1. INTRODUCTION

At Minerva Technologies Limited (“VPay”, or the “Company” or “Us” or “We”

or “Our”), We are committed to protecting your privacy and ensuring the

security of your personal information. This Privacy Policy (“Notice”) outlines how

we collect, use, and disclose your information when you use our services. VPay

is a payment solution that enables cashiers and online shopping carts to

increase customer loyalty by accepting payments via bank transfer

(“Services”).

2. DATA PROTECTION OFFICER

In compliance with the Nigerian Data Protection Act 2023, the Company has appointed a Data Protection Officer to guide and manage its processing activities. If you have any question and issue regarding this Notice, kindly contact our DPO- 02016339125.

3. INFORMATION WE COLLECT

In connection with the services we offer you, we will collect, use and store the

following categories of information about you

- Personal Information: When you sign up for our Services, we may collect personal information such as your name, email address, phone number, physical address, passport photograph, gender and payment details.

- Usage Information: We may collect information about how you interact with our website, mobile application, and other platforms, including IP addresses, browser type, and device identifiers.

- Device Information: We may collect information about your mobile device, including device type, operating system, and unique device identifiers.

- Location Information: With your consent, we may collect and use your precise location information to provide location-based services.- Cookies: We use cookies and similar tracking technologies to enhance your experience and analyze usage patterns.

If you provide information to us about any person other than yourself, your employees, counterparties, your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their consent for you to disclose it to us and for you to allow us, and our outsourced service providers to use it.

4. HOW WE USE YOUR INFORMATION

We use your personal information to

- To provide and improve our Services.

- To communicate with you about your account and transactions.

- To personalize your experience and tailor our services to your preferences.

- To analyze usage patterns and trends to improve our Services and optimize performance.

- To comply with our obligations under the law.

- To resolve dispute resolution that may arise in the course of providing services or products to you.

- To carry out know your customer (KYC) due diligence.

- To provide marketing communication to you.

- To ensure fraud prevention and investigation.

- To respond to your inquiries and correspondence.

- To establish, defend, investigate and exercise our legal rights.

- For our own legitimate business interests.

- To enhance security, monitor and verify identity or service access, combat other malware or security risks, and to comply with applicable security laws and regulations in our jurisdiction.

5. INFORMATION SHARING AND DISCLOSURE

- We may disclose your information in response to legal requests or to comply with applicable laws and regulations.

- We may share aggregated or anonymized data for marketing, analytics, and other business purposes.

- We may share your personal information with a third party to fulfil a contract between you and the third party or where you have authorized us to do so.

- We, and Our advertising partners, use cookies to collect Personal Data and serve you with advertisements that We believe are relevant to you and your interests.- We may share your Personal Data for financial audits purpose.

- We may share your personal data with financial institutions to enable payment processing.
6. Data Security:

We maintain appropriate internal, technical, and physical controls to ensure that your data are kept safe. HTTPS is put in place for the transmission of the data. Other security measures include but are not limited to, secure servers, firewalls, data encryption, and granting access only to designated employees.

On your part strive to ensure your passwords to your accounts are safe.

7. Your Choices and Rights:

You have certain rights under the law which we respect and adhere to and which can be exercised by you at any time. However, note that these rights are not absolute and may only apply in certain circumstances. Your rights are as itemized:

- Request access to your personal information (commonly known as a "Data Subject Access Request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to process it further. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.

- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) object to processing on this ground and you object to the processing based on reasons that are peculiar to you. You also have the right to object where we are processing your personal information for direct marketing purposes.

- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

You can opt-out of receiving promotional communications from us by

following the instructions in the emails or contacting us directly.

8. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any significant changes by posting the updated policy on our website.

9. Contact Us:

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at [email protected]

10. Push Notifications:

We may send you push notifications to provide updates, promotions, or other relevant information. You can opt-out of receiving these notifications through your device settings.

11. Third-Party Services:

Our mobile app and website may integrate with third-party services, such as social media platforms or analytics providers. These third-party services providers may collect information about your use of their platform, subject to their own privacy policies. We do not control these third-party service providers and are not responsible for their privacy notice. When you leave our mobile app, we encourage you to read the privacy notice of every website you visit.

12. Website Analytics:

We use web analytics services to track and analyze user interactions on our website. These services may use cookies and other tracking technologies to collect information about your browsing behavior. Cookies are small pieces of text that are saved on your Internet browser when you use our website. The cookies are sent back to our computer each time you visit our website. Cookies make it easier for us to give you a better experience online. You can stop your browser from accepting cookies

13. Children's Privacy:

Our Services is not intended for children under the age of 18. We do not knowingly collect personal information of children and we have put appropriate measure in place to block a person below the age of 18 years from registering on our platforms. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately. In the event that there is a need for us to process personal information of a person below 18 years, we will obtain a verified consent of the parent or guardian of such person.