Updated february 13, 2021
This is the Privacy Statement of Mainline Digitech Innovations Limited, a company incorporated in Nigeria,
whose registered number is 1577301, with a registered office located at 15, Ramat Cresent Ogudu GRA, Lagos
Nigeria. It applies to all subsidiaries and branches of IdentityPass to the extent that they process
personal data. IdentityPass is supervised by the National Information Technology Development Agency of
Nigeria.
IdentityPass treats personal data which it receives through its websites, portals and any other means
with
due care and is dedicated to safeguarding any personal data it receives. IdentityPass is bound
by Nigerian Data Protection Regulation. This
Privacy Statement is designed to inform you about the type of information that Identitypass collects
when
using our website and our application and the purposes for which this information is being processed,
used,
maintained and disclosed (together the “Services”).
This Privacy Statement aims to explain in a simple and transparent way what personal data we gather about
you
and how we process it. It applies to the following persons:
● The legal representatives and ultimate beneficial owners of all past, present and prospective commercial
contracting parties. We are legally obliged to retain personal data of these persons, also for a certain
period after the relationship has ended, in compliance with ‘know your customer’ (“KYC”) regulations.
● Anyone visiting the Identitypass website. We may amend this Privacy Statement to remain compliant with
any changes in law and/or to reflect how our business processes personal data.
Personal data refers to any information that tells us something about you or that we can link to you.
IdentityPass processes any information we receive from you, including personal and financial information
you
provide to us including when you or your business: enquire or make an application for Identitypass’s
services, register to use and/or use any of our services and when you communicate with us through e-mail,
SMS,
WhatsApp, a website or portal, telephone or any other electronic means. Such information may include your:
name including first name and family name, nationality, place of birth, date of birth, street name, street
number, street number suffix, postal code, city, country of residence, phone number, e-mail address,
gender,
photograph,
document type, ID document (picture), document number, issue date, expiration date, geolocation and a
selfie.
Identitypass processes your personal data in accordance with the NDPR in the event at least one of the
following applies:
● The data subject has given consent to the processing of his or her personal data for one or more specific
purposes (NDPR). In the event you give your consent to the processing of your personal data for specific
purposes, the processing is permitted on the legal basis of your consent, which consent is revocable at
any
time.
● Personal data is processed to conduct financial or KYC services in order to fulfil our contractual
and
pre-contractual obligations. These actions are only taken when requested by you.
● Processing is
necessary
for the purposes of the legitimate interests pursued by the controller 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, in particular where the data subject is a child. In we deem it
is
necessary, we will process your personal data beyond our contractual obligations in order to protect our
legitimate interests or the legitimate interests of a third party. By processing we mean everything we can
do
with this data such as collecting, recording, storing, adjusting, organising, using, disclosing,
transferring
or deleting.
● You share personal information with us, for example when you: visit our website, complete
a(n)
(online) (application) form, sign a contract or contact us through one of our channels. We also use data
that
is legally available from public sources such as commercial registers, the media, or data that is
legitimately
provided by other companies within the Identitypass Group or by third parties.
We do not record sensitive data relating to your health, ethnicity, religious or political beliefs unless it is strictly necessary. When we do it is limited to specific circumstances.
We only use your personal data for legitimate business reasons. This includes:
Administration
When you provide us with information by filling in a form on our website or through the application we are
legally obliged to collect
personal data that verifies your identity (such as a copy of your ID card or passport) and to assess
whether we
can accept you or your company as a customer. We also need to know your address or phone number to contact
you.
Managing customer relationships
We may ask you for feedback about our products and services and share this with certain members of our
staff to
improve our offering. We might also use notes from conversations we have with you online, by telephone or
in-person to customise products and services for you.
Providing you with the best-suited products and services
When you visit our website, call our customer service centre or visit a branch we gather information about
you.
We analyse this information to identify your potential needs and assess the suitability of products or
services. We assess your needs in relation to key moments when a specific financial product or service may
be
relevant for you. We assess your interests based on simulations you participate in on our website.
Improving and developing products and services
Analysing how you use our products and services helps us understand more about you and shows us where we
can
improve. For instance, we analyse the results of our marketing activities to measure their effectiveness
and
the relevance of our campaigns.
Preventing and detecting fraud and data security
We have a duty to protect your personal data and to prevent, detect and contain data breaches. This
includes
information we are obliged to collect about you, for example, to comply with regulations against money
laundering, terrorism financing and tax fraud.
● We may process your personal information to protect you and your assets from fraudulent activities, for
example, if you are the victim of identity theft, if your personal data was disclosed or if you have been
hacked.
● We may use certain information about you for profiling (e.g. name, account number, age,
nationality,
IP address, etc.) to quickly and efficiently detect a particular crime and the person behind it.
Internal and external reporting
We process your data for our operations and to help our management make better decisions about our
operations
and services. To comply with a range of legal obligations and statutory requirements (anti-money
laundering
legislation and tax legislation, for example). The personal information we have collected from you will be
shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify
your
identity. If fraud is detected, you could be refused certain services, finance, or employment Data that we
process for any other reason is anonymised or we remove as much of the personal information as possible.
Whenever we share personal data internally or with third parties in other countries, we ensure the
necessary
safeguards are in place to protect it.
To be able to offer you the best possible services and remain competitive in our business, we share certain
data both internally as well as outside of the Identitypass Group. This includes:
Identitypass entities
We transfer data across Identitypass businesses and branches for operational, regulatory or reporting
purposes. We may also transfer data to centralised storage systems or to process it globally for more
efficiency.
Government authorities
To comply with our regulatory obligations, we may disclose data to the relevant authorities, for example to
counter terrorism and
prevent money laundering. In some cases, we are obliged by law to share your data with external parties,
including:
● Public authorities, regulators and supervisory bodies such as fraud protection agencies and the central
banks
of the countries where we operate.
● Judicial/investigative authorities such as the police, public
prosecutors, courts and arbitration/mediation bodies on their express and legal request.
● Lawyers, for
example, in case of a claim or bankruptcy, trustees who take care of other parties’ interests and company
auditors.
Third-party service providers
When we use other service providers we only share personal data that is required for the particular task we
involve the service provider for. Service providers support us with activities like:
● Performing certain services and operations.
● Designing and maintenance of internet-based tools and
applications.
● Marketing activities or events and managing customer communications.
● Preparing reports
and
statistics, printing materials and designing products.
● Placing advertisements on apps, websites and
social
media.
Business transfers
The Mainline Digitech Innovations Limited may buy or sell business units or affiliates. In such
circumstances,
we may transfer customer information as a business asset. Without limiting the foregoing, if our business
enters into a joint venture with or is sold to or merged with another business entity, your information
may be
disclosed to our new business partners or owners.
With your permission
Your information may also be used for other purposes for which you give your specific permission, or when
required by law or where permitted under the terms of the laws of the relevant jurisdiction.
Identitypass makes use of cookies and similar technologies throughout our websites to ensure your visit
to
our website goes smoothly. Our websites (and some emails) use “cookies” and other technologies, which
store
small amounts of information on your computer or device, to allow certain information from your web
browser to
be collected. Cookies (and similar technologies) are widely used on the internet and allow a website/portal
to
recognise a user’s device, without uniquely identifying the individual person using the computer. These
technologies help to make it easier for you to log on and use our websites and provide information to us,
for
example which parts of the website you visit. For more information about cookies, including how to see
what
cookies have been set and how to manage, block and/or delete them, please refer to the below information
about
our Cookie Policy.
Cookies
Identitypass may use cookies or similar techniques whenever you interact with this website.
What are cookies?
Many of the websites you view place small text files on your computer. This enables the site to recognize
your
computer each time you visit. We call these text files ‘cookies’. A cookie is sent by a web server to a
web
browser that enables the server to collect information back from the browser.
Which cookies are used and what do they do?
This website uses the following cookies:
1. Functional cookies
These cookies may store your browser name, the type of computer and technical information about your means
of
connection to this website, such as the operating system and the Internet Service Providers utilized and
other
similar information. This information is used to technically facilitate the navigation and use of this
website. In addition, functional cookies may be used to store personal settings, such as language, or to
remember your information for next visits if so requested.
2. Third-party/social media cookies
This website contains cookies from third-party websites, mainly social media cookies. When placed on your
computer, they automatically activate handy extras, for example, a Facebook ‘like’ button or a Twitter
messaging option. These cookies inform our
website whether you are logged into such social media and they also enable you to share parts of this
website
on social media. When visiting this website, Identitypass will ask for your consent to use these
cookies.
3. Do you object to cookies?
Cookies generally process your IP-address, but they do not save your personal information like e-mail
address
or phone number. If you do not want to have cookies stored on your computer or want to remove cookies that
have already been stored, you can arrange this via your browser settings. You can find more information
concerning the removal of cookies on the website all about cookies.
We respect your rights as a customer to determine how your personal information is used. These rights
include:
Right to access information
You have the right to ask us for an overview of your personal data that we process.
Right to rectification
If your personal data is incorrect, you have the right ask us to rectify it. If we shared data about you
with a
third party that is later corrected, we will also notify that party.
Right to object to processing
You can object to Identitypass using your personal data for its own legitimate interests. There is a
list of
contact details at the end of this Privacy Statement. We will consider your objection and whether
processing
your information has any undue impact on you that requires us to stop doing so.
You can also object to receiving personalised commercial messages from us. You cannot object to us
processing
your personal data if we are legally required to do so, even if you have opted out of receiving
personalised
commercial messages.
Right to object to automated decisions
We sometimes use systems to make automated decisions based on your personal information if this is
necessary to
fulfil a contract with you, or if you gave us consent to do so. You have the right to object to such
automated
decisions (for example requiring a new
passport copy if the one we have on file for you as representative of your company is no longer valid) and
ask
for an actual person to make the decision instead.
Right to restrict processing
You have the right to ask us to restrict using your personal data if:
● You believe the information is inaccurate.
● We are processing the data unlawfully.
● Identitypass no
longer needs the data, but you want us to keep it for use in a legal claim.
● You have objected to us
processing your data for our own legitimate interests.
Right to data portability
You have the right to ask us to transfer your personal data directly to you or to another company. This
applies
to personal data we process by automated means and with your consent or on the basis of a contract with
you.
Where technically feasible, we will transfer your personal data.
Right to erasure
You may ask us to erase your personal data if:
● We no longer need it for its original purpose.
● You withdraw your consent for processing it.
● You
object
to us processing your data for our own legitimate interests or for personalised commercial messages.
● Identitypass unlawfully processes your personal data.
Right to complain
Should you for any reason be unhappy with the way IdentityPass treats your personal data, you can file a
complaint with IdentityPass’s Compliance Officer via team@myidentitypass.com You can also contact the
data
protection authority in your country.
Exercising your rights
How you can exercise your rights depends on the type personal data Identitypass processes. It could be
through our website, by fulfilling our KYC obligations or by processing a transaction. We aim to respond
to
your request as quickly as possible. In certain
cases, we may deny your request. If it’s legally permitted, we will let you know within a reasonable
timeframe
why we denied it. If you want to exercise your rights or submit a complaint, please contact us via the
e-mail
address provided below.
There is certain information that we must know about you so that we can commence and execute our duties as a verification institution and fulfil our associated obligations. There is also information that we are legally obliged to collect. Without this data we may for example not be able to enter into an agreement with you.
We apply an internal framework of policies and minimum standards to keep your data safe. These policies and standards are periodically updated to keep them up to date with regulations and market developments. More specifically and in accordance with the law, we take appropriate technical and organisational measures (policies and procedures, IT security etc.) to ensure the confidentiality and integrity of your personal data and the way it’s processed. In addition, Identitypass employees are subject to confidentiality and may not disclose your personal data unlawfully or unnecessarily.
Unfortunately, the transmission of information via the internet, in general, is not always completely
secure.
Although we will do our
best to protect your personal information, we cannot guarantee the security of your information transmitted
to
our site; any transmission is at your own risk. Once we have received your information, we will use strict
procedures and security features to try to prevent unauthorised access. We do our utmost to protect your
data,
but there are certain things you can do too:
● Install anti-virus software, anti-spyware software and a firewall on your computer and keep them
updated.
●
Do not leave verification tokens or your credit card) unattended.
● Keep your passwords strictly
confidential
and use strong passwords, i.e. avoid obvious combinations of letters and figures.
● Be alert online and
learn
how to spot unusual activity, such as a new website address or phishing emails requesting personal
information.
Identitypass will store and process your personal data only as long as it is necessary to perform our obligations under the agreement with you or as long as the law requires to store it. Therefore, we keep your personal data as long as you are using our Services and for five (5) years after termination of the agreement to comply with the law. There may be circumstances (e.g. fraud or anti-money laundering) whereby we are obliged to store your personal data even longer.
If you want to know more about Identitypass’s data policies and how we use your personal data, you can send us an e-mail at the following dedicated e-mail address: Team@myidentitypass.com