data, demographic data, content and files, geolocation data, usage data, and inferences associated with identifiers and device information (such as cookie IDs, device IDs, and IP address) as described in the Cookies section of this statement. These third party vendors may combine this data across multiple sites to improve analytics for their own purpose and others. For example, we use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners.
Finally, we may share de-identified information in accordance with applicable law.
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5. How We Protect your Information
Paystack shall establish adequate controls in order to protect the integrity and confidentiality of personal data, both in digital and physical format and to prevent personal data from being accidentally or deliberately compromised.
Paystack is committed to managing your personal data in line with best practices. We protect your personal data using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration, we also use industry recommended security protocols to safeguard your personal data. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to our building and files, and only granting access to personal data to employees who require it to fulfil their job responsibilities. Employees may have access to personal data only as is appropriate for the type and scope of the task in question and are contractually forbidden to use personal data for their own private or commercial purposes or to disclose them to unauthorised persons, or to make them available in any other way.
In compliance with the Payment Card Industry Data Security Standard (PCI DSS Requirements”), we implement access control measures, security protocols and standards including the use of encryption and firewall technologies to ensure your card information is safe and secure in our servers, additionally, we implement periodical security updates to ensure that our security infrastructures are in compliance with reasonable industry standards.
Two factor authentication (“2FA”) is an additional layer of security we have added to your account. When 2FA is enabled, you will be required to enter a One Time Password (OTP) (which is a verification code we have sent to you for authentication purposes), each time you checkout using Paystack on a merchant’s website or platform. While we encourage you to enable this feature on every transaction, you may choose to disable the 2FA feature after your initial enrolment by clicking on the toggle button to disable. However, if you choose to disable this feature, you agree that Paystack shall not be liable for any loss or damages incurred as a result of your action.
Paystack also maintains a data breach procedure in order to deal with incidents concerning personal data or practices leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed. You may contact our Data Protection Officer (DPO) upon becoming aware of any breach of personal data or if your access credentials have been compromised, to enable us to take the necessary steps towards ensuring the security of your personal data or account.
6. Storage Limitation
We will retain your information for the following periods:
- As long as reasonably necessary for the purpose of providing our services to you
- For the duration your account is active and we have your consent
- For the period needed to comply with our legal and statutory obligations
- As needed to verify your information with a financial institution
Paystack is statutorily obliged to retain the data you provide in order to process transactions, ensure settlements, make refunds, identify fraud and to comply with applicable laws and regulatory guidelines.
7. Transfer of Data
Where personal data is to be transferred to a country outside Paystack’s countries of operation, Paystack shall put adequate measures in place to ensure the security of such personal data. Any transfer of personal data out of Paystack jurisdictions will be in accordance with the provisions of relevant data protection regulations. In particular, Paystack shall, among other things, use contractual terms to ensure protection of the data or ensure the country has adequate data protection laws (i.e. listed in the General Data Protection Regulation’s [“GDPR”] Adequacy List).
Should you wish to transfer personal data to a country deemed to have inadequate data protection laws, Paystack will take all necessary steps to ensure that informed consent is obtained from you, and you are aware of the risks entailed with such transfer. In any instance, Paystack will ensure personal data is transmitted in a safe and secure manner. Details of the protection given when your personal data is transferred abroad, and details of the basis of such transfers shall be provided to you upon request.
8. Grounds for Processing of Personal Data
Processing of personal data by Paystack shall be lawful if at least one of the following applies:
- the Data Subject has given consent to the processing of his/her personal data for one or more specific purposes;
- the processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which Paystack is subject;
- processing is necessary in order to protect the vital interests of the Data Subject or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in Paystack; and
- processing is necessary for the purposes of the legitimate interests pursued by Paystack or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
9. Choices and Rights
Individuals who have personal data held by Paystack are entitled to reach out to Paystack to exercise the following rights:
- Right to request for and access any personal data collected and stored by Paystack;
- Right to be informed regarding their personal data and any automated decision-making including profiling;
- Right to be informed about appropriate safeguards in place where data is transferred abroad;
- Right to request data undergoing automated decision making is moved to another Controller in a structured electronic commonly used format (data portability);
- Right to request rectification and modification of personal data which Paystack keeps;
- Right to request the deletion of their data;
- Right to revoke consent;
- Right to restrict processing or object to processing of personal data;
- Absolute Right to object to direct marketing; and
- Right to submit a complaint to a Supervisory Authority.
Your request will be reviewed and answered by Paystack’s Data Protection Officer within a 30-day period upon receipt of the request.
11. Contact Paystack’s Data Protection Officer (DPO)
For any further queries, our Data Protection Officer, may be reached at the following address:
126 Joel Ogunnaike Street,
Ikeja GRA, Ikeja,