Introduction

We, as an organization committed to lawfulness and transparency, prioritize the responsible management, processing, and protection of your Personal Data in accordance with relevant laws. Throughout our business operations and your interactions with us and third parties via our Platforms (including but not limited to websites, mobile applications, software, physical offices, and more), we may handle your Personal Data, subject to the terms outlined in this policy. This Privacy Policy ("Policy") serves to elucidate our privacy practices concerning the collection and processing of your Personal Data and delineates your rights as a user of our product, PayVite. This Policy is applicable to PayVite and all its associated services and tools, irrespective of the manner in which they are accessed or utilized.

Within this Privacy Policy, "we," "us," or "our" pertains to PayVite and its legal successors, agents, and assigns. "You" or "your" refers to yourself or any individual who subscribes to, employs, or authorizes the use of our Service.

By utilizing any of the PayVite Products, you acknowledge and accept this Privacy Policy, whether during the sign-up process or while using our products, services, content, technologies, or functionalities available on the Software/Application, as well as all associated websites and services ("Services"). Our Privacy Policy delineates the privacy rights of our users in the following key areas:

a. Information we collect.

b. Reasons for collecting such information.

c. Utilization of this information.

d. Storage, sharing, and safeguarding of this information.

Definition

For the purpose of this Policy

Personal Data/Information means any information relating to you, including your name, identification number, location data, online identifier address, photo, email address, pins, passwords, licenses, bank details, posts on our Platforms, religion, date of birth, health, race/tribe, nationality, ethnicity, political views, trade union membership, criminal records, medical information, and other unique identifiers such as but not limited to Media Access Control (MAC) address, Internet Protocol (IP) address, International Mobile Equipment Identity (IMEI) number, Bank Verification Number (BVN), International Mobile Subscriber Identity (IMSI) number, Subscriber Identification Module (SIM) and others. It also includes factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.

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 particularly with respect to the processing of your Personal Data. If you proceed to use our Website/Software/Application, 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. All Personal Data which we may process shall be in accordance with this Policy and other applicable laws

Collection Of Personal Data

During your interactions with PayVite or third parties through our platform, we may gather your Personal Data through the following means:

1. **Automatic Information Collection:** When you engage with us or our Software/Application using your computer, mobile device, forms, or documents, we may automatically collect data. This information encompasses, but is not limited to, details about the pages you access, your computer's IP address, unique device identifiers, device type, geo-location data, computer and connection details, mobile network information, page view statistics, and traffic to and from our platform. Additionally, we employ cookies and web beacons to collect anonymous information, tailoring your platform experience and enhancing account security. You have the option to decline our use of cookies, unless they are essential for platform functionality. It's important to note that refusing to allow cookies may impact your platform experience.

2. **Information from Downloads:** When you download or use our digital software, we may receive information about your location and your mobile device, including a unique device identifier. This information may be used to provide location-based services, such as tailored advertisements, search results, and personalized content. You can disable location tracking in your device's settings.

3. **Physically or Digitally Provided Information:** We may collect and process your information when you fill out forms, questionnaires, surveys, or provide data through documents, letters, emails, agreements, correspondence, identity cards, passports, or any other means through which you willingly share information with us.

4. **Third Parties:** Your information may also come from third parties, including relatives, guardians, financial institutions, identity verification services, vendors, and service providers, among others.

5. **Social Media:** Information may be gathered from your interactions with us on social media platforms such as Facebook, Instagram, LinkedIn, Twitter, and others. This can include your responses to our posts, comments, inquiries, messages to us, and more. We may also collect data from your public profiles and updates on social media.

Accessing Your Personal Information

When you use our Website, Application, or Software, we may gather information related to your activities and interactions with our Services. We are committed to maintaining the security and confidentiality of this data.

We provide you with the option to connect to our Software via various means, including mobile devices, computers, websites, and more. This Privacy Policy is applicable to all devices, including computers.

If you access, download, or use our mobile application or visit our mobile-optimized websites, we may collect details about your device and location, including a unique device identifier. This information enables us to offer location-based services, such as personalized advertisements and search results. Most mobile devices allow you to manage or disable location services through the device's settings menu. If you require assistance in disabling location services on your device, we recommend contacting your mobile service provider or the manufacturer of your specific device.

Using Your Personal Information

Throughout your interactions with us via our Website, Application, Software, or Platform, we collect personal information for various legal purposes. This data enables us to enhance your experience and provide more efficient services. Some of the reasons for collecting this information include:

1. Service Provision: We use your data to provide services and offer customer support.

2. Product Improvement: Gathering information helps us enhance and develop our product.

3. Financial Services: We use your information to provide payment and financial services, including facilitating money transfers and payments to other bank accounts.

4. User Needs: We identify your needs to better provide and improve our services.

5. Personalization: Your data enables us to personalize our products and make recommendations tailored to you.

6. Marketing: We may use your information for advertising and marketing purposes, including sending promotional communications and presenting relevant offers.

7. Analysis and Research: Data analysis helps us assess our performance, fulfill legal obligations, develop our workforce, and conduct research.

8. Account Creation: We collect information to create and manage your account for our services.

9. Communication: We use your data to communicate with you about your account, send information, and request feedback on our website, applications, or policy changes.

10. Updates: Periodic emails and updates about our products and services are sent based on your preferences.

11. Identity Verification: Verifying your identity is important, especially during account creation and password reset processes.

12. Risk Management: We use data to detect, investigate, and prevent activities that may violate our policies or be illegal, including fraud prevention.

13. Contractual Obligations: Data is used to fulfill our contractual obligations to you.

14. User Experience: We improve our services and user experience by customizing content and layout.

15. Infrastructure Management: Data helps in managing and protecting our information technology infrastructure.

16. Know Your Customer (KYC): We enable on-demand services by digitizing and standardizing KYC data reporting.

17. Targeted Marketing: Data allows us to provide targeted marketing, service updates, and promotional offers based on your communication preferences.

18. Contact: We gather your contact information to reach you through various means such as telephone, text (SMS), email, or social media.

19. Background Checks: Data is used for conducting background checks, verifying information, and comparing it with third-party sources.

20. Policy Administration: We use data to identify and address policy violations and administer our terms of use

21. Compliance: Data is used to comply with legal, contractual, and regulatory obligations.

22. Specific Requests: We process your data according to your specific requests or instructions.

23. Complaints and Inquiries: Data helps us investigate and respond to your complaints or inquiries.

24. Access to Services: Data is used to process your access to our services, Software, or functions as needed.

If we intend to use your Personal Information in a manner that deviates from this Privacy Policy, we will inform you of such anticipated use before or at the time when the Personal Information is required, and we will seek your consent accordingly.

Storage And Protection Of Your Data

We employ a comprehensive set of security measures, including physical, technical, and administrative safeguards, to protect your personal information and mitigate the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of these safeguards include:

- **Access Controls:** Our various platforms are accessible only to authorized users, enhancing security.

- **Secure Storage:** Your information is stored on secure servers, as well as in protected physical locations and, where applicable, on secure cloud infrastructure.

However, it's important to note that even with our best efforts, no security measures are entirely foolproof or invulnerable to breaches.

We retain your personal information for the duration necessary to fulfill the purposes outlined in this privacy policy, unless longer retention is mandated or allowed by law. To securely dispose of personal data, we may anonymize it, delete it, or take other suitable measures. Copies of personal data may persist for additional time for backup and business continuity purposes.

While we are committed to safeguarding your Personal Data, it is also imperative that you take precautions to ensure the security of your access codes, PINs, passwords, usernames, and any other information that could potentially grant third-party access to your accounts on our Platforms. We strongly recommend keeping such information confidential and secure. If you use a third party's device (e.g., laptops, phones, public internet) to access your account, please ensure that you log out after use. However, be aware that certain devices may save passwords or usernames automatically, so use third-party devices with caution. If you suspect unauthorized access to your information, please contact us promptly via our email payvite@proton.me. Your proactive involvement in protecting your data is essential.

Processing Your Information

To fulfill our obligations to you and carry out transaction processes, we may need to handle your Information, which can include details like your name, account number, contact information, office address, bank particulars, and shipping or billing address. Additionally, we collaborate with various third parties, including corporate entities, partners, and service providers, who play a role in facilitating transactions conducted on our Platform

For transparency, during your engagement with us or when using our services and Software, it's possible that we may share your information with various stakeholders. These stakeholders may encompass but are not limited to financial institutions, service providers, subsidiaries and affiliates of PayVite, regulatory or judicial authorities, and other third parties as necessitated by a subpoena, court order, or other legal processes or requirements. It's important to note that these parties may be located either within or outside the The Republic of Guinea, as needed.

Furthermore, we may process your Information if we, at our sole discretion, believe that disclosing your Information is necessary to adhere to applicable laws and regulatory orders, conduct investigations, mitigate existing or imminent risks, prevent fraud, criminal activities, financial losses, ensure public safety, report suspected unlawful actions, or investigate violations of our Terms and Conditions.

Regardless of the circumstance, we will take all necessary precautions to safeguard your Information and inform the receiving party about its confidential nature. This includes emphasizing the need to maintain the confidentiality of your Information and prevent any unauthorized or unlawful use.

Your Rights

You have the following rights concerning your personal information that we have collected:

1. Right to Access: You can request access to the personal information we hold about you. To make such a request, please email us at payvite@proton.me.

2. Right to Data Portability: You can ask for your personal data to be provided to you in an electronic format or sent to a third party. However, please note that we may decline such requests if they are frequent, unreasonable, or likely to result in substantial costs for us. In such cases, we will provide reasons for our refusal.

3. Right to Rectify: If you discover any inaccuracies or incompleteness in your personal information, you have the right to request corrections. Please promptly notify us and provide documentary evidence to facilitate the necessary updates.

4. Right to Withdraw Consent: You can withdraw your consent for the processing of your information. However, this withdrawal will not invalidate any processing that was carried out based on your prior consent.

5. Right to Restrict or Object: You have the right to restrict or object to the processing of your personal data. Please be aware that there may be legal requirements, regulatory obligations, or court orders that compel us to continue processing your data.

6. Right to Erasure: You can request the deletion of your personal data. However, we may be required by law, contract, regulatory authorities, or court orders to retain certain information even after your request for deletion.

We are committed to upholding your rights regarding your personal information, and we will take appropriate actions in accordance with applicable laws and regulations.

Disclosures

We may share your personal information with various parties for specific purposes:

a. **PayVite Company Members:** We may share your information with other PayVite group entities to provide joint content, products and services. This sharing facilitates tasks such as registration, transactions, and customer support, as well as detecting and preventing potentially illegal activities and policy violations. It also guides decisions about their own products, services and communications. These group members will only send you communications and marketing opportunities if you have requested their services.

b. **Mergers and Acquisitions:** If we plan to merge with or are acquired by another company, we may share your information with them. In such instances, we will ensure that the new entity adheres to this Privacy Policy in relation to your personal information. If your information might be used differently from this policy, you will receive prior notice

c. **Legal Obligations:** We may disclose your personal information to law enforcement, government officials, or other third parties when required by a subpoena, court order, or other legal processes applicable to PayVite or its agents. We may also do so to comply with the law or when, at our discretion, we believe that disclosing personal information is necessary to prevent physical harm, financial loss, report suspected illegal activities, or investigate violations of our Terms & Conditions and other agreements.

Additionally, we may share your information with unaffiliated third parties for the following purposes:

a. **Fraud Prevention and Risk Management:** Sharing information to prevent fraud or assess and manage risk.

b. **Customer Service:** Sharing for customer service purposes, including account servicing and dispute resolution.

c. **Legal Compliance:** Sharing to assist in complying with anti-money laundering and counter-terrorist financing verification requirements.

d. **Service Providers:** Sharing with contracted service providers to support our business operations, such as fraud prevention, marketing, customer service, and technology services. Our contracts with these service providers specify that they can only use your information for services performed on our behalf and not for their own gain.