1. Introduction

This privacy policy seeks to keep users abreast with details of how we Process personal information; how we use it and the options you have regarding this data. This Policy is in conformity with the Nigerian Data Protection Regulation, 2019 as issued by National Information Technology Development Agency (NITDA). Please note that this Policy is prone to occasional update, alterations and modifications depending on the prevailing laws and other extenuating factors, so do well to constantly read through the updated versions that we put out from time to time.

Be informed that this Privacy policy applies to users of TinkaSave Nigeria Limited, including users of TinkaSave’s apps, websites, features or other services hence it has become imperative to put out this notice to describe how we collect and manage data which we use for our apps, websites, features or other services both locally and on the international scene. Data privacy is an integral aspect of the technological age that’s constantly evolving, we understand this and we strife every day to maintain the trust reposed on us by users in respect of their data. We further assure users that their personal data will not be shared except under certain circumstances as provided in this privacy policy.

This privacy policy applies to our services as listed below: Tinka Smooth, Tinka Buddie, Tinka Gsave and Tinka Kids. TinkaSave would require the financial details e.g. ATM Card number, bank details, BVN Number to process these services. Also note that this notice regulates TinkaSave’s other collections of personal data in connection with TinkaSave’s services. To this end, we may collect the contact information of individuals who use TinkaSave services but do not fall into the categories specified above.

The updated versions of this policy which we put out from time to time will reflect our recent developments; industry trends and/or changes in legal and regulatory requirements. Users are bound by the terms of the updated versions if they continue using our services provided that the legal rights of users are not restricted.

2. How we collect data: TinkaSave collects data provided by users during account creation:

• Data created during use of our services.
• Financial information of users.
• Data provided by Users during Account creation. User’s profile:

  During account creation or update, we collect users’ personal data such as their full names, phone Numbers, email addresses, login names and password, Residential address, IP address, profile pictures, payment or banking information such as account details and Bank Verification Number, financial history and other government identification documents.

We reserve the right to carry out due diligence of the users’ data to confirm the veracity or otherwise of such data. User generated content: We collect the information users provide or generate when they use our services or interact with our customer support.

We also collect information through ratings and questionnaires. Some of the information received through this medium may include conversation recordings, signatures, feedbacks and attached photographs or screenshots. Data supplied by users by completing our survey, by joining our mail list or through correspondences with us are regarded under this category.

Demographic data: We collect demographic data about users such as age, gender, employment status and income through user surveys. This would help us to determine if our services are well received, the areas with larger subscription and how we are to improve our services. Data created during use of our services.

Location data: This data is collected when the app is opened on screen or in the background of user’s devices.

App usage data: These includes but are not limited to data involving the, app features and crashes, viewed pages, browser used, date and time of usage, sites and services of third parties visited and other service activity. In certain cases, we may use cookies, pixels, tags and other similar tracking technologies to create unique identities for users.

Device data: Data about mobile devices used to access our services are crucial to us. To this end, we may collect data that deals directly with the device’s hardware models, its file management and operating system, the versions of the devices, IP address, installed software, advertising identifiers, and other data needed to identify the device.

Financial information of users: We offer financial services, so it is important that we collect financial information of our users. These data shall include financial history of users, account details, bank details, Bank verification Numbers amongst other information. In addition to the above, please note that we also collect data through the following means;

• User feedback, such as ratings, complaints, or compliments.
• Third party data: we encourage referrals, however where a person is referred to us by a user, such user is obligated to provide us with the data of the referred person and the referred person agrees that we are permitted to receive and process his data. This also applies to the use of users account by a third party.
• Data provided by users in connection with any legal rights, claim, proceedings or dispute.
• Data available to the public.
• Data received through marketing sources.
• User’s data received from our business partners and affiliates through which user’s access our services. Examples includes payment providers, other apps and websites that use our API’s or whose API’s we use.
• We may merge the data collected from other sources with the data in our possession.

3. How we use personal data:

We use data to improve our services so as to ensure standard delivery of financial services, to help our users save for the rainy days, to support our users with difficulties associated with access and/or use of our services, to carry out researches incidental to our internal operations and necessary for an upgrade in our services. Furthermore, the data we collect may be used to send marketing and non-marketing communications such as ads, promotions, policy changes and recommendations to users. We may also use data to investigate or address claims which are connected with any legal proceedings. In protecting the data of users, we do not exchange user’s personal data with third parties for their direct mail advertising, except with the prior consent of our users. In addition to the above, please note that we also use data for the following purposes;

Decision making: we reserve the right to deactivate users who have been observed and identified with fraudulent or other activities that is likely to negatively affect our brand name.

To create distinct identities for users through cookies, pixels, web beacons and other identity technologies.

We may include third party links which are out of our control. You are strongly advised to review the privacy policies of third party sites and Apps that you are directed to before continuing to use their services. Users hereby agree to hold TinkaSave harmless from any liability arising out of the use and practices of third party sites.

We may also engage the services of other sites to advertise our services across the internet. These sites may use cookies, pixels, web beacons or any other technology to track and identify visitors to our websites and services.

4. Sharing of Data and Full disclosure.

Users are hereby informed that we may share data with other users based on user’s request.

We may also share data with other business partners, associates, subsidiaries, vendors, research firms, marketing partners and other service providers in order to further enhance our services.

We may share data of users for legal reasons or in connection with any legal proceedings.

We may share data for marketing and communication purposes provided that the prior consent of users are obtained.

Personal data may be viewed by the general public when users interact with us by dropping reviews, information or complaints on our websites or social media handles.

5. Update, alterations and modifications to this privacy policy.

We may update this privacy policy from time to time. Where there is any update, we will inform users by posting a notice on our website. Users would be given ample opportunity to read through the changed policy and contact us with any question or query as regards the new privacy policy.

Notice of updated and/or modified privacy policy shall remain on our website for a period of 14 days from the date of publication after which it shall be taken down. By continuing to use the site and mobile application you agree to be bound by the terms of the new policy.

6. Questions on our privacy policy:

All questions, concerns and complaints arising from this privacy policy should be forwarded to our email address at support@tinkasave.com.