TradEX is a product powered by Patiti Consulting in conjunction with Afrixem Bank and AKU and we leverage technology to develop digital products that drive e-commerce across the globe. We are committed to safeguarding the safety and privacy of users of our services. To ensure your continuous support and trust in the use of TradEX, we insist on the highest standards of practice in customer information privacy and protection. This Privacy Statement “Statement” and Cookie Notice contains your privacy rights and provides information on how TradEX collects and processes your personal data when access/use our services and e-commerce platform (collectively referred to as TradEX) either through web or mobile device. This Privacy Statement and Cookie Notice is subject to change at any at and changes may be made without any direct notice to you therefore you are encouraged to review this policy periodically to be up to date on any changes that may occur. TradEX Services are not intended for use by minors, and we do not collect process information from users under the age of 18. Please discontinue the use of our services if you fall within this category.

1. What is the purpose and scope of this statement?

The purpose of this Statement is to inform you about how we collect, use, store, make available, disclose, update, safeguard, destroy or otherwise deal with (process) your personal information (also referred to as personal information in some countries) and also to explain your rights relating to the privacy of your personal information and how the law protects you. We may use your information for any of the purposes set out in this statement where we have lawful grounds for doing so. Your personal information may be processed in another country that does not provide you with the same data protection that the country of origin does, but we will only process or transfer personal information to countries where recipients are bound by code, law, contracts, or corporate rules which would provide an adequate level of protection of personal information.

It is your responsibility to review this Agreement frequently and to stay informed of all changes which may be made to it. By using our services after a revision has been made to this Agreement, you consent to be bound by the changes we made.

However, in the absence of adequate protection, your personal information could still be transferred in cases where:

1. Your consent has been obtained despite being informed of the possible risks.
2. It is necessary for the performance of a contract which you are a party to or needed to act in accordance with your request prior to entering a contract.
3. It is for your sole benefit, and it is not reasonably practicable to obtain your consent for the transfer, but if it were, you would likely approve
4. It is necessary for important reasons of public interest.
5. It is necessary for the establishment, exercise, or defense of legal claims.
6. It is necessary to protect your vital interests or those of other people, where you are physically or legally incapable of giving consent.

Protecting the privacy, confidentiality and security of your personal information is very important to us as it is critical for us to maintain your trust and act in the right way to meet your needs. We have therefore implemented this Statement to ensure that your personal information is protected.

2. What is personal information and what types of personal information do we collect?

The personal data we collect includes information you provide for us, your identity data, contact data, biometric data, delivery address and financial data. These types of personal data may include:

1. Contact details (such as your name, postal addresses, phone numbers, and email addresses).
2. Demographic information (such as your date of birth, age or age range, and gender).
3. Online registration information (such as your password and other authentication information).
4. Payment information (such as your ATM card information and billing address).
5. information provided as part of online questionnaires (such as responses to any customer satisfaction surveys or market research),
6. Competition entries/submissions.

3. Information we automatically collect/generate or obtain from third parties:

Information we automatically collect/generate or obtain from third parties: We automatically collect and store certain types of information regarding your use of our platform including information about your searches, views, downloads and purchases. In addition, we may receive information about you from third parties including our carriers; payment service providers; merchants/brands; and advertising service providers. These types of personal data may relate to your device (such as your PC, tablet or other mobile device), your use of our websites and apps (as well as certain third-party websites with whom we have partnered), and/or your personal preferences, interests, or geographic location. Examples of these types of information include:

1. Name and age (or predicted age range).
2. Information about your device, operating system, browser, and IP address.
3. Unique identifiers associated with your device.
4. Details of web pages that you have visited.
5. which products you have looked at online (including information about products you have searched for or viewed, purchased or added to an online shopping basket),
6. how long you spend on certain areas of a website or app together with the date and time of your visit/usage,
7. Personal data contained within user-generated content (such as blogs and social media postings), social media username or ID, and social media profile photo and other social media profile information (such as number of followers).

Cookies and How We Use Them

Cookies allow us to distinguish you from other users of our services. This helps us to provide you with enhanced user experience. For example, we use cookies for the following purposes:

1. Recognizing and counting the number of users and how these users move around the site.
2. Identifying your preferences,
3. Sending you newsletters and commercial/advertising messages tailored to your interests.

Our approved third parties may also set cookies when you use our services. Third parties include search engines, providers of measurement and analytics services, social media networks and advertising companies.

5. How We Use Your Personal Data

We use your personal data to operate, provide, develop and improve the products and services that we offer, including the following:

1. Registering you as a new User/Merchant
2. Provide our TradEX Services to you
3. Managing your relationship with us.
4. Enabling you to participate in promotions, competitions and surveys.
5. Improving our website, applications, products and services
6. Recommending/advertising products or services which may be of interest to you.
7. Complying with our legal obligations, including verifying your identity where necessary.
8. Detecting fraud.

Lawful basis we rely on for processing your personal data include;

1. Your consent has been given for using our Services
2. Processing your information is required for us to deliver our TradEX Services to you in accordance with our Terms of Use and this Privacy Statement
3. Processing your information is required to enable us to remain compliant with applicable Laws and Regulatory Requirements.

6. How We Share Your Personal Data

We may need to share your personal data with third parties for the following purposes:

1. Provision of TradEX Services: In order process your transactions, we may be required to provide your personal data to third parties. We may share your contact information with merchants as part of your purchase details for record purposes.
2. Working with third party service providers: We engage third parties to perform certain functions on our behalf. Examples include analyzing data, providing marketing assistance, processing payments, transmitting content, assessing and managing risk, and providing customer service.
3. Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, customer information may be transferred together with other business assets
4. Detecting fraud and abuse: We release account and other personal data to other companies and organizations for fraud protection and credit risk reduction, and to comply with any applicable law.

When we share your personal data with third parties, we require them to agree to use your data in accordance with the terms of this Privacy Statement and Cookie Notice, our Privacy Policy and in accordance with the law; and only permit them to process your personal data for specified purposes and in accordance with our instructions. We do not allow our third-party service providers to use your personal data for purposes other than those contained in this Statement not for their personal use.

7. International Transfers

We may transfer your personal data to locations in another country, if this is permissible pursuant to applicable laws in your location. There are, however, inherent risks in such transfers. In the event of international transfers of your personal data, we shall put in place measures necessary to protect your data, and we shall continue to respect your legal rights pursuant to the terms of this Privacy and Cookie Notice and applicable laws in your location.

8. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized manner, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties strictly on a need-to-know basis. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. 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.

In compliance with the Payment Card Industry Data Security Standard (PCI DSS Requirements), we implement access control measures, security protocols and standards including the use of encryption and firewall technologies to ensure your card information is safe and secure in our servers, additionally, we implement periodical security updates to ensure that our security infrastructures follow reasonable industry standards

We have also appointed Data Protection Officers to ensure compliance with the Nigerian Data Protection Regulation (NDPR).

9. Data Retention

We will take every reasonable step to ensure that your personal data is processed for the minimum period necessary for the purposes set out in this Statement. Your personal information may be retained in a form that allows for identification only for as long as:

1. We maintain an ongoing relationship with you. This will enable us to improve your experience with us and to ensure that you receive communications from us.
2. Your personal information is necessary in connection with the purposes set out in this Statement and we have a valid legal basis.
3. The duration of:
   1. any applicable limitation period (i.e., any period during which a person could bring a legal claim against us).
   2. We will actively review the personal data we hold and delete it securely, or in some cases anonymize it, when there is no longer a legal, business, or consumer need for it to be retained

10. Your Legal Rights

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to access, correct or erase your personal data, object to or restrict processing of your personal data, and unsubscribe from our emails and newsletters.

11. Changes and Updates to this Privacy policy

This Privacy Statement may be subject to modifications and amendments as the need arises. All amended versions will be posted on our website and all other platforms; therefore, you are encouraged to review this policy periodically to be up to date on any changes. Updated policies take effect from the date they are posted and by continuing to use our TradEX Services, you expressly consent to any amendments of this Statement.

12. Further Details

If you are looking for more information on how we process your personal data, or you wish to exercise your legal rights in respect of your personal data, please contact us atcontactus@tradex.africa