OVERVIEW
VestPay™ respects the privacy of our users. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our financial service; it also applies when you visit our website www.vestpay.com and our mobile application, including any other media form, media channel, mobile website, or mobile application related or connected thereto VestPay™. Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the VestPay™ financial service application, mobile app or the website.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Cloud Application, Mobile Application, and Website, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the VestPay™ cloud application, mobile app or the website after the date such revised Privacy Policy is posted.

COLLECTION OF YOUR INFORMATION
We may collect information about you in a variety of ways. The information we may collect on the Site includes:

Personal Data
Personally identifiable information, such as your name, residential address, email address, and telephone number, and demographic information, such as your BVN, age, gender, hometown, and other personal information, that you voluntarily give to us when you register with the VestPay™ cloud application, mobile app or the website as a user or when you choose to participate in various activities related to the VestPay™ cloud application, mobile app or the website, such as online chat and message boards. You are under no obligation to provide us with any other personal information apart which is mandatory.

Derivative Data
Information our servers automatically collect when you access the VestPay™ website, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the site. If you are using our VestPay™ mobile application, this information may also include your device name and type, your operating system, your phone number, your country, your likes and replies to a post, and other interactions with the application and other users via server log files, as well as any other information you choose to provide.

Financial Data
Financial information, such as data related to your payment method (e.g. valid debit/credit card number, card brand, expiration date) that we may collect when you request for loan, repay loan, deposit into your VestPay™ wallet, or request information about our services from the VestPay™ website and mobile application. All financial information is stored by our payment processors, Paystack, GTPay, Quickteller, Interswitch, VISA, Mastercard, American Express, Amazon Payments, Stripe, Skrill, Paypal, Flutterwave and others, and you are encouraged to review their privacy policy and contact them directly for responses to your questions.

Mobile Device
Data Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the VestPay™ cloud application, or the website from a mobile device.

Third-Party Data
Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the VestPay™ cloud application, mobile app or the website permission to access this information.

Data from Contests, Giveaways, and Surveys
Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.

Mobile Application Information
If you connect using our VestPay™ mobile application:
● Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

● Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s Bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

● Mobile Device Data. We may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.

● Push Notifications. We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

USE OF YOUR INFORMATION
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the VestPay™ cloud application, mobile app or the website to:
● Administer sweepstakes, promotions, and contests.
● Assist law enforcement and respond to subpoena.
● Compile anonymous statistical data and analysis for use internally or with third parties.
● Create and manage your account.
● Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the VestPay™ cloud application, mobile app or the website to you.
● Email you regarding your VestPay™ account, savings or loans.
● Enable user-to-user communications.
● Fulfill and manage purchases, orders, payments, and other transactions related to the VestPay™ cloud application, mobile app or the website.
● Generate a personal profile about you to make future visits to the VestPay™ cloud application, mobile app or the website more personalized.
● Increase the efficiency and operation of the VestPay™ cloud application, mobile app or the website.
● Monitor and analyze usage and trends to improve your experience with the VestPay™ cloud application, mobile app or the website.
● Notify you of updates to the VestPay™ cloud application, mobile app or the website.
● Offer new products, services, mobile applications, and/or recommendations to you.
● Perform other business activities as needed.
● Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
● Process payments and refunds.
● Request feedback and contact you about your use of the VestPay™ cloud application, mobile app or the website
● Resolve abuse, violations and user experience issues.
● Respond to product and customer service requests.
● Send you a newsletter.
● Solicit for investment/partnerships for the VestPay™ cloud application, mobile app or the website.

DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers
We may share your information with third parties that perform services for us or on our behalf, including payment processing, data protection, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Marketing Communications
With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

Team Conversations
When you post comments, contributions or other content to the VestPay™ cloud application, or mobile app Google Play Store review page, your comments may be viewed by all users.

Third-Party Advertisers
We will not permit third-party advertising companies to serve ads when you visit the VestPay™ cloud application, mobile app or the website.

Business Partners
We do NOT share your information with our business partners for any reason whatsoever. However, we may share your data with our bank/financial service providers.

Other Third Parties
We may share your usage analysis information with investors for the purpose of conducting general business analysis purposes, as permitted by law.

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honour commitments we made in this Privacy Policy. We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

TRACKING TECHNOLOGIES
Cookies and Web Beacons
We may use cookies, web beacons, tracking pixels, and other tracking technologies on the VestPay™ cloud application, mobile app or the website to help customize and improve your experience. When you access the VestPay™ cloud application, mobile app or the website, your personal information will not be collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the VestPay™ cloud application, mobile app or the website. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis. For more information on how we use cookies, please refer to our Cookie Notification Policy posted on the Site, which is incorporated into this Privacy Policy. By using the VestPay™ cloud application, mobile app or the website, you agree to be bound by our Cookie Policy. Additionally, we may use third-party cloud applications to improve user experience on VestPay™ cloud application, mobile app or the website. These third-party applications may use cookies or similar tracking technology to help manage and optimize your online experience with us.

Website Analytics
We may also partner with selected third-party vendors such as Mcafee, Symantec, to allow security and tracking technologies on the VestPay™ cloud application, mobile app or the website through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the VestPay™ cloud application, mobile app or the website, determine and better understand online user activity. By accessing the VestPay™ cloud application, mobile app or the website, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact us directly for responses to your questions. You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

SECURITY OF YOUR INFORMATION
Amongst administrative, technical, and physical security measures, we use top class data security companies to help protect your personal information. VestPay™ is committed to securing your personal information, help guard your personal data from loss, theft, unauthorized access, disclosure, alteration and destruction. VestPay™ complies with applicable data protection, privacy, and security breach notification laws. We protect your data by encrypting it while at rest, during transmission over the public Internet.

POLICY FOR CHILDREN
VestPay™ is will always remain dedicated to file security of our users by takingappropriate technological and organizational measures to help protect your personal information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. VestPay™ complies with applicable data protection, privacy, and security breach notification laws. We protect your data by encrypting it while at rest, during transmission over the public Internet.

OPTIONS REGARDING YOUR INFORMATION
You may at any time review or change the information in your account or terminate your account by:
▪ Logging into your account settings and updating your account
▪ Contacting us using the contact information provided below
Upon your request to terminate your account, we will deactivate your account from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Emails and Communications
If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:
▪ Noting your preferences at the time you register your account with the VestPay™ cloud application, mobile app or the website.
▪ Logging into your account settings and updating your preferences.
▪ Contacting us using the contact information provided below
If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

CONTACT US
If you have questions or comments about this Privacy Policy, make a complaint or have a concern about our handling of your personal information, want to report a possible breach of privacy laws; please contact us at privacy@vestpay.com or at 6, Old Aba Road, Woji Junction, off Artillery, Port Harcourt, Rivers State, Nigeria. VestPay™ will respond to your inquiry within 30 days.