Privacy & Cookie Policy

Last updated: Oct 19th, 2023

We are committed to protecting your privacy. This Privacy and Cookie Policy (“Privacy Policy”) describes how we collect, store, use, share, and protect personal data from visitors and registered users who engage with our services. It applies to all our websites, web apps and associated domains, and mobile apps. By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.



The following terminology applies to this Privacy Statement:

"Cookie" is a small amount of data generated by a website and saved by your web browser. It is used to identify your browser, provide analytics, and remember information about you such as your language preference or login information.

"The Company," "Ourselves," "We," "Our," "Us," "Nephew," "Buddy Nephew Limited, " and "Guarantur" refers to our Company, it’s representatives or its subsidiaries;

"Customer" refers to any company, organization or person that signs up to use our Service

"Device" refers to any device connected to the internet which is assigned an Internet Protocol (IP) address.


Information automatically collected

We collect and store the information you provide when creating an account with us. Depending on whether you are an End user or an Organization, some of the information we collect include but are not limited to name, password, means of identity, home or business address, email, phone number, name of organization, business registration documents, photo, etc. We also use identity verification service from Dojah to verify the identity of End users. When you click to verify your Identity on Dojah, you are bound by Dojah’s Privacy Policy which is available on (https://dojah.io/privacy-policy). Likewise, we automatically collect certain information when you visit, use or navigate the platform. These information do not reveal your specific identity (like your name or contact information) but may reveal device and usage information. Your Internet Protocol (IP) address and/or browser and device characteristics are collected automatically when you visit our platform. Other information collected automatically could be computer and connection information such as browser plug-in types and versions, time zone setting, operating systems and platforms, the full Uniform Resource Locator (URL) clickstream to, through and from our Website that may include date and time; cookie number; parts of the site you viewed or searched for; and the phone number you used to call our Customer Services. We may also use browser data such as cookies, Flash cookies (also known as Flash Local Shared Objects) or similar data on certain parts of our Website for fraud prevention and other purposes. During your visits, we may use software tools such as JavaScript to measure and collect session information including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. We may also collect technical information to help us identify your device for fraud prevention and diagnostic purposes. Other information we may collect may include your operating system, language preferences, referring URLs, device name, country, location, information about who and when you use our service and other technical information. These information are primarily needed to maintain the security and operation of our platform, and for our internal analytics and reporting purposes.


We may also collect information from mobile devices for a better user experience, such as:


Location (GPS): Location data helps us determine where our users are accessing our platform from.


Phonebook (Contacts list): We may request permission to access your phonebook to enable you access certain features of our platform


Camera: Granting camera permission allows the user to take a picture with their device


Photo Gallery: Granting photo gallery access allows the user to upload pictures from their photo gallery



How We Use The Information We Collect?

Any of the information we collect from you may be used in one of the following ways:


To personalize your experience - your information helps us to better respond to your individual needs


To improve our service - we continually strive to improve our offerings based on the information and feedback we receive from you


To improve customer service - your information helps us to more effectively respond to your customer service requests and support needs


To administer a contest, promotion, survey or other site feature


To provide you with our core services


To respond to your questions or requests


To address inappropriate use of our website


To resolve disputes that may arise, including investigations by law enforcement or regulatory bodies


To prevent, detect and manage risk against fraud and illegal activities using internal and third party screening tools


To maintain up-to-date records


To verify your identity and the information you provide in line with Guarantur’s statutory obligations using internal and third party tools


To send you marketing content, newsletters and service updates curated by us - only with your explicit consent

Any other purpose that we disclose to you in the course of providing our services to you.



Sharing your information with third parties

We may share the information that we collect, both personal and non-personal, with third parties such as advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we think may interest you. We may also share it with our current and future affiliated companies and business partners, and if we are involved in a merger, asset sale or other business reorganization, we may also share or transfer your personal and non-personal information to our successors. We may engage trusted third party service providers to perform functions and provide services to us, such as hosting and maintaining our servers, database storage and management, e-mail management, storage marketing, customer service, etc. We will likely share your personal information, and possibly some non-personal information, with these third parties to enable them to perform these services for us and for you. We may share portions of our log file data, including IP addresses, for analytics purposes with third parties such as web analytics partners, application developers, and ad networks. If your IP address is shared, it may be used to estimate general location and other technographics such as connection speed, whether you have visited the app in a shared location, and type of the device used to visit the app. They may aggregate information about our advertising and what you see on the app and then provide auditing, research and reporting for us and our advertisers. We may also disclose personal and non-personal information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate in order to respond to claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations.



How We Use Your Email Address

By submitting your email address on our app and websites, you agree to receive emails from us. You can cancel your participation in any of these email lists at any time by clicking on the opt-out link or other unsubscribe option that is included in the respective email. We only send emails to people who have authorized us to contact them, either directly, or through a third party. We do not send unsolicited commercial emails, because we hate spam as much as you do. By submitting your email address, you also agree to allow us to use your email address for customer audience targeting on social media, where we display custom advertising to specific people who have opted-in to receive communications from us. If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.



How Long We Keep Your Information

We keep your information only so long as we need it to provide our services to you and fulfill the purposes described in this policy. This is also the case for anyone that we share your information with and who carries out services on our behalf. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we'll remove it from our systems.



Security of Information

We take precautions to protect the security of your information. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes or fail to follow policies. Therefore, while we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If applicable law imposes any non-disclaimable duty to protect your personal information, you agree that intentional misconduct will be the standards used to measure our compliance with that duty.



Updating your Information

You may edit portions of your information submitted to us to the extent that we permit after you submit. You may contact us to (1) update or correct your personally identifiable information, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personally identifiable information maintained about you on our systems by canceling your account. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. Promptly after receiving your request, all personal information stored in databases we actively use, and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and technically practicable.



Sale of Business

We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantial assets of our Company or any of its properties or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding, provided that the third party agrees to adhere to the terms of this Privacy Policy.



Affiliates

We may disclose information (including personal information) about you to our Corporate Affiliates. For purposes of this Privacy Policy, "Corporate Affiliate" means any person or entity which directly or indirectly controls us, is controlled by us or is under common control with us whether by ownership or otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.



Governing Law

This privacy policy is made pursuant to the Nigeria Data Protection Regulation 2019 and other relevant Nigerian laws, regulations or international conventions applicable to Nigeria. Where any provision of this Policy is deemed inconsistent with a law, regulation or convention, such provision shall be subject to the overriding law, regulation or convention. The laws of the Federal Republic of Nigeria excluding its conflicts of law rules, shall govern this Agreement and your use of our service. Your use of the service may also be subject to other local, state, national, or international laws.



Your Consent

By using Guarantur or contacting us directly (through any means e.g physically, taking a survey, filling a form, phone calls, etc), you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not engage with our website, or use our services. Continued use of the website, direct engagement with us, or following the posting of changes to this Privacy Policy means that you hereby consent to our Privacy Policy and agree to its terms



Links to Other Websites

This Privacy Policy applies only to our Services. Our service may contain links to other websites or use services of third party partners not operated or controlled by us. We are not responsible for the content, functionality, accuracy or opinions expressed in such websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us. Please remember that when you use a link to go from our Services to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our platform, is subject to that website's own Terms and Privacy policies. Such third parties may use their own cookies or other methods to collect information about you.



Cookies

Guarantur uses "Cookies" to identify the areas of our website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We use Cookies to enhance the performance and functionality of our services but are non-essential to their use. However, without these cookies, certain functionality like videos may become unavailable or you would be required to enter your login details every time you visit the app as we would not be able to remember that you had logged in previously. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our website correctly or at all. We never place Personally Identifiable Information in Cookies.



Blocking and disabling cookies

Wherever you're located you may also set your browser to block cookies and similar technologies, but this action may block our essential cookies and prevent our website from functioning properly, and you may not be able to fully utilize all of its features and services. You should also be aware that you may also lose some saved information (e.g. saved login details, site preferences) if you block cookies on your browser. Different browsers make different controls available to you. Disabling a cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your browser, you should visit your browser's help menu for more information.



Payment Details

We do not store credit card details on our server. To fund your wallet, we integrate with Paystack as our payment processor. When funding your wallet, you are bound by Paystack’s Privacy policy which can be found at https://paystack.com/terms.



Kids' Privacy

We do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.


Changes To Our Privacy Policy

We may change our Service and policies, and we may need to make changes to this Privacy Policy so that they accurately reflect our Service and policies. Unless otherwise required by law, we will notify you (for example, through our Service) before we make changes to this Privacy Policy and give you an opportunity to review them before they go into effect. Then, if you continue to use the Service, you will be bound by the updated Privacy Policy from the effective date provided on our website. If you do not want to agree to this or any updated Privacy Policy, you can delete your account. We advise that you check this page often, referring to the date of the last modification on the page.



Third-Party Services

We may display, include or make available third-party content (including data, information, applications and other products services) or provide links to third-party websites or services ("Third-Party Services"). You acknowledge and agree that Guarantur and all our representatives, employees, owners, acquirers, shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof. Guarantur does not assume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services. Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely at your own risk and subject to such third parties' terms and conditions.



Policy Violations and Enquiry

Kindly bring to the notice of our Data Protection Officer, any violation of this Privacy for timely action, or if you have any questions relating to this Privacy Policy, or would like to find out more about exercising your data protection rights. You can reach our Data Protection Officer at dpo@guarantur.com



Acceptable Use Policy

By accessing or using Guarantur, you agree to comply with the terms and conditions of this Acceptable Use Policy.



Restricted Activities and Business Categories

You may not use Guarantur in connection with any product, service, transaction or activity that:


1. violates any law or government regulation, or promotes or facilitates such by third parties;

2. is fraudulent, deceptive, unfair or predatory;

3. causes or threatens reputational damage to us or our partners;

4. involves any of the business categories listed in clause 2 below; or

5. results in or creates significant damages or other harm or liability.

6. falls within the Prohibition List of the Nigerian Customs Administration of the Federal Republic of Nigeria

7. relates to the sale and/or purchase of:

- banned narcotics, steroids, certain controlled substances or other products that present a risk to consumer's safety;

- blood, bodily fluids or body parts;

- burglary tools;

- counterfeit items;

- illegal drugs and drug paraphernalia;

- fireworks, destructive devices and explosives;

- lottery tickets, sweepstakes entries or slot machines without the required license;

- offensive material or hate speech or items that promote hate, violence, racial intolerance, or the financial exploitation of a crime;

- chemicals;

- recalled items;

- prohibited services;

- unlicensed financial services, stocks or other securities;

- stolen property;

- items that infringe or violate any copyright, trademark, right of publicity or privacy or any other proprietary right under the laws of any jurisdiction;

- obscene material or pornography;

- certain sexually oriented materials or services;

- certain firearms, firearm parts or accessories, ammunition, weapons;

- any product or service that is illegal or marketed or sold in such a way as to create liability to Guarantur; or

- production of military and paramilitary wears and accoutrement, including those of the Police and the Customs, Immigration and Prison Services.

8. relates to transactions that:

- show the personal information of third parties in violation of applicable law;

- support pyramid or ponzi schemes, matrix programs, other "get rich quick" schemes;

- are associated with purchases of annuities or lottery contracts, lay-away systems, off-shore banking or transactions to finance or refinance debts funded by a credit card;

- pertain to ammunitions and arms; and;

- involve gambling, gaming and/or any other activity with an entry fee and a prize, including, but not limited to casino games, sports betting, horse or greyhound racing, lottery tickets, other ventures that facilitate gambling, games of skill (whether or not it is legally defined as a lottery) and sweepstakes unless the operator has obtained prior approval from Guarantur and the operator and customers are located exclusively in jurisdictions where such activities are permitted by law.



Actions we can take

If, in our sole discretion, we believe that you may have engaged in any violation of this Acceptable Use Policy, we may (with or without notice to you) take such actions as we deem appropriate to mitigate risk to us and any impacted third parties and to ensure compliance with this Acceptable Use Policy. Such actions may include, without limitation:


- Terminating a transaction;

- Suspending, restricting or terminating your access to and use of our Services;

- Terminating our business relationship with you, including termination without liability to us of any pending request or amount in your wallet with us;

- Taking legal action against you;

- Contacting and disclosing information related to such violations to (i) End Users you have requested Guarantors or References from in the past (ii) any Businesses that may have requested Guarantors or References from you in the past, (iii) law enforcement or regulatory agencies, and (iv) other third parties that may have been impacted by such violations; or assessing against you any fees, penalties, assessments or expenses (including reasonable attorneys’ fees) that we may incur as a result of such violations, which you agree to pay promptly upon notice.