Privacy Policy
Introduction
Validate Systems ("Validate Systems",
"we", "us", "our"), recognizes
your privacy rights as guaranteed under the 1999
Constitution of the Federal Republic of Nigeria; the
Nigerian Data Protection Regulation 2019 (NDPR) issued by
the National Data Technology Development Agency (NITDA), and
the privacy provisions in other relevant laws applicable to
our business in Nigeria. Thus, it is important to us as a
law-abiding organisation that your Personal Data is managed,
processed and protected in accordance with the provisions of
the applicable laws. During our business and/or your
engagement with us and third parties through our Platforms
(including our websites, digital platforms, mobile
applications, physical operations/offices, amongst others),
we may process your Personal Data, subject however to the
terms of this Policy. This Privacy Policy
("Policy") therefore explains our privacy
practices with respect to how we process your Personal Data
and describes your rights as a user of any of our services
and Platforms.
This Policy applies to all our Platforms, and all related
sites, applications, services and tools regardless of how
they are accessed or used.
Definitions
For the purpose of this Policy:
Data means any information relating to you, including
your name, identification number, online identifier address,
photo, email address, date of birth, health, race/tribe,
nationality, ethnicity, political views, trades union
membership, criminal records, medical information, and other
unique identifiers such as but not limited to MAC address,
IP address, International Mobile Equipment Identity (IMEI)
number, International Mobile Subscriber Identity (IMSI)
number, Subscriber Identification Module (SIM), National
Identification Number (NIN), and others.
Process/Processing means any operation or set of
operations which is performed on your personal Data or sets
of personal Data, whether or not by automated means, such as
collection, recording, organisation, structuring, storage,
adaptation or alteration, retrieval, consultation, use,
disclosure by transmission, dissemination or otherwise
making available, alignment or combination, restriction,
erasure or destruction.
Consent
We kindly request that you carefully read through this
Policy before using our Platforms. Please note that if you
proceed to use any of our Platforms and services, it will
deemed that you have provided your express consent to the
terms of this Policy.
Age
You must be at least 18 years old to use our services or any
of our Platforms. Individuals under the age of 18, or
applicable age of maturity, may utilize our Platforms
services only with involvement of a parent or legal
guardian, under such person’s account. Regardless, all
Personal Data which we may process shall be in accordance
with this Policy and other applicable laws.
Collection of Data
In the course of your engagement with us or with third
parties through our Platforms, we may collect your personal
Data in the following ways:
Automatic Data collection We may automatically collect Data
upon your engagement with us or our Platforms through your
computer, mobile phones, forms, documents made available to
us, other access devices like a webservice call. We also
collect anonymous information through our use of cookies and
web beacons to customize your experience on our Platform and
to improve account security. You may decline our use of
cookies, unless same is mandatory for the use of our
Platform. Please note however that refusal to permit the use
of cookies may affect your use of our Platform.
Data from downloads When you download or use our digital
Platforms, or access any of our sites, we may receive
information about your location and your mobile device,
including a unique identifier for your device. We may use
this information to provide you with location-based
services, such as advertisements, search results, and other
personalized content. You may disable your location in the
settings menu of the device.
Physically or Digitally Provided Data: We may collect and
process your information when you create and/or update your
account on our Platform, complete forms, questionnaires,
surveys etc. We may also collect Data from the data you
provide to us through API, documents, letters, e-mail,
agreements, correspondence, Identity cards, certificates,
passports, or through any other means by which you wilfully
provide information to us.
Third Parties We may also receive your information from
third parties such as relatives, guardians, financial
institutions, vendors, and service providers, government
agencies etc.
Social Media: We also receive Data through your engagements
with us on social media sites (e.g., Facebook, Instagram,
LinkedIn, Twitter, and WhatsApp). This includes but are not
limited to your replies to our posts, your comments,
enquiries, messages to us, etc.
Using Your Personal Data
In the course of your engagements with us or through our
Platforms, we collect personal information for various legal
reasons, largely to enable us to personalize your experience
and to provide a more efficient service to you.
If we intend to use any personal Data in any manner that is
not consistent with this Privacy Policy, you will be
informed of such anticipated use prior to or at the time at
which the Personal information is required and obtain your
consent.
Storage and protection of your Data
We protect your personal Data using physical, technical, and
administrative security measures to reduce the risks of
loss, misuse, unauthorized access, disclosure and
alteration. Some of our safeguards include ensuring that
sensitive Data are encrypted and stored, with only
authorised users having access to this information. Access
to our various Platforms is restricted to authorized users
only. Your Data is also stored on our secure servers as well
as secure physical locations and cloud infrastructure. Data
are also stored in data centers which are collocated out of
our office environment to ensure security of data and also
availability of data when required.
We will take all necessary measures to ensure that your
personal Data is safe, however, you are also required to
ensure that access codes, PINs, passwords, usernames, and
all other information or hints that may enable third party
access to your accounts on our Platforms are secure. We
therefore strongly advise you to keep such information
secure and confidential. If you use a third party’s device
(laptops, phones, public internet, etc.) to access your
account, kindly ensure that you always log out. Kindly note
however that certain devices are programmed to save
passwords or usernames, as such, we therefore advise that
you use third party devices with extreme caution. If you
believe that an unauthorized person has accessed your
information, please contact us immediately.
Processing your Data
In order to execute our obligations to you or process your
transactions, we may be required to process your Data, such
as your name, identification number, contact details, shipping and billing
address, or other information needed to complete the
transaction. We also work with third parties, including
financial institutions, vendors, service providers,
government agencies who at one point or another facilitate
transactions executed on our Platforms. For completeness, in
the course of your engagement with us or use of our services
and Platforms, we may share your information with different
stakeholders, including but not limited to financial
institutions; partners; service providers; government
agencies; credit bureaus and collection agencies to report
account or credit information; affiliates of Validate
Systems; regulatory or judicial authorities; or other third
parties pursuant to a subpoena, court order, or other legal
process or requirement applicable to Validate Systems.
Please note that the parties mentioned above may be within
or outside Nigeria.
We may also process your Data when we believe, in our sole
discretion, that the disclosure of your Data is necessary to
comply with applicable laws and judicial/regulatory orders;
conduct investigations; manage existing or imminent risks,
prevent fraud, crime or financial loss, or for public safety
or to report suspected illegal activity or to investigate
violations of our Terms and Conditions.
In all cases, we will ensure that your Data is safe and
strictly processed only when necessary, and we will notify
the receiving party of the confidential nature of your Data,
particularly the need to maintain the confidentiality of
same and prevent unlawful or unauthorised usage.
Your Rights
You have the following rights regarding your personal information collected by us:- Right to access your personal Data being held by us.
- Right to request that your personal data be made available to you in an electronic format or that it should be sent to a third party (Kindly note that we have the right to decline such request if it is too frequent, unreasonable, and likely to cause substantial cost to us. In any event, we will communicate the reason for our refusal);
- Right to rectify any inaccurate, incomplete information. As such, if you discover any inaccuracy in your personal Data, kindly notify us promptly and provide us with documentary evidence to enable us to update the requisite changes;
- Right to withdraw consent for the processing of your Data, provided that such withdrawal shall not invalidate any processing previously done based on the consent previously given by you;
- Right to restrict or object to the processing of your personal Data. Kindly note that this right will not apply if we are compelled to process your data where required by any law, regulatory authorities, or court of law;
- Right to request that your personal Data be deleted. We may however continue to retain the Data where required by law, contract, regulatory authorities, or court of law.
- Right to Data portability;
- Right to lodge complaints with relevant authorities;
- Right to information regarding the existence of automated decision-making, including profiling and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing;
Cookie Policy
Cookies are small pieces of data, stored in text files, that
are stored on your computer or other device when websites
are loaded in a browser, and which collects information
about user actions on a site.
When you access our Platforms, 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 recognize users as customers;
customize 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 on our Platform. We also use
cookies to collect and use Data as part of our services,
recognize your browser or device, learn more about your
interests, and provide you with essential features and
services.
This Policy applies to our websites and Platforms alone. We
do not exercise control over the sites displayed or linked
from within our various services. These other sites may
place their own cookies or other files on your computer,
collect Data or solicit personal Data from you.
What type of cookies do we use?
Temporary cookies: This is also known as 'session
cookies'; it helps our sites and platforms to recognize
users, temporary memorize their online activities and the
information provided when they navigate through a website.
Session cookies only retain information about your
activities for as long as you are on the website. Once the
web browser is closed, the cookies are automatically
deleted.
Permanent cookies: This is also known as 'persistent
cookies' or 'first-party cookies'; they
remain in operation even after the web browser has closed.
It helps our sites or Platforms remember your information,
preferences and settings such as language selection and
internal bookmarks for when you revisit in the future.
Why do we use cookies?
Cookies store helpful information to enhance users’
experiences on our Platforms, and possibly to improve our
ability to reconnect with you later. They are used to
remember you and your preferences such as your preferred
language, device settings, browsing activities and other
useful information, help you navigate between pages
efficiently, and generally improve your experience in using
our services.
These cookies may be used as follows:
Authentication: We use cookies and similar technologies to
recognize you when you visit our site. If you are signed
into our website or mobile app, it helps us show you the
right information and personalize your experience in line
with your settings. Cookies also enables us to identify you
and verify your account.
Security: We use cookies to make your interactions with our
services and Platforms faster and more secure. For example,
we use cookies to enable and support our security features,
keep your account safe and to help us detect malicious
activity and violations of our terms and conditions of use.
Preferences, features and services: We use cookies to enable
the functionality of our Services, such as helping you to
fill out forms on our Services easily and providing you with
features, insights and customized content. We also use it to
remember information about your activities on our Platforms,
and your preferences.
Performance, Analytics and Research: Cookies help us learn
more about how well our services perform in different
locations. We use cookies to determine and measure
performance and to learn whether you have interacted with
our websites, content or emails and provide analytics based
on those interactions.
Where We Place Cookies
We set cookies in a number of different locations across our
services. These locations may include:
Our website, and other services or Platforms
Our mobile applications
E-mails (We may use cookies in some of our emails to enable
us to understand how you interact with our emails. It also
helps us to improve our future email communications with
you. Depending on your email or browser settings, cookies in
our emails may be automatically accepted.)
Controlling Cookies
We will always ask for your consent to accept the use of
cookies on your device. You can freely decline our cookies
when you see our "accept cookies" request or
through your browser settings. Cookies are optional unless
they are required to prevent fraud or ensure the security of
Platforms we control. You may also configure your specific
browser or email settings to automatically reject cookies.
You may also erase cookies stored on your device through
your browser settings or by deleting the folder or file
where they are stored on your device.
Declining our cookies may affect your ability to fully
utilize of our Platform and services. Without cookies you
may not have access to certain features on the site,
including access to certain personalized content.
Validate Systems may revise this Cookies Policy to reflect
changes in the law, our data collection and use practices,
the features of our site, or advancements in technology. If
we make any material changes, we will notify you by email or
through a prominent notice on our sites/platforms prior to
such change.
Third Party Contract & Service Providers Data Policy
Data transfer to third parties
We may share your personal Data with our service providers,
financial institutions, vendors, affiliates, subsidiaries,
parent company, contractors, government agencies etc. to
assist us in providing, delivering, analyzing,
administering, improving, and personalizing content that are
delivered to you as part of our services. These include
third parties who assist us in performing, delivering, or
enhancing certain products and services related to the
delivery and operation of our services; or who provide
technical and/or customer support on our behalf; or who
provide application or software development and quality
assurance; or who provide verification functions, who
process transactions and payment requests, research on user
demographics, interests, and behaviour, and other products
or services. These third-party service providers may also
collect personal information about or from you in performing
their services and/or functions on our website or Platforms.
We may also pass certain requests from you or your
organization to these third-party service providers.
Regardless of the third-party involved, any disclosure shall
only be for a lawful purpose.
Data transfer for the purpose of legal/regulatory
compliance
We may from to time be required to share your personal data
with a regulator, law enforcement body, government agency,
court or other third party to (i) comply with the law; (ii)
enforce the terms of a contract; and (iii) protect the
rights, property, or safety of Validate Systems or the
public.
Links to third-party websites or services
This Policy only applies to Data collected by our
site/Platforms or which we transfer in the course of our
services to you. Our site and Platforms may contain links to
other websites or services that are not owned or controlled
by us, including links to websites of financial or technical
partners, financial institutions, vendors, advertisers,
sponsors, partners, service providers, who at one point or
the other facilitate transactions executed on our Platforms.
We have no control over these third-party websites, and your
use of third-party websites and features are subject to the
privacy policies of those websites or platforms. We are not
responsible or liable for the privacy or business practices
of any third-party websites linked to our site or
third-party social media feature or functionality displayed
on our site, including, but not limited to Facebook,
LinkedIn, Twitter, etc. Your use of third-party websites
linked to our sites is at your own risk, therefore, we
encourage you to read the privacy policies of any linked
third-party websites or platform you access through or
outside our sites or platforms. If you are dissatisfied with
the privacy policy or data protection standard of such third
party, you are at liberty to exit such site/platform.
Validate Systems will not be responsible for any damage,
loss or liability caused to you on those third-party sites
or platforms.
Security of shared information
We will not share your Data with any third party until we
obtain an undertaking (implicit or explicit) that they will
take appropriate steps to implement appropriate security
measures by themselves, their employees, officers,
affiliates, and sub-processors to protect your Data and
prevent unauthorised disclosure or loss. We will also ensure
that such third parties commit themselves to the statutory
and contractual obligation of confidentiality, as may be
stipulated in a non-disclosure agreement, privacy policy,
confidentiality clauses, etc. We will also obtain an
undertaking that such third party will comply with the
Nigerian Data Protection Regulations, 2019, and other
applicable data protections laws in force, and that it will
under no circumstances use your Data for any unlawful
purpose or purpose other than that for which the Data was
disclosed.
Validate Systems will from time to time monitor and review
the conduct or activities of these third parties to ensure
that they are compliant with the confidentiality obligations
imposed on them.
Exceptions
Please note that this Privacy Policy does not apply to Data
that is already in the public domain through no fault of
ours.
Violation
If you violate the letter or spirit of this Policy, or
otherwise create risk or possible legal exposure for us or
attempt to violate the privacy rights of Validate Systems
and/or its other users, we reserve to restrict your access
to our Platforms. We will notify you if we are constrained
to take such decision.
Dispute resolution
We are dedicated to ensuring that you are satisfied with our
management of your Data. However, in the unlikely event that
you have a complaint, please contact us via the details
below, stating your name and details of your complaint.
Contact Us
If you have questions regarding your data privacy rights or
would like to submit a related data privacy right request,
kindly contact us via the information below:
Validate Systems
36 Ilupeju Street
Camp FUNAAB
Ogun State.
Phone number: 09131176590
Email address: info@validatesystems.com
Please allow up to 2 (two) working days for requests to be
processed. The Company reserves the right to charge a
reasonable fee to process excessive or repeated requests.
Amendment
We may amend or revise this Policy at any time by posting a
revised version on our website. Notice of the amendment will
be posted on our website and the revised version will be
effective from the date of publication. Kindly note that
your continued use of our Platform after the publication of
the revised version constitutes your acceptance of our
amended terms of the Policy.