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PRIVACY POLICY.

Introduction

Last updated June 25, 2024

This privacy notice for Kria Technologies Limited ("we," "us," or "our") outlines how and why we collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

  • Download and use our mobile application (Kriapay) or any other application that links to this privacy notice.
  • Engage with us in other related ways, including sales, marketing, or events. Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please refrain from using our Services. If you have any questions or concerns, please contact us at support@kriapay.com.

SUMMARY OF KEY POINTS

This summary highlights key points from our privacy notice. For more details on any of these topics, you can click the link following each key point or use our table of contents to find the relevant section.

1. What personal information do we process?

When you visit, use, or navigate our Services, we may process personal information based on how you interact with us and the Services, the choices you make, and the products and features you use.

2. Do we process any sensitive personal information?

No, we do not process sensitive personal information.

3. Do we collect any information from third parties?

No, we do not collect any information from third parties.

4. How do we process your information?

We process your information to provide, improve, and administer our Services, communicate with you, ensure security and prevent fraud, and comply with legal requirements. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

5. In what situations and with which parties do we share personal information?

We may share information in specific situations and with certain third parties.

6. How do we keep your information safe?

We have implemented organizational and technical measures to protect your personal information. However, no method of electronic transmission or storage is entirely secure, so we cannot guarantee that unauthorized third parties such as hackers or cybercriminals will not be able to breach our security and improperly collect, access, steal, or modify your information.

7. What are your rights?

Depending on your geographical location, applicable privacy laws may grant you certain rights regarding your personal information.

8. How do you exercise your rights?

The easiest way to exercise your rights is by submitting a data subject access request or by contacting us. We will review and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect?

TABLE OF CONTENTS

  1. What information do we collect?
  2. How do we process your information?
  3. When and with whom do we share your personal information?
  4. How long do we keep your information?
  5. How do we keep your information safe?
  6. Do we collect information from minors?
  7. What are your privacy rights?
  8. Controls for do-not-track features
  9. Do other regions have specific privacy rights?
  10. Do we make updates to this notice?
  11. How can you contact us about this notice?
  12. How can you review, update, or delete the data we collect from you?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We gather personal information that you voluntarily give to us when you register on the Services, express interest in learning more about us or our products and Services, participate in activities on the Services, or contact us in any other way.

Personal Information Provided by You: The personal information we collect varies based on your interactions with us and the Services, the choices you make, and the products and features you use. This information may include:

  • Names
  • Phone numbers
  • Email addresses
  • Mailing addresses
  • Usernames
  • Passwords
  • Contact or authentication data
  • Billing addresses Sensitive Information: We do not process sensitive information.

Payment Data: If you choose to make purchases, we may collect data necessary to process your payment, such as your payment instrument number and the security code associated with your payment instrument. All payment data is processed and stored by Moniepoint and Orange Money. Their privacy notices can be found here:

  • Moniepoint Privacy Policy

  • Orange Money Privacy Notice Application Data: If you use our application(s), we may collect the following information if you provide us with access or permission:

  • Geolocation Information: We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. You can change our access or permissions in your device's settings.

  • Mobile Device Access: We may request access or permission to certain features from your mobile device, such as contacts, SMS messages, storage, calendar, camera, microphone, sensors, and other features. You can change our access or permissions in your device's settings.

  • Mobile Device Data: We automatically collect device information, such as your mobile device ID, model, manufacturer, operating system, version information, system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and IP address (or proxy server). If you use our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

  • Push Notifications: We may request to send you push notifications regarding your account or certain features of the application(s). You can opt out from receiving these types of communications in your device's settings. This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information you provide to us must be true, complete, and accurate. You must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, ensure security and fraud prevention, and comply with legal requirements. We may also process your information for other purposes with your consent.

We handle your personal information for various reasons, depending on your interactions with our Services, including:

  1. To facilitate account creation and authentication and manage user accounts: We process your information to enable you to create and log in to your account and to maintain your account in good working order.
  2. To deliver and facilitate the delivery of services to the user: We process your information to provide you with the services you request.
  3. To send you marketing and promotional communications: If in line with your marketing preferences, we process the personal information you provide to send you marketing and promotional materials. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
  4. To protect our Services: We process your information to ensure the safety and security of our Services, including monitoring for and preventing fraud.
  5. To identify usage trends: We process information about how you use our Services to understand usage trends and improve our offerings.
  6. To comply with our legal obligations: We process your information to comply with legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

  1. Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  2. Affiliates: We may share your information with our affiliates, and in such cases, we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  3. Offer Wall: Our application(s) may display a third-party hosted "offer wall." This offer wall allows third-party advertisers to provide virtual currency, gifts, or other items to users in return for accepting and completing an advertisement offer. When you interact with an offer wall, you will be directed to an external website belonging to third parties, leaving our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider to prevent fraud and properly credit your account with the relevant reward.

4. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We retain your information for as long as necessary to fulfill the purposes outlined in this privacy notice, unless otherwise required by law.

We will only retain your personal information for as long as it is necessary to achieve the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as for tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for more than three (3) months after the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it. If deletion or anonymization is not possible (for instance, if your personal information is stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is feasible.

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We strive to protect your personal information through a combination of organizational and technical security measures.

We have put in place appropriate and reasonable technical and organizational security measures to safeguard any personal information we process. Despite these efforts, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Therefore, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to breach our security and improperly collect, access, steal, or modify your information. While we are committed to protecting your personal information, transmitting personal information to and from our Services is at your own risk. You should access the Services only within a secure environment.

6. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect personal information from or market to individuals under the age of 18.

We do not knowingly collect, solicit, or market personal information from children under the age of 18, nor do we knowingly sell such information. By using the Services, you affirm that you are at least 18 years old, or if you are the parent or guardian of a minor, you consent to the minor's use of the Services. If we discover that we have inadvertently collected personal information from someone under 18 years of age, we will deactivate the account and take reasonable steps to promptly delete such information from our records. If you are aware that we may have collected personal information from a child under 18, please contact us at support@kriapay.com.

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your country, province, or state of residence, you have the right to review, modify, or terminate your account.

Withdrawing Your Consent: If we rely on your consent to process your personal information (which may be expressed or implied depending on applicable law), you have the right to withdraw your consent at any time. You can withdraw consent by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. Please note, withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal, nor does it affect processing based on other lawful grounds.

Opting Out of Marketing Communications: You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send, or by contacting us using the details in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. Even if you opt out of marketing communications, we may still send you non-marketing messages related to your account administration, service requests, or other non-marketing purposes.

Account Information: If you wish to review, update, or terminate your account:

  • Log in to your account settings to modify your information.
  • Contact us using the contact information provided. Upon requesting account termination, we will deactivate or delete your account and information from our active databases. Some information may be retained in our files to prevent fraud, troubleshoot issues, assist with investigations, enforce legal terms, or comply with legal requirements.

For questions or comments about your privacy rights, you can email us at support@kriapay.com.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and applications offer a Do-Not-Track ("DNT") feature or setting that allows you to express your preference not to be tracked for online browsing activities. As of now, no universally accepted technology standard for recognizing and implementing DNT signals has been established. Therefore, we currently do not respond to DNT browser signals or any other mechanism that automatically conveys your choice not to be tracked online.

If a standard for online tracking is adopted that we are required to follow in the future, we will update this privacy notice to inform you about how we respond to such signals.

9. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Depending on the country you reside in, you may have additional privacy rights.

Republic of South Africa

You have the right to request access to or correction of your personal information at any time. To make such a request, please contact us using the details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

If you are unsatisfied with how we handle your complaint regarding our processing of personal information, you can contact the office of the regulator:

The Information Regulator (South Africa)

General enquiries: enquiries@inforegulator.org.za

Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

10. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to comply with applicable laws.

We may periodically update this privacy notice. The updated version will be indicated by an updated "Revised" date at the top of this privacy notice. If there are significant changes, we may notify you by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to regularly review this privacy notice to stay informed about how we protect your information.

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have any questions or comments about this notice, you can email us at support@kriapay.com or contact us by mail at:

Kria Technologies Limited

16, Onijanikin Street, Alasia, Nigeria Alasia, Lagos 102101 Nigeria

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Depending on the laws applicable in your country, you may have the right to request access to the personal information we collect from you, details about how we process it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please submit a data subject access request.