Privacy Policy
Document Ammended June 2023
TABLE OF CONTENT:
Introduction
QorePay Technology Solutions Limited, referred to as "QorePay," "Company," "we," "us," or "our," provides digital payment solutions platform and and support service. Our services enable businesses to make or collect payment conveniently online and at physical retail locations. This Privacy and Cookie Policy ("Privacy Policy") outlines how we collect, use, store, disclose, transmit, erase, and safeguard your data and personal information as Website Visitors, Customers, and/or Vendors ("Data Owners") who engage with our services. This Privacy Policy applies to our website, related sites, applications, POS Terminals, services, and tools collectively referred to as "Services."
QorePay Services primarily target and serve businesses and organizations ("Subscribers") rather than individual consumers. We generally process personal data on behalf of Subscribers as a service provider or "Data Processor." However, we do not control or assume responsibility for the privacy practices of these Subscribers. If you are a Customer of a QorePay Subscriber, we encourage you to review the Subscriber's Privacy Policy and address any privacy inquiries directly to the Subscriber. Subscribers themselves should refer to the Subscriber Privacy Policy.
Please note that this Privacy Policy does not apply to services not owned or controlled by QorePay, including third-party websites and services offered by QorePay's Subscribers. However, it does apply to all systems, operations, and processes within the QorePay environment that involve the processing of personal data.
In accordance with the Nigerian Data Protection Regulation (NDPR) and other Data Protection Regulations, by accessing or using any portion of our Services, you acknowledge and consent to the following terms outlined in this Privacy Policy:
- The collection of your personal data within QorePay's system
- The processing of your personal data within QorePay's system
- The sharing of your personal data with third parties
- The storage of your personal data within QorePay's system
Please note that utilizing our Services is contingent upon agreeing to QorePay's Terms.
1. DEFINITIONS
1.1. Account means a QorePay Account.
1.2. Personal Information/Data Any information that can be used to identify a living person including email address, company name, password, payment card, financial information such as bank account number, etc., Government-issued Identity card, Bank Verification Number (BVN) and/or taxpayer-identification it may also include anonymous information that is linked to you, for example, your internet protocol (IP), log-in information, address, location, device or transaction data.
1.3. QorePay means QorePay Technology Solutions Limited and subsidiaries or affiliates.
1.4. QorePay Services means to provide an online payment platform and a Point-of- Sale (POS) Terminal deployment and support service on its website, related sites, applications, POS Terminals, services, tools.
1.5. User means an individual who uses the Services or accesses the Sites and has agreed to use the end services of QorePay.
2. WHAT DATA DO WE COLLECT AND HOW DO WE COLLECT THEM?
We collect information through multiple channels and methods, encompassing data you provide directly, data collected automatically, information obtained from third-party sources, and data derived or generated from other sources. These are determined by your interactions with us, the services you use, and the choices you make.
2.1. Directly provided Personal data:
2.1.1. We collect and process data when you register and activate a QorePay account on the QorePay service platform(s) and use or view our website via your browser’s cookies.
2.1.2. We may collect information about you that is personally identifiable like your contact information, your name, address, email address, phone number, date of birth, BVN, gender, debit card details, bank information, and other information we deem necessary and not otherwise publicly available.
2.1.3. We may collect information through communications when you contact us directly, for example, with an inquiry or a support request. We may also receive additional personal data about you and the content of the communications during such communications.
2.1.4. We may also collect and use payment information when you make a purchase such as when you checkout with QorePay on a subscriber’s website or make a payment using our Point of Sales (POS) Terminal, transactional account history, or account balance, which includes payment card numbers, financial account information, and other payment records or details.:
2.2. Automatically Collected Personal Data
2.2.1. We make use of Personal Data to help us understand how you use our services and to help us improve them. We automatically receive information about your interactions with our services. This information includes records of your transactions and information about your other activities related to our services, such as the date and time of your sessions, the pages you view, links to and from any page, and time spent in a session. We gather some of these data using cookies and similar technologies.
2.2.2. We may collect information about the device and software you use to access our services, including Internet Protocol (IP) address, web browser type, operating system version, and device identifiers.
2.2.3. We may collect information about your location when you use our services. We may also collect or infer your general location information, such as your IP address which may indicate your general geographic region.
2.3. Personal information received from third parties.
2.3.1. We may also collect and use the information received from third parties such as family, solicitors, friends, or employers, website/ social media pages made public by you, government agencies, regulators, supervisory or credit agencies.
2.3.2. We may get additional personal data about you from other identification/verification services such as your financial institution and payment processor. We may combine that data with other information we have about you for the process of providing you with optimum services on our service platforms.
2.3.3. We may receive personal data or information from publicly available sources. Public sources of information such as open government databases. We may also infer additional Personal Data based on the Personal Data. For example, for site visitors, we may infer your interests based on the web pages you view.
2.4. You may decline when asked to provide personal data and make use of the web browser or operating system controls to prevent certain types of automatic data collection. Kindly note that where you choose not to provide or allow information that is necessary for certain services or features, some services or features on our service platforms may not be available or fully functional.
3. HOW WILL WE USE YOUR DATA?
3.1. The information collected from you are used in a number of ways. We use the information to process your registration, fulfill your service order, maintain the quality of our service, generate statistics about our QorePay service (s) visitors, facilitate payment in respect of services rendered to you, customize, and improve the content of our QorePay service (s), fulfill any other request you have made, conduct research, and generally enhance our service delivery to you. The information collected is also used to prepare reports for our internal use, analysis and for our current or potential partners e.g., investors, sponsors, advertisers, and other potential users. The information also helps to reconcile our accounts, search results, links, and paid listings to help prevent and detect fraud.
3.2. We may from time to time wish to provide you with information about special features of the QorePay service (s) or any other service we think may be of interest to you. Occasionally, we might want to provide you with related information from third parties we think may be of interest to you. Your information could also be provided to selected third parties, our affiliates, or subsidiaries whose services we believe may be of interest to you. If you do not wish to receive these kinds of communications, you can opt out by unchecking the appropriate announcement boxes during registration or on the user profile page on the QorePay service. Alternatively, you can send an email to [email protected].
3.3. We sometimes hire other companies to provide services on our behalf e.g., performing statistical analysis of our service, etc. These companies may use your personal information and/or communicate with you. We will only provide those companies with the information necessary to provide us with such services. However, they shall be prohibited from using data collected for any purpose other than the intended purpose as contained in this policy document.
3.4. We reserve the right to disclose information about you or your use of the QorePay service (s) in compliance with any regulatory process (i.e., any statutory demand, subpoena, warrant, or court order) to protect against the fraudulent, abuse, unlawful use of the QorePay service (s), to protect our rights or property, to defend the personal safety of users or when we believe in good faith that a situation involving danger or injury to any person requires disclosure.
3.5. We shall not share or offer information about you to third parties except in the manner described in this policy.
5. WHAT ARE YOUR DATA PROTECTION RIGHTS?
5.1. QorePay would like to make sure you are fully aware of all your data protection rights. Every user is entitled to the following:
5.1.1. The right to access - You have the right to request QorePay for copies of your personal data. We may charge you a small fee for this service.
5.1.2. The right to rectification - You have the right to request that QorePay correct any information you believe is inaccurate. You also have the right to request QorePay to complete information you believe is incomplete.
5.1.3. The right to deletion — You have the right to request that QorePay delete or erase your personal data, under certain conditions.
5.1.4. The right to restrict processing - You have the right to request that QorePay restrict the processing of your personal data under certain conditions.
5.1.5. The right to object to processing - You have the right to object to QorePay’s processing of your personal data, under certain conditions.
5.1.6. The right to data portability - You have the right to request that QorePay transfer the data that we have collected to another organization, or directly to you, under certain conditions.
5.1.7. Right to be informed about appropriate safeguards in the place where data is transferred abroad.
5.1.8. Right to object to automated decision-making and processing.
5.1.9. Right to request the movement of data from QorePay to a third party - this is the right to the portability of data.
5.1.10. Right to revoke consent.
5.1.11. Right to object to direct marketing.
5.1.12. Right to submit a complaint to the National Information Technology Development Agency (NITDA).
5.2 All requests will be reviewed and answered by the officer in charge of Data Protection at QorePay within a 30-day period, please contact us as stated in Section 20 below.
9. GROUNDS FOR PROCESSING PERSONAL DATA
9.1. The processing of Personal Information by QorePay shall be lawful where at least one of the following applies:
9.1.1. The Data Owner has given consent to the processing of his/her Personal Information for one or more specific purposes.
9.1.2. The processing is necessary for the performance of a contract to which the Data Owner is party or to take steps at the request of the Data Owner prior to entering a contract.
9.1.3. Processing is necessary for compliance with a legal obligation to which QorePay is subject.
9.1.4. Processing is necessary in order to protect the vital interests of the Data Owner or of another natural person; and
9.1.5. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of an official public mandate vested in QorePay.
10. TRANSFER OF PERSONAL DATA
10.1. Our service provision includes where we may rely on third-party servers, and databases co-located with hosting providers which are residents in foreign jurisdictions, which constitutes the transfer of your personal data to computers or servers in foreign countries. We take steps designed to ensure that the data we collect under this Privacy Policy is processed and protected according to the provisions of this Policy and applicable law wherever the data is located.
10.2. Where personal data is to be transferred to a country outside Nigeria, QorePay shall put adequate measures in place to ensure the security of such personal data. Any transfer of personal data out of Nigeria will be in accordance with the provisions of relevant data protection regulations. Specifically, QorePay shall, among other things, use contractual terms to ensure the protection of the data or ensure the country has adequate data protection laws i.e., as listed in Nigeria’s National Information Technology Development Agency’s [“NITDA”] Whitelist of Countries, or the General Data Protection Regulation’s [“GDPR”] Adequacy List.
10.3. In the event that you wish to transfer personal data to a country deemed to have inadequate data protection laws, QorePay will take all necessary steps to ensure that informed consent is obtained from you and that you are aware of the risks entailed with such transfer. In any instance, QorePay will ensure personal data is transmitted in a safe and secure manner. All details of the protection given when your personal data is transferred abroad, and details of the basis of such transfers shall be provided to you upon request.
11. STORAGE LIMITATION
11.1. QorePay will retain your information for the following periods:
11.1.1. As long as reasonably necessary for the purpose of providing our services to you.
11.1.2. For the duration your account is active, we have your consent.
11.1.3. For the period needed to comply with our legal and statutory obligations
11.1.4. As needed to verify your information with a financial institution.
11.1.5.QorePay is statutorily obliged to retain the data you provide to process transactions, ensure settlements, make refunds, identify fraud, and comply with applicable laws and regulatory guidelines.
12. LINKS - PRIVACY POLICIES OF OTHER WEBSITES
12.1. QorePay website may contain links to other websites. This privacy policy QorePay Service (s)lies only to our website, so if you click on a link to another website, we encourage you to read their privacy policy.
13. COMMUNITIES AND FORUMS
10.1. Any personally identifiable information that you disclose through any message boards, or chat windows on this QorePay service (s) may be collected and used by others. We recommend caution when giving out information to others.
14. SECURITY COMMITMENT
14.1. We employ appropriate technical and organizational security measures to prevent unauthorized access to information that we collect online. In the unlikely event of such an occurrence; if we determine that such a breach poses a threat to your rights and freedoms and data owner? We will notify you of the breach and all steps we have taken to ensure that your information remains secure and private.
14.2. We implement access control measures, security protocols, and standards including the use of encryption and firewall technologies in compliance with the Payment Card Industry Data Security Standard (PCI DSS Requirements”). This is to ensure your card information is safe and secure on our servers. Additionally, we implement periodical security updates to ensure that our security infrastructures are in compliance with reasonable industry standards.
14.3. Two-factor authentication (“2FA”) is an additional layer of security. When 2FA is enabled, you will be required to enter a One Time Password (OTP) which is a verification code we have sent to you for authentication purposes, each time you checkout using QorePay on a subscriber’s website or platform. While we encourage you to enable this feature on every transaction, you may choose to disable the 2FA feature after your initial enrolment by clicking on the button to disable it. However, if you choose to disable this feature, you agree that QorePay shall not be liable for any loss or damage incurred as a result of your action.
14.4. You are required by Governing Regulations and best practice standards to implement and maintain an accurate record of your end users, and transactions. It is important to note that as a User of QorePay, you are bound by the rules of the National Information Technology Development Agency (NITDA) and will be held to account on all points of compliance with this regulation including without limit, the implementation and maintenance of appropriate security measures.
15. ACCESS AND CONTROL OF INFORMATION
15.1. You can access, edit, and delete some information that we collect and process about you. For example, you can edit and update personally identifiable information including your name, email address, phone number, etc. We want to ensure that your personal information is accurate and up to date. If the information that you have provided changes i.e., your email address, name, or other personally identifiable information, please let us know or forward the correct details by sending an email to [email protected] , we may correct any information that we think is inaccurate.
15.2. Occasionally, we may choose to send emails concerning QorePay services, disruptions, new products, and other news about our QorePay Services to registered users and are not subscription-based. Such emails are considered a part of our QorePay Services’ services to users.
16. BUSINESS OR ASSET TRANSFER OR SALE
16.1. We may choose to acquire or sell business assets of our business or merge with another business. In such transactions, information obtained from you is generally one of the transferred business assets. In the event of such a transfer, we will make reasonable efforts to provide notice on the QorePay Service (s) and to notify you of any change in ownership or control of your personal information. Any casual inadvertence in providing such notification shall be considered a breach of our obligation under the policy.
17. CHANGES TO THIS POLICY
17.1. We keep our privacy policy under regular review and place any updates on this webpage.
17.2. We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the personal information that we collect. You acknowledge and agree that we do not have any further obligation to inform you of such changes and that it is your responsibility to review this policy periodically and become aware of any modifications.
18. CONDITIONS OF USE
18.1. By registering on the QorePay Service (s), you signify your acceptance of this policy and the QorePay Services’ Terms and Conditions of Use. If you do not agree to this policy, please do not use the QorePay Service (s). By submitting your personal information, you consent to the use of that information as set out in this policy. You confirm that you have the consent to provide any information you have furnished on the QorePay Service (s). Your continued use of the QorePay Service (s) following the posting of changes to this policy will be deemed your acceptance of those changes.
19. QOREPAY SERVICE (S) ACCESS
19.1. In order to access the QorePay Service (s) and all its features, you must register and activate a QorePay Wallet, which will provide you with full access to the QorePay service (s).
19.2. Children under the age of 18 are not permitted to register or use the QorePay Service (s) or any functionality contained in it.
20. HOW TO CONTACT US
If you have any questions about QorePay’s privacy policy, the data we hold on to you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us via email at: [email protected]