This privacy policy (this "Privacy Policy") explains how personal information is collected, used, stored, and disclosed by Piggytech Global Limited, ("PiggyVest," "we," "us," and "our").
The provisions contained in this Privacy Policy supersede all previous notices and statements regarding our privacy practices with respect to our services.
Last updated: August, 2024
This privacy policy (this "Privacy Policy") explains how personal information of our users (“Users”) is collected, used, stored, and disclosed by Piggytech Global Holdings Limited ("PiggyVest," "we," "us," and "our").
The provisions contained in this Privacy Policy supersede all previous notices and statements regarding our privacy practices with respect to our services.
Application of this Privacy Policy
This Privacy Policy serves to set out our approach to personal data, inclusive of personal data of our Users. This Privacy Policy applies to systems, operations and processes of PiggyVest that involve the collection, use, storage, and disclosure etc. of personal information of our Users.
This Privacy Policy applies to the use of our website at https://piggyvest.com, and all affiliated websites and applications owned and operated by us (collectively, the "Website"), applications, other online services and/or any related services, sales, marketing, promotional or events, and social media activities (together with the Website, our "Services"). Currently, this Website operates only in Nigeria, and is only available to users who have Nigerian bank accounts. For our Users, this Privacy Policy is part of our Terms of Use.
This Privacy Policy applies to your use of (regardless of means of access) our Services. You may access or use our Services through a desktop, laptop, mobile phone, tablet, or other consumer electronic device (each, a "Device"). This Privacy Policy also applies to your offline interactions with PiggyVest.
When you submit an inquiry to us via any means, register for a PiggyVest account, register to attend a PiggyVest event, interact with us on social media, partake in competitions and promotional activities and volunteer information to us; we may collect personal information from you, which may include your name, email address, mobile phone number, banking information, image and other information that identifies you (collectively, "Personal Information").
By accessing or using our Services, you agree to this Privacy Policy.
Guiding Principles PiggyVest is committed to maintaining the principles in the Nigerian Data Protection Regulation (NDPR) 2019, the Nigerian Data Protection Act (NDPA) 2023 and other applicable privacy and data protection laws regarding the processing of Personal Information. To demonstrate this commitment as well as our aim of creating a positive privacy culture within PiggyVest, PiggyVest adheres to the following basic principles relating to the processing of Personal Information: lawfulness, fairness and transparency; data accuracy; purpose limitation; data minimization; storage limitation; integrity and confidentiality; and accountability.
LAWFUL BASIS FOR USE OF YOUR PERSONAL INFORMATION
We may process your Personal Information under any of the bases provided below as recognised by data protection laws:
Consent
By using our Services, you consent to the terms of this Privacy Policy, as to allow us to utilise your data to serve you more accurately.
By accessing our Services and voluntarily providing us with the requested Personal Information, you consent to the collection and use of the information in accordance with this Privacy Policy. Your consent can be withdrawn at any time by sending a request to that effect to this e-mail: [email protected] or calling 0700 933 933 933. If you do not consent to the collection, use or disclosure of your Personal Information as outlined in this Privacy Policy, please do not provide any Personal Information to PiggyVest.
Contractual obligations We may process your Personal Information to fulfil our contractual obligations such as providing our Services to you or to take necessary actions at your request before providing our Services to you. This enables us to provide you with the Services you request. When you enter into a contract with us, such as subscribing to our Services, or engaging in a business agreement, we need to use your Personal Information to carry out our commitments. This includes processing information such as your name, contact details, payment information, and any other data necessary to deliver the agreed-upon Services or products. Without this data, we would be unable to complete transactions or manage our contractual relationship effectively.
Legal obligations We may also process your Personal Information to fulfil our legal obligations mandated by Nigerian law. This includes sharing financial information for tax reporting and accounting, and using employment data to comply with labour laws, payroll requirements, and health and safety regulations. We may also process Personal Information to adhere to legal requests, court orders, and regulatory requirements.
Legitimate Interest We may also process your Personal Information on the grounds of legitimate interest such as fraud investigation and prevention, to safeguard our IT systems, and for user-tailored marketing. We may process personal data on this basis as long as same is not in contravention of the other lawful bases, fundamental rights or freedoms of our users or where users would not have a reasonable expectation that the personal data would be processed in the manner envisaged.
Vital Interest We may process your Personal information if necessary to protect your vital interests or the interests of another natural person, where the data subject is physically or legally incapable of giving consent such as in the event of a claim for any amounts in the account of a deceased User by the User’s next-of-kin.
Public Interest We may process your Personal Information if necessary to perform an obligation in the public interest or by virtue of an official authority bestowed on us.
These lawful bases may be extended to cover any additional grounds for the processing of personal data as may be recognised by data protection laws in force from time to time.
INFORMATION WE COLLECT AND HOW WE COLLECT IT Information You Provide Us
In general, you can visit https://www.piggyvest.com without telling us who you are or revealing any information about yourself. As a User, we will also ask you to create login information for your PiggyVest account, such as a username and password. When you provide your mobile phone number, we may ask for your consent to receive text messages relating to our Services on that number. In general, we collect Personal Information you give us by filling out forms or by corresponding with us by phone, email, social media posts & messages, or otherwise.
By providing your Personal Information and any other kind of information or data to us, you expressly agree to our collection, use, storage, and disclosure of such information as described in this Privacy Policy. We may receive, use, store and transfer different kinds of Personal Information about you, including but not limited to the following: Identity Information: which includes your first name, last name, maiden name (where applicable), username or similar identifier, marital status, title, date of birth and gender.
Contact Information: which includes your billing address, delivery address, email address and telephone numbers.
Transaction Information: which includes details about your transactions.
Device Information: which includes information on the Devices with which you access the Website.
Profile Information: which includes your username and password, picture, transaction history, your interests, preferences, feedback and survey responses.
Usage Information: which includes details of your use of our Services. We may aggregate your usage information to calculate the percentage of Users accessing a specific Website feature.
Marketing and Communications Information: which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Location Information: which includes your current location disclosed by GPS technology or any other location territory.
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose.
Information About Your Transactions We collect Personal Information about your transactions with us and others. Information from Third Parties
We also collect Personal Information about you from other companies. For instance, we may receive Personal Information about you from a consumer reporting agency or we may collect Personal Information from your employer where your employer is providing a service to PiggyVest.
We may collect your Personal Information from a User where your Personal Information is filled in a Next-of-Kin form. Information Automatically Collected
We (or service providers acting on our behalf) may collect information about your use of our Services. This information may include Personal Information as well as statistical information that does not identify you ("Analytics"). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy. Information that we automatically collect in connection with your access or use of our Services may include: Device Information: We may collect Device-specific information (such as hardware model, operating system version, unique Device identifiers, and mobile network Information, including your mobile phone number). We may associate your Device identifiers or mobile phone number with your PiggyVest account. Log Information: We may record or log information from your Devices, their software, and your activity accessing or using our Services. This information may include: The Device's Internet Protocol ("IP") address Identification numbers associated with your Devices Device event information, such as crashes, system activity, and hardware settings Location preferences Date and time stamps of transactions System configuration information Other interactions with our Services Information Collected Through Cookies and Similar Technologies We use cookies to personalize our Services for you and to collect aggregate information about usage of our Services. A cookie is a text file or other local storage identifier provided by your browser or associated applications. We use cookies for record-keeping purposes and to enhance the quality of your use of our Services. The cookies assign random, unique numbers to your Devices to enable our systems to recognize your Devices and to allow us to see how you use our Services. Additional general information about cookies and how they work is available at www.allaboutcookies.org. The cookies we may use in connection with our Services include: Session cookies: Session cookies are temporary cookies that expire and are automatically erased whenever you close your browser window. We use session cookies to grant Users access to content and to enable actions they must be logged into their PiggyVest account to perform. Persistent cookies: Persistent cookies usually have an expiration date in the distant future and remain in your browser until they expire, or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve our Services. For example, we may use a persistent cookie to associate you with your PiggyVest account or to remember your choices for our Services. Third-party cookies: We permit certain third parties to place cookies through our Services to provide us with better insights into the use of our Services and user demographics and to advertise our Services to you. These third parties may collect information about your online activities over time and across different websites when you access or use our Services. For example, we utilize Google Analytics to analyse usage patterns for our Services. Google Analytics generates a cookie to capture information about your use of our Services, which Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify its cookie, but this will not be associated with any other data held by Google. We may also permit third-party service providers to place cookies for our Services, as indicated above, to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties. By accessing or using our Services, you consent to the placement of cookies on your Devices as described in this Privacy Policy. If you prefer not to receive cookies through our Services, you may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Unless you set your browser settings to refuse all cookies, our system may issue cookies when you access or use our Services. If you set your browser settings to refuse all cookies, the performance of certain features of our Services may be limited or not work at all.
Do-Not-Track Signals Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.
How We Use Information We may use Analytics as described above for research and commercial purposes to improve our Services. We may use Personal Information to fulfil and support our contractual obligations to you, to send important notices such as communications about our Services and changes to our terms, conditions, and policies, for our legitimate interests related to internal purposes such as auditing, data analysis, network and IT security, or to offer our products and services and products and services of third parties that we think you might find of interest and for other purposes contained in this Privacy Policy. Only PiggyVest and our third-party service providers involved in distributing the offers or providing the products or services will have access to your Personal Information. Our third-party service providers will only be permitted to use Personal Information for the clearly intended purpose. We may use your email address to respond to your inquiries and to provide information about our Services. You may elect not to receive promotional emails from us either by "unsubscribing" to an email you receive from us or by contacting us as indicated below. As a User, if you unsubscribe from receiving emails from us, we may still send you non-promotional emails, such as emails about your PiggyVest account or our ongoing business relations, unless you withdraw your consent to receive electronic communications as provided in our Terms of Use.
How We Share Information You agree that we can share your Personal Information, and other information that you share with us: if you request or authorise it;
if the information is provided to help complete a transaction for you;
with any of our affiliated companies and service providers;
with financial service providers, including the financial institutions identified in your cardholder bank agreement that provide banking services in connection with your PiggyVest account;
with another User, when you sign up for our Services via a referral link. The User that referred you may receive information indicating that you have enrolled with us;
with non-financial companies, such as email service providers that perform marketing services on our behalf, and fraud prevention service providers that use the information to provide services to us;
with a non-affiliated third-party to access and transmit your personal and financial information from a relevant institution. You grant the third-party the right, power, and authority to access and transmit this information according to terms of their privacy policy;
with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or alternatively, acquire all or parts of their businesses;
in response to a request for information, if we are required by, or we believe disclosure is in accordance with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas or legal process;
for our everyday business purposes;
for publication of our events and competitions on digital and print media;
protect our rights, property, or safety or the rights, property, or safety of our Users or others; or
with relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud.
We do not share your Personal Information with: (1) other companies for joint marketing purposes without your consent; or (2) any other third parties so they can market to you.
If you provide us with bank account or debit card information, or any other payment information, through our Services, we may share that information with third-party payment processors and other third-party service providers, solely to the extent necessary to provide you with the relevant Services.
When you are no longer our User, we may continue to share your information as described in this Privacy Policy as permitted by applicable laws.
We may disclose Analytics with third parties for our commercial purposes.
Opt-Out Rights If you do not wish to receive offers or other notices from us in the future, you can "opt out" by contacting us as indicated at the end of this Privacy Policy or by following the "unsubscribe" instructions in any communication you receive from us. Please be aware that if you are a User, you are not able to opt out of receiving communications about your PiggyVest account or related transactions with us.
Other Rights to Your Personal Information with Us Beyond your right to opt out of our processing Personal Information, you also have the option of exercising any of the below rights with respect to your Personal Information:
Right to request Correction to your Personal Information We respect your wishes to correct inaccurate information and as such you must notify us of any change in your Personal Information. If you are a User, you can change some of your Personal Information by updating your PiggyVest account profile through our Services. Changes to financial details will require you to contact us directly. If you are not a User, you can contact us as indicated at the end of this Privacy Policy to make any changes or request on Personal Information we hold about you. Any changes will affect only future uses of your Personal Information and we may need to verify the accuracy of the new data you provide to us.
Right to request Access to your Personal Information You can ask us whether we are storing your Personal Information, and you can ask to receive a copy of that Personal Information. Before sending you any Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information we hold about you.
Right to data portability In certain circumstances you can request to receive a copy of your Personal Information in a commonly used electronic format. This right only applies to Personal Information that you have provided to us (for example by completing a form or providing information through our Website). Information about you which has been gathered by monitoring your digital behaviour will also be subject to the right to data portability. The right to data portability only applies if the processing is based on your consent or if the Personal Information must be processed for the performance of a contract and the processing is carried out by automated means (i.e., electronically).
Right to request us to refrain from doing certain things with your data or restrict the extent of our collection or processing of your data. You may object to the processing of your Personal Information where you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right to request partial or complete erasure of your Personal Information. You may request for us to delete or remove Personal Information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note however that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to request the transfer of your Personal Information to another party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to lodge a complaint with the Commission If you believe that the processing of your Personal Information violates data protection law, you also have the right to complain to the Nigeria Data Protection Commission (“Commission”) website via the link: https://services.ndpc.gov.ng/breach/.
Right to withdraw consent Where we are relying on consent to process your Personal Information, you may withdraw your consent to the processing of Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you. We may advise you if this is the case at the time you withdraw your consent.
Right to object to decisions taken by automated means You have the right to object to decisions made solely based on automated processing of personal data, including profiling, that may have a legal effect on you. This means where the decision impacts your legal right i.e. freedom from discrimination or similarly significant effects. However, this right is not absolute where we have your consent, the decision is necessary for entering into or performing a contract with us, where there are appropriate safeguards for your rights.
We would implement appropriate measures to protect your rights and interests. These measures include ensuring you can obtain human intervention in the decision-making process, express your views, and contest the decision.
Information You Share Socially Our Services may allow you to connect and share your actions, comments, content, and information publicly or with friends. We are not responsible for maintaining the confidentiality of any information you share publicly or with friends. Our Services may also allow you to connect with us on, share on, and use third-party websites, applications, and services. Please be mindful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those sites and services directly if you want to learn about their privacy practices.
Security and Storage of your Personal Information We have suitable security measures in place to prevent your Personal Information from being accidentally lost or used or accessed in an unauthorised way by a third party. When your bank account information is transmitted via our Services, it will be protected by encryption technology, such as Secure Sockets Layer (SSL). In addition, we limit access to your Personal Information to those employees, employers, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We have, and require our third-party service providers that receive Personal Information from us to have, a comprehensive written information security program that contains administrative, technical, and physical safeguards for our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, or alteration
No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your email address, username and password for your PiggyVest account and do not share them with others.
If we receive instructions using your PiggyVest account login information or other PiggyVest account security information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your PiggyVest account or any other breach of security. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate PiggyVest accounts, and to remove or edit content.
Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.
Protecting Children's Privacy Our Services are not directed, or intended to be attractive, to children under the age of eighteen (18). We do not knowingly collect Personal Information from children under the age of eighteen (18). If you are under the age of eighteen (18), do not use our Services or submit any information to us.
Links to Third-Party Websites When you use our Services, you may be directed to other websites that are beyond our control. We may also allow third-party websites or applications to link to our Services. We are not responsible for the privacy practices of any third parties or the content of linked websites, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties and websites. This Privacy Policy only applies to our Services.
Data security and retention We deploy strict physical, electronic, and administrative security measures to protect your information from access by unauthorised persons, against unlawful processing and foreseeable hazards and breaches when online.
We generally retain your Personal Information for as long as is necessary for the purposes we collected it and also to give you better service. To this end, we are committed to maintaining the confidentiality of the Personal Information.
To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, and the applicable legal requirements.
By accessing this Website and any of its pages you are agreeing to the terms set out above. You may also request to have all your Personal Information deleted entirely. Please note that if you request the erasure of your Personal Information, we may retain and use your Personal Information to the extent necessary to comply with our legal obligations, including but not limited to tax, legal reporting and auditing obligations.
If you would like to know more about the retention periods we apply to your Personal Information, please contact us at [email protected] or 0700 933 933 933.
Changes to our Privacy Policy Subject to applicable law, we may revise this Privacy Policy at any time and in our sole discretion. When we revise this Privacy Policy, we will post the revised version via our Services and will update the date at the top of this Privacy Policy. The revised Privacy Policy will be effective upon posting via our Services, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing or using our Services. If you do not agree to the terms of this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access and use of our Services. Except as otherwise expressly stated by us, your access and use of our Services is subject to the version of this Privacy Policy in effect at the time of access or use.
How can I contact PiggyVest? If you have any questions, comments, or concerns with respect to your Personal Information or this Privacy Policy please contact us at [email protected] or 0700 933 933 933.