Privacy Policy

1Introduction

This Privacy Policy describes your privacy rights regarding Vendex Platforms Limited's ("we", "the Company", "us", or "our") collection, use, storage, sharing, and protection of your personal information. It applies to our platform, website, and all related sites, applications, services, and tools ("Services") regardless of how you access or use them.

This Privacy Policy applies to all forms of systems, operations, and processes within our environment that involve the collection, storage, use, transmission, and disposal of Personal Information. It is provided to help you understand what information we collect, how it is used, how we protect it, and your rights in relation to it.

2Information We Collect

As part of our operations, we collect and process certain types of information about individuals including current, past, and prospective employees, merchants, suppliers, customers of merchants, registered users ("Users"), and others we communicate with ("Data Subjects").

To use our Services, you will voluntarily provide us with certain Personal Information — information relating to an identified person, or information that can be used to identify you, including anonymous information that may be linked to you (e.g. IP address).

We may collect the following from you:

• Name, username, gender, and date of birth.
• Email address, postal address, and telephone number.
• Your interests and preferences.
• Any other information necessary for the Services.

How we use your personal information:

• Administering your account and processing orders or applications.
• Sending information about our products and services.
• Carrying out marketing analysis and improving our platform.
• Responding to your inquiries and fulfilling your requests.
• Informing you about changes to terms, conditions, and policies.
• Delivering marketing communications tailored to you.
• Verifying your identity and location to prevent fraud and protect your account.
• Evaluating your eligibility for products or services.
• Conducting data analysis, audits, and improving products and services.
• Risk control, fraud detection and prevention, and compliance with laws and regulations.
• Granting access to device features (e.g. contact lists, geo-location) when you request certain services.

3Platform Visitors

We do not collect any unauthorized Personal Information when you visit our website or platform, except for the purpose for which you have given your consent. Any Personal Information collected for the purpose of carrying out the Services will be done with your explicit consent and used only for the stated purpose.

However, to monitor and improve our platform and Services, we may collect non-personally-identifiable information. We will not share this with third parties except as necessary to provide our Services. Where applicable, we may use this information to target advertisements to you.

4Purpose Limitation

We collect Personal Information only for identified purposes for which consent has been obtained. Such information cannot be reused for another purpose that is incompatible with the original purpose, unless consent is obtained for the new purpose.

5Data Processing Principles

Your personal data will be:

• Collected and processed in accordance with specific, legitimate, and lawful purposes consented to by you.
• Adequate, accurate, and without prejudice to the dignity of the human person.
• Stored only for the period within which it is reasonably needed.
• Secured against all foreseeable hazards and breaches, including theft, cyberattack, viral attack, dissemination, manipulation, and physical damage.

6Data Minimization

We limit Personal Information collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the stated purpose. We evaluate whether and to what extent processing is necessary, and where the purpose allows, anonymized data will be used.

7Cookies

We use cookies to identify you as a User, customize our Services, content, and advertising, help ensure your account security is not compromised, mitigate risk, prevent fraud, and promote trust and safety on our website. Cookies allow our servers to remember IP addresses, date and time of visits, monitor web traffic, and prevent fraudulent activities.

Our cookies never store personal or sensitive information. They hold a unique random reference to you so that once you visit our website, we can recognize who you are and provide certain content to you.

8Automatically Collected Data

We and our third-party service providers may collect and use other information, including:

• Log files / IP addresses: When you visit the platform, our web server automatically records your IP address. This is not linked to your personal information and is used to administer the platform and collect demographic data for aggregation purposes.
• Pixel tags, web beacons, and clear gifs: Used in connection with site pages, mobile applications, and HTML-formatted emails to measure the effectiveness of communications and marketing campaigns, personalize your experience, detect fraud, and assist with account-related questions.
• Browser and device data: MAC address, device type, screen resolution, operating system version, and browser type and version — used to ensure the platform functions properly and for fraud prevention and security purposes.
• Aggregated and de-identified data: Compiled from various sources including accounts and transactions, used for business purposes such as offering products or services, research, and market analysis.

9How We Use Your Data

We use the information we collect to operate, improve, and develop our Services; verify your identity and the identities of other members of your company; bill for our Services; transmit payment; and comply with law, including for tax reporting purposes.

We also use your information to personalize your Service experience, communicate with you about products, services, offers, and events, and to monitor and analyze trends, usage, and activities. Your data is also used to detect and prevent fraud, malicious activity, and other illegal activities.

10How We Share Your Data

We do not sell, trade, or rent personal information to anyone. To enable us to render our Services, we may share your information with trusted third parties such as financial institutions, payment processors, verification services, sanctions screening and identity verification services, and any third parties you have directly authorized to receive your Personal Information.

We may disclose your Personal Information in compliance with applicable law or a legal obligation. We may share with law enforcement agencies, public authorities, or other organizations if legally required or if we have good faith belief that such disclosure is reasonably necessary to:

• Comply with a legal obligation, process, or request including tax and related reporting requirements.
• Enforce our Terms of Service and other agreements, policies, and standards.
• Detect, prevent, or address security, fraud, or technical issues.
• Protect the rights, property, or safety of us, our users, a third party, or the public.

11Transfer of Personal Information

Third-party processors within Nigeria

We may engage third parties to process Personal Information we collect. Any such processing will be governed by a written contract with us to ensure adequate protection and security measures are in place.

Transfer outside Nigeria

Where Personal Information is to be transferred to a country outside Nigeria, we will put adequate measures in place to ensure its security. We will confirm whether the destination country is on the Nigeria Data Protection Commission ("NDPC") White List of Countries with adequate data protection laws.

Transfer outside Nigeria will be in accordance with the Nigeria Data Protection Act 2023 ("NDPA") and other applicable data protection laws. We will only transfer Personal Information out of Nigeria where:

• The consent of the Data Subject has been obtained.
• The transfer is necessary for the performance of a contract between us and the Data Subject.
• The transfer is necessary to conclude a contract in the interest of the Data Subject.
• The transfer is necessary for reasons of public interest.
• The transfer is for the establishment, exercise, or defense of legal claims.
• The transfer is necessary to protect the vital interests of the Data Subject or other persons where the Data Subject cannot give consent.

12Lawful Basis for Processing

We will only use and process your personal data as permitted by the NDPA. We may rely on the following legal bases:

• Processing necessary for the pursuit of legitimate purposes by us, a data processor, or a third party to whom data is disclosed.
• Where you have given consent to processing for one or more specific purposes.
• Where processing is necessary for the performance of a contract to which you are a party.
• Where processing is necessary for compliance with a legal obligation to which we are subject.
• Where processing is necessary to protect your vital interests or the vital interests of another natural person.
• Where processing is necessary for a task carried out in the public interest or in exercise of an official public mandate.

13Advertising

From time to time, we may send you information about financial products and services offered by the Company that we think may be of interest to you. We advertise online (on our own sites and on third-party sites and mobile apps) and offline.

We collect certain information through advertising service providers using cookies, IP addresses, and other technologies to understand how our advertising performs. The collected information may include page visits, search engine referrals, browsing activities over time, and responses to advertisements.

We use this information to present tailored ads, analyze the effectiveness of our ads, and determine whether you might be interested in new products or services.

14Your Rights

Once your Personal Information is held by us, you are entitled to exercise the following rights:

15Age Restriction

Our Services are not directed to children under 18. We do not knowingly collect information from children under 18. If you access our platform and are below 18, you represent that you have obtained consent from your parent(s) or legal guardian(s).

If you have inadvertently provided personal data of a child to us, or if as a parent or guardian you become aware that your child has provided information without your consent, please notify us at hello@vendex.africa and we will delete such data.

16Regulatory Compliance

We comply with the Nigeria Data Protection Act 2023 ("NDPA") and the Nigeria Data Protection Regulation 2019 ("NDPR") on data collection, transmission, usage, and protection. We also adopt pertinent best practices from the General Data Protection Regulation (GDPR) to the extent that they do not conflict with Nigerian data protection regulations and laws.

17Changes to This Policy

We reserve the right to update, modify, change, or revise this Privacy Policy from time to time — for example due to a change in law or to comply with new best practices. Changes will not be retroactive. The most current version will always be on this page.

We will notify you of any material changes via email associated with your account or through a service notification. By continuing to use our Services after changes become effective, you agree to be bound by the revised Policy.

18Complaints & Remedies

You may file a complaint if you believe any provision of this Privacy Policy or your privacy rights have been violated. All complaints must be addressed to our Data Protection Officer. We will notify you of any breach and also notify the NDPC within 72 hours of becoming aware of such a breach.

You may also seek redress in a court of competent jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the data protection authorities.

19Contact & Enquiries

For questions, comments, or requests relating to this Privacy Policy, or to exercise your data protection rights, please contact us: