Privacy Policy 2 – Addosser Microfinance Bank

This Mobile Application Privacy Policy (“Policy”) describes the types of information Addosser Microfinance Bank collects through its Mobile Banking Application (the “App”), what we do with that information and how we protect it. This Policy applies solely to the App and does not apply to any other mobile applications, interactive features, web sites, or offline information collection, unless expressly stated at the time of collection.

We use your Personal Information only for providing and improving the App. By using the App, you agree to the collection and use of information in accordance with this policy. The information presented in the Summary Table is qualified and explained more fully below.

SUMMARY TABLE

Ways we Use Your Information				Information Sharing
Types of Registration	Providing the service and maintaining the App	Marketing	Profiling	Service Providers	Legal Process
App Settings	Yes	No	No	Yes	Yes
Contact Information	Yes	No	No	Yes	Yes
Financial Information	Yes	No	No	Yes	Yes
Tracking your activity on this app (“usage Information”) including Device Identifier	Yes	No	No	Yes	Yes
Your Location	Yes	No	No	Yes	Yes

The App does not collect biometrics, , phone or text logs, your contacts, other than your activity on this App as described elsewhere in this privacy policy, health, medical or therapy information, or user files on your device that contain your content.

DEFINITIONS

App Settings: This refers to data stored locally on the device you use to access the App that contain information about your activities on the App or allow the App to remember information about you and your activities.

Device Identifier: IP address or other unique identifier for any computer, mobile phone, tablet or other device you may use to access the App. A Device Identifier is a number that is automatically assigned to your device, and our servers identify your device by its Device Identifier. The App does not collect, use, or share your hardware-based Device ID (such as your UDID or IMEI).

Tracking your activity: Refers

To the Addossers you visited on this App and how long you stayed at each Addosser
Activities you engaged in on this App, such as your searches and transactions
Messages you sent to the company, such as via email.

Usage Information: Information about your use of the App, including the type of device you are using to access the App, the browser and operating system you are using, the search terms or advertisements that referred or otherwise led you to the App, the areas of the App that you access or use, and the time of day you used the App. Usage Information may also include a Device Identifier. We and our Service Providers, including analytics providers, may automatically collect certain “Usage Information” whenever you access and use the App.

Your location: Information about your geographic location, such as GPS, WiFi-based, network-based, or user entered.

INFORMATION COLLECTION AND USE

Collection: While using our App, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to your name, address, telephone number and Bank Verification Number (BVN) (“Personal Information”).

Use for Marketing: in the table above means contacting you through means other than telephone (for example, email or postal mail) to offer and market to you services or products, including special offers or advertisements, any of which may be tailored to you.

Use for Profiling: in the table above means use of your information to do research and analysis and to make decisions that directly affect you, such as to display ads based on your activity in the App.

Use for Registration: providing the service and maintaining the App” means using i nformation about you to:

allow you to participate in features we offer or to provide related customer service;
process your registration, including verifying that the information you provide is active and valid;
process a transaction you initiate;
improve the App and our products, and for internal business purposes, including the measurement of the App’s effectiveness; and
contact you with regard to your use of the App and, in our discretion, changes to our policies.

In addition to the uses described above, to analyze our App, the App may use various analytics services, which may independently collect Usage Information, set and access their own tracking technologies, and otherwise collect or have access to non-personally or personally identifiable information about you. We may also use your information for purposes disclosed at the time you provide your information, or with your consent.

INFORMATION SHARING

Service Providers: As noted in the table above, we may share information you provide to us through the App with third party service providers we have engaged to implement services on our behalf such as developing, hosting or maintaining the App, providing customer support, sending email or other communications, providing marketing assistance, and providing analytics services. These service providers are not authorized by us to use or disclose the information except for the purposes of implementing services for which they were engaged on behalf of Addosser or to comply with legal requirements.

Legal Purposes: Sharing information for legal purposes as noted in the table above, means that we may divulge your information;

If we are required or permitted by law or the legal process to reveal same
If required by law enforcement authorities, or
If we believe disclosing your information is necessary to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.

In addition, we may also share your information with third parties with your consent or at your request, or as disclosed at the time you provide us with information. Addosser also reserves the right to disclose and transfer your information if Addosser goes through a corporate restructuring such as a merger, acquisition by another company, sale of all or a portion of its assets, or other corporate change, including during the course of any due diligence process.

Log Data/ Non-Personal Information: Like many Mobile App operators, we collect information that your mobile device sends whenever you log into our mobile App (“Log Data”). Addosser may share this log data such as your mobile device’s Internet Protocol (“IP”) address, browser type, browser version, the Addossers of our APP that you visit, the time and date of your visit with affiliates and third parties.

We may also share your non-personal information such as the aggregate user statistics (e.g., number of downloads and registrations), demographic information and usage Information, with affiliates and third parties including content providers and analytics providers such as Google Analytics that collect, monitor and analyse this. Addosser does not control the information collection, use, or sharing practices of third parties, including analytics providers.

We do not share your personal information with ad networks, carriers, consumer data resellers, data analytics providers other than the independent collection by those third parties described above, operating systems and platforms, other apps, or social networks.

UPDATING YOUR INFORMATION AND YOUR CHOICES

You may be able to review and update your account information through the App. You may opt out of receiving marketing e-mails from us by following the opt-out instructions provided to you in those e-mails.

Please note that we reserve the right to send you certain communications relating to your account or use of the App, and these transactional account messages may be unaffected if you opt-out from marketing communications.

THIRD PARTY CONTENT AND LINKS TO THIRD PARTY CONTENT

Certain content provided through the App may be hosted and served by third parties. In addition, the App may link to third party web sites, apps, or other content over which we have no control and which are governed by the privacy policies and business practices of those third parties. We are not responsible for the privacy practices or business practices of any third party.

SECURITY

The security of your Personal Information is important to us, thus we take commercially reasonable and appropriate security measures to help protect your personal information, both during transmission and once we receive it. We secure and ensure that your personal information is protected from loss, unauthorized access, misuse, modification or disclosure.

Your personal information with us remains secure because we use strict security measures and technologies to prevent fraud and intrusion. In addition, our security controls and processes are regularly updated to meet and exceed industry standards.

However, no method of electronic transmission or method of electronic storage is 100% secure. Therefore, we cannot guarantee fully the security of any information you submit and you do so at your own initiative and risk.

Cookies are files with small amount of data, which may include an anonymous unique identifier.

Like many other apps, we use “cookies” to collect information, improve your experiences, understand how our Services are being used and to remember your choices. You can instruct your device to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our App.

CHILDREN’S PRIVACY

We do not knowingly collect personally identifiable information from children under 18 without parental consent. The App is not directed to or intended for individuals under 18 years of age. If you are under the age of 18, please do not provide personally identifiable information of any kind.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of (2, August 2017) and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this Addosser.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this Addosser will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

If we make any material changes to this Privacy Policy, we will notify you prior to the change being effective either through the email address you have provided us, or by placing a prominent notice on our website