1.1 Introduction

We've created this Privacy Policy to explain how we collect, use, disclose and protect your information, including any non-public personal data.

This policy applies to information we collect when you use our website and mobile application (collectively, “Services”) or otherwise interact with us as described below.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and in some cases, we may provide you with additional notice (such as by adding a statement to the homepages of our website or mobile application or by sending you an email notification).

We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy. This privacy policy applies to the Services provided Ashley Hargreeves Limited, whose principal place of business is at 79 Mareham Road, Horncastle - LN9 6BN. (“Ashley Hargreeves Limited”, “we” or “us”).

1.2 Collection of Information

Categories of Non-Public Personal Data

We collect non-public personal data you provide to us when you use our website, apply for a verify-africa.com account or when you communicate with us about your verify-africa.com account. The types of information we may collect include your name, address, phone number, email address, academic credentials data, username and password.

Information About Your Transactions with Us

As you use your verify-africa.com account to perform transactions, we collect non-public personal data in connection with each transaction, including transaction time, currency amount and order details. We may also collect photos, memos or other information that you attach to your transactions.

Information from Other Sources

Collecting personal information from a source other than the person to whom it relates, such as another institution or a third party, is considered to be an “indirect collection.” An application form that requires an individual to provide personal information about his or her spouse, children or someone else is a common example of an indirect collection.

We may collect information, including non-public personal data, about you from non-affiliated third-party service providers in order to verify your identity and for fraud prevention, including your prior addresses and names.

Other Information We Collect

We may collect information you provide to us, such as your name, email address and any other information you choose to provide. For example, we may collect such information if you request an invite to join verify-africa.com or if you enter into any contest or promotion organized by verify-africa.com.

Information We Collect Automatically from our Services

When you access or use our Services, we automatically collect information about you as follows:

Log Information: We log information about your use of our Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Services.

Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.

Location Information: We may collect your location information from your mobile device with your prior consent. Also, we have incorporated Google Maps into our Services, and you may consent to the collection of location information by Google Maps in connection with your use of this maps service. Any information collected via your use of Google Maps will be transmitted directly to Google and is not collected by us. Please refer to Google’s privacy policy for details about their collection, use and sharing of this information. For information about how to disable the collection of location information from your device, please see “Your Choices” below.

Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information on our Services and other websites, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve our Services and your experience, see which areas and features of our Services are popular and count visits. For more information about cookies, and how to disable them, please see “Your Choices” below. We may also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

How We Respond to Do Not Track Signals: We allow Do Not Track browser configurations. We use cookies and other tracking technologies, and Do Not Track status may alter the available services with certain browsers, when these tracking functionalities are used to provide services. We do not alter the information our applications attempt to collect based on your Do Not Track configuration.

The app does use third party services that may collect information used to identify you. Links to privacy policy of third-party service providers used by the app: Google Play Services and Facebook

Information we receive from other sources.

We are working closely with third parties (including, for example, academic institutions, regulatory bodies, financial service providers, security agencies, etc.). We will notify you within 14 days when we receive information about you from them and the purposes for which we intend to use that information.

1.3 What Personal Data Do We Need

The personal data we would collect and process, depending on the particular processing requirement, are under the following categories:

1 Identity Data Full Name, maiden name, marital status, title, NIN, date of birth, gender, address and employment history, and citizenship

2 Contact Data Address, Email Address and Telephone Numbers Information received during your contact with face-to-face meetings, phone calls, emails, letters and SMS

3 Financial Data Organisation account information and organisation statements, Organisation verification Number, your income and outgoings, your financial position, status, and credit history, debit or credit card information and account number.

4 Transaction Data Information regarding the products and services you may have benefitted from by using <> and any of its subsidiaries, transactional information including in respect of products which you purchase.

5 Technical Data Internet protocol (IP) address, your login data, details of your browser and operating system, time zone setting and location, browser plug-in types and versions, platforms and other technology on the devices you use to access this website

6 Profile Data includes your username and password

7 Job Application Data data submitted throughout the recruitment process eg: name, email address. Any personal information you provide to verify africa as part of the provisioning process.

8 Usage Data includes information about how you use our website, products and services

9 Marketing & Communications Data Information about your communications with us. Your preferences in receiving marketing e-mails from us and consents you have given us

Where the personal data we need to collect may fall under a special category of sensitive personal data, the Organisation’s lawful basis of processing will be the explicit consent of the individual, or where applicable, compliance with a legal obligation, or for legal proceedings/advice.

1.4 Use of Information We will only use your personal data where we are permitted to do so by applicable law. Under EU and UK data protection law, the use of personal data must be justified under one of a number of legal grounds. The principal legal grounds that justify our use of your personal data are:

Contract performance: where your information is necessary to enter into or perform our contract with you.

Legal obligation: where we need to use your information to comply with our legal obligations.

Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.

Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.

Consent: where you have consented to our use of your information (you will have been presented with a consent form or facility in relation to any such use and may withdraw your consent through an unsubscribe or similar facility).

We may use your personal data in the following ways. In each case, we note the grounds that we rely on to use your personal data:

Provide, maintain and improve our Services: [Legal grounds: legitimate interests, consent, contract performance]

Provide and deliver the products and services you request, process transactions and send you related information, including confirmations: [Legal grounds: legitimate interests, consent, contract performance]

Verify your identity and prevent fraud: [Legal grounds: legitimate interests, consent, contract performance]

Send you technical notices, updates, security alerts and support and administrative messages: [Legal grounds: legitimate interests, consent, contract performance]

Respond to your comments, questions and requests and provide customer service: [Legal grounds: legitimate interests, consent, contract performance]

Communicate with you about products, services, offers, promotions, rewards, and events offered by verify africa and others, and provide news and information we think will be of interest to you: [Legal grounds: legitimate interests, consent, contract performance]

Monitor and analyse trends, usage and activities in connection with our Services: [Legal grounds: legitimate interests, consent, contract performance]

Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests: [Legal grounds: legitimate interests, consent, contract performance] 

Process and deliver contest or promotion entries and rewards: [Legal grounds: legitimate interests, consent, contract performance]

Link or combine with information we get from others to help understand your needs and provide you with better service: [Legal grounds: legitimate interests, consent, contract performance]

Carry out any other purpose for which the information was collected: [Legal grounds: legitimate interests, consent, contract performance]

1.5 Automated Decision Making We may make decisions about you based on the profiling of your information. Profiling is a form of automated processing of your information to evaluate, analyse or predict your economic situation, preferences, reliability, behaviour, location and may be used

1.6 Disclosure of Information We may disclose any information we collect about current and former customers, including non-public personal data, to affiliates and non-affiliated third parties as follows:

With financial service providers, including the financial institutions identified in your cardholder bank agreement that provide banking services in connection with your verify africa account.

With another user, when you sign up for verify africa services via a referral link. The user that referred you may receive information indicating that you have enrolled with verify africa. You may avoid this sharing by not using a referral link to enrol.

With non-financial companies, such as email service providers that perform marketing services on our behalf, and fraud prevention service providers that use the information to provide services to verify africa and other companies.

With a non-affiliated third-party to access and transmit your personal and financial information from a relevant financial institution. You grant the third-party the right, power, and authority to access and transmit this information according to terms of their privacy policy.

With other non-affiliated companies for our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations or report to credit bureaus. For example, in connection with our everyday business purposes, we may share information about you as follows:

In response to a request for information, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process.

With relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud.

If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of verify africa or others.

In connection with, or during negotiations of, any merger, sale of verify africa assets, financing or acquisition of all or a portion of our business to another company; and

With your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or de-identified Information, which cannot reasonably be used to identify you. For example, we may share transaction zip codes with third parties to improve our accuracy in geo-locating transactions and to improve the clarity of transaction descriptions.

We will usually not share your personal data with other third parties without your consent. Where we need to transfer your data to another country, such country must have an adequate data protection law. We will seek your consent where we need to send your data to a country without an adequate data protection law.

1.7 Your Choices

Account Information

You may edit your account profile information by logging into your account via our Services. If you wish to delete or deactivate your online account, please contact us, but note that we may retain certain information as required by law or for legitimate business purposes.

Promotional Communications

You may opt out of receiving promotional emails and text messages from verify africa by following the instructions in those messages. Please note that if you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.

Location Information

If you initially consent to the collection of location information by verify africa or Google Maps within our mobile application, you may be able to subsequently stop this collection through your device operating system settings or through your online account settings. If either of these opt-out options are not available to you, you may also disable location information by following the standard uninstall process to remove our mobile application from your device.

Cookies

Our web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. Where you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org/

Social Sharing Features

Our Services include social sharing features for common social networks to let users share content. These features are served from third-party services that may serve their own cookies. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Analytics and Advertising Services Provided by Others

We may allow others to provide analytics services on our behalf and to serve advertisements on our behalf across the Internet. These entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by XXX and others, to, among other things, analyse and track data, determine the popularity of certain content, deliver advertising targeted to your interests and better understand your online activity.

1.8 Your Rights

The law gives you certain rights in respect of the information we hold about you. Below is a highlight of some of those rights. It is not a complete, exhaustive statement of your rights in respect of your personal data:

You have a right to consent to this Privacy Policy and to withdraw your consent at any time.

You have a right to a copy of the personal data we hold about you, as well as the information about what we do with it, who we share it with and how long we hold it for. We may make a reasonable charge for additional copies of that data in the case of unfounded and excessive requests.

You have a right to freely transfer your data received from us to any other person.

You have the right to have the information we hold about you corrected, if it is factually inaccurate. You may contact us for this purpose.

In some circumstances, you have the right to the deletion of the information that we hold about you.

You have a right to lodge a complaint about the handling of your personal data with the supervisory authority

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes If you wish to exercise your rights, you may contact the office of our data protection and compliance officer.

1.9 Security

Ashley Hargreeves Limited takes reasonable measures to help protect all information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Additionally, Ashley Hargreeves Limited implements policies designed to protect the confidentiality and security of your non-public personal data, including a privacy protection policy.

Where you have chosen a password that allows you to access certain parts of the website and mobile application, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. We have also taken measures to comply with provision of security facilities for the protection of your non-public personal data through the set-up of firewalls, limited access to specified authorized individuals, encryption and continuous capacity building for relevant personnel. We therefore have digital and physical security measures to limit and eliminate possibilities of data privacy breach incidents.

Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to us or by us. We will notify you and any applicable regulator of a breach where we are legally required to do so.

1.10 Where we store your Data

The data that we collect from you will be transferred to and stored at a destination outside the country. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. All information you provide to us is stored on our secure cloud storage solution.

Your personal data will not be retained for longer than is necessary for the purposes for which it was processed. 1.11 How long we keep your personal data We will hold your personal data on Ashley Hargreeves Limited’s systems for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.

Ashley Hargreeves Limited will delete or destroy it from it’s systems and records, or take steps to securely archive it while protecting your identity and privacy rights as the case may be.

1.12 Complaints and Contacts

If for any reason you wish to make a complaint about how we (or any of the organisation’s third parties) handles or have handled their personal data, or how their complaint has been handled, they have the right to lodge a complaint directly with the supervisory authority and Data Protection Officer.

Below are the details for each of these contacts: dataprotectionoffice@ashleyhargreeves.co.uk