Anchor Software Ltd and its affiliates ( "Anchor", "we", "us", "our" ) is a financial technology company that provides technological and end-to-end business solutions, (our "Services" ) through its banking partners to its corporate clients ( "User", "you" "your" ) to enable you to provide diverse financial services, as contained in our Terms of Use, which is incorporated by reference into this Agreement, to your customers ( "Customers" ).By accessing or using our Services, or otherwise assenting to this Privacy Notice ( “Notice” ), you signify that you have read, understood and agreed to our collection, storage, use and disclosure of your personal information as described in this Notice and our Terms of Use. if you are an individual acting on behalf of a company, ( “Administrator” ) you represent and warrant that you are an authorised representative of the company with the authority to bind the company to this Notice and that you agree to this Notice on the company’s behalf.

1.1. This Notice applies to your information, when you visit our website or use our Services through our mobile application (“Platform”) it demonstrates our commitment to privacy and explains how we collect, retain, process, share and transfer the information you provide to us. It also outlines your Customer’s data subject rights, including their right to object to some uses of their Personal Data by us;

1.2. We recommend that you read this Notice carefully, to understand your rights and our duties towards the management of your information, in addition to our Terms of Use.

We may make changes to this Notice from time to time to reflect the changes in our business and practices. Such changes or revision shall be effective immediately upon posting it on our Platform. We will provide you notice of such changes, by indicating the Last Revised Date on our Platform. Your continued use of our Services after such revision, shall constitute your acceptance of the Notice. If you do not agree to the Notice as at the Last Revised Date, do not use our Services.

3.1. By using our Services, you are deemed to have consented to this Privacy Notice and our use of your information in the manner set forth under this Agreement;

3.2. We provide you with the option to accept this Notice, by clicking on the “accept” button to either opt in and out of your use of our Platform, Services, features, technologies or visit our offices for official or unofficial purposes;

3.3. You may only withdraw your consent by not using our Services. When you decide to withdraw your consent after using our Services, information collected prior to your withdrawal may be processed in accordance with the version of this Notice that was in place when you used our Service.

The categories of information we collect, collectively referred to as “data”, are collected on your behalf when you use our Platform in providing Services to your Customers, and they include:

4.1. Personal data

‍When you use our Platform to provide services to your Customers we collect unique information or aggregated data which when processed with other information can identify an entity as a human being (“Personal Data”) when you provide them to us. This information includes;

4.1.1. For our payment services; Customer’s namer, email address, bank account information, date of payment and time of payment, originating and destination bank, phone number, shipping and billing address;

4.1.2. For our banking infrastructure API; Customer’s name, Bank Verification Number, Location, Means of Identification, passport photographs, age, email address, address.

4.2. Device information

‍When you use our Services on your computer or mobile device (“Device”), we may collect information from your Device such as the model, operating system and version, browser type, unique identification number, presence of browser add-ons, the locations from where you access our services and your stored contacts;

4.3. Service information

‍We collect information about how you use our Service, your actions on our Platform, and your communications with us through our Platform.

4.4. Location Information

We may receive information from you that helps us to approximate your location, such as using the IP address provided on your browser or your device.

Your onboarding and continued use of our Platform is subject to your compliance with our acceptable use requirements. You agree not to use our Platform or Services for any of the following;

5.1. We collect public and non-public data through your direct disclosures to us when you use our Services or access our Platform, through your communication to us through our customers support channels, when you read our emails or notices, online research on social media and websites which may not be publicly available, when you participate in surveys which we make available to you;

5.2. We collect information about you when you engage with us by using our Services or accessing our Platforms through a variety of tracking technologies which include cookies, flash objects, web beacons, file information and similar technologies (“Tracking Technologies”);

5.3. We use the data collected through Tracking Technologies to:

5.3.1. Remember information about your use of our Services to make it easier for you to navigate our Services when you access our Platforms subsequently;

5.3.2. Monitor aggregate metrics such as the total number of visitors, traffic, usage and demographic pattern;5.3.3. Identify you across multiple devices;

5.3.4. Provide custom, personalised content and information, including targeted content and advertising;

5.3.5. Diagnose or fix technology problems and otherwise plan for and enhance our Services;5.3.6. Provide and monitor the effectiveness of our Services.

5.4. If you would prefer not to accept tracking technologies most browsers will allow you to:

5.4.1. Change your browser settings to notify you when you receive a cookie, which lets you to choose whether or not to accept it;

5.4.2. Disable existing cookies;

5.4.3. Set your browser to automatically reject cookies. Please note that disabling or automatically rejecting cookies, may negatively impact your experience using our Services as some features on our Platform may not work properly;

5.5. We may also use one or more third party analytics services to evaluate your use of our Services as the case may be and analyse performance metrics. These third parties use cookies and other technologies to help collect, analyse and provide us reports or other data. By accessing and using our Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Notice. Please be advised that if you opt out of any of the services they provide, you may not be able to use the full functionalities of our Service.

The information we collect or receive from you is used to operate, improve and protect the Services we provide to you, and more specifically they are for the following reasons:

6.1. Contractual and precontractual business relationships

‍We process your information for the purpose of entering into business relationship with you and for the performance of our contractual obligations which include:

6.1.1. The creation and management of Anchor Accounts, including the evaluation of applications to commence or expand your use of our Services;

6.1.2. Accounting , auditing and billing activities and6.1.3 Processing of payments, including fraud detection and prevention, optimising valid transactions, communications regarding such payments and other related service;

6.2. Legal compliance

6.2.1. We process your information so as to verify your identity or when requested by you, the identity of your Customers, in other to comply with fraud monitoring, prevention and detection obligations, laws associated with the identification and reporting of illegal and illicit activity, such as Anti Money Laundering and Combating the Financing of Terrorism (AML/CFT) and Know Your Customer (KYC) Obligations as well as financial reporting obligations;

6.2.2. These obligations are imposed on us by the operation of law, industry standards and by our financial partners and may require us to report our compliance to third parties and to submit to third parties verification audits;

6.3. Legitimate business interests

6.3.1. Where allowed under the applicable law, we rely on our legitimate business interests to process your data for the following reasons.

6.3.1.1. Protect you, our Services, and our Platform from malicious activity and other privacy and security risks;

6.3.1.2. Send technical notices, updates, security alerts, supports and administrative messages;

6.3.1.3. Promote analyse, modify and improve our Services, systems and tool and develop new products and services, including the reliability of the Services,

6.3.1.4. Detect, monitor and prevent fraud;

6.3.1.5. Determine eligibility for and offer new Anchor products and Services;

6.3.1.6. Manage, operate and improve the performance of our Platform and Services by understanding their effectiveness;

6.3.1.7. Conduct aggregate analysis and develop business intelligence that enables us to operate, protect, make informed decisions and report on the performance of our business;

6.3.1.8. Enable network and information security throughout Anchor and our Services;

6.3.1.9. Investigate any misuse of our Services or our Platforms;

6.3.1.10. To confirm a person’s authority as a representative or agent of a User;

6.3.1.11. To provide our Services to you, including the performance of our obligations under our agreement and carry out related business functions including transaction processing, handling User inquires and managing relationships;

6.3.1.12. To conduct record keeping and otherwise manage our business;

6.3.1.13. For any other purpose with your consent;


6.4. We may use raw or aggregated and anonymised data for the purposes provided in this Notice. We may also use machine learning to verify the legitimacy of your identification documents, verify the factualness and credibility of the information you provide to us and avoid from, by among other actions, comparing biometric data with data previously or separately obtained.

7.1. We may share your data with third parties in the manner provided in this clause and for the purposes contained under this Notice;

7.1.1 With our partner banks in order to comply with regulations and the bank’s regulatory obligations;

7.1.2. With third parties party service providers that performs services on our behalf as needed to carry out their work for us, which may include providing the following services: tax and accounting, fraud prevention services, identity verification services, web hosting, customer and support services or analytics services;

7.1.3. Third parties, to investigate fraud inside or outside our Services;

7.1.4. To card networks in case you are issued a card by our partner banks;

7.1.5. To independent external auditors or other service providers around the world;

7.1.6. To support our audit, compliance and corporate governance functions;

7.1.7. In connection with change of ownership or control of all or part of our business, such as a merger, acquisition, reorganisation or bankruptcy;

7.1.8. For our everyday business purposes such as processing your transactions, maintaining your accounts or reporting to regulatory authorities;

7.1.9. Third parties at your request;

7.1.10. Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to:

7.1.10.1. Comply with the law and the reasonable requests of the law enforcement;

7.1.10.2. With regulators and self-regulatory bodies to which we are subject, wherever we do business.

7.1.10.3. Enforce our Terms of Use or to protect the security or integrity of our Services and or;

7.1.10.4. Exercise or protect the rights, property or personal safety of Anchor, our visitors or other User;

7.1.10.5. Protect against legal liability.

8.1. Anchor maintains organisational, technical and administrative measures designed to protect Personal Data covered by this Policy against unauthorised access, disclosure, alteration, misuse and destruction;

8.2. Unless otherwise specified in this Notice, we limit access to your information to employees that have a business reason to know such information and further implement security practices and procedures designed to protect the confidentiality and security of such information and prohibit unlawful disclosure of such information in accordance with our policies;

8.3. To help us protect your data, we encourage you to also maintain effective security measures that correspond to the nature of your business, and to utilise strong passwords for your Anchor Account. If you have reasons to believe that your interactions with us is no longer secure, please contact us immediately;

9.1. We retain your data for as long as we are providing our Services to you or for a period during which we reasonably anticipate providing Services to you and in accordance with the provision of the Nigerian Data Protection Regulation (NDPR) 2019. For compliance reasons, we may further retain your information for at least five years after your last active use of our Services;

9.2. The information we collect through your use of our Services may be stored and processed in Nigeria or in any other country where we maintain facilities;

9.3. Please note that we may transfer your data including personal information to a country and jurisdiction that does not have the same data protection laws as Nigeria. You acknowledge and agree to such transfer by continued use of our services;

9.4. All data are stored in encrypted formats of Anchor’s database;

9.5. You may request that we delete your data before the expiration of the five years retention period and we may do so immediately upon your request.

9.5.1 When no statutory provision states otherwise;

9.5.2 When you are not subject to an investigation or suit that may require retention of the data sought to be deleted;

9.6. The personal representative of a User, may request the deletion of a data provided that such personal representative makes available a copy of the probate or letters of administration issued.

9.7. We may retain your data after you or your personal representative have requested us to delete it if:

9.7.1 There is an unresolved issue relating to your Anchor Account, such as an outstanding fee or a chargeback claim;

9.7.2. We are required to do so by an applicable law or;

9.7.3. It is necessary for our legitimate business interests such as fraud prevention and enhancing the safety of our Users.

10.1. Defending on your location and subject to the applicable law, you may have the following rights with respect to the data we collect about you

10.1.1 The right to request confirmation of whether Anchor processes data relating to you and if so, to request a copy of such data;

10.1.2 The right to request that Anchor erase your Personal Data in certain circumstances provided by law;

10.1.3 The right to request that Anchor rectifies or updates your Personal Data or Business Information which is inaccurate, incomplete or outdated;

10.1.4 The right to request that we export your Personal Data that we hold to another company where we believe it is technically feasible to do so;

10.1.5 The right to request that Anchor restrict the use of your Personal Data in certain circumstances, provided that you understand that the exercise of this right might restrict your access to our Services;

10.1.6 The right to withdraw your consent in accordance with this Notice, where it has been previously given; Users.

10.2. In the exercise of your rights above, you may contact us through such channel provided under this Notice and we may request that you complete a form and provide suitable identifications in order to verify your identity, and we will provide you with requests as soon as possible;

10.3. You may control our access to your Device through the settings app on your devices;

10.4. If you no longer want to receive marketing related emails from us, you may opt-out via the unsubscribe link included in such email. We will try to comply with your request as soon as practicable;

10.5. Where any of your rights as provided for under this Notice is breached, resolution shall be in accordance with the provision of our Terms of Use, provided that you can only apply for a remedy within a period of 2 years within which the breach occurred.

Our Platform may contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the website of third party sites.

This Notice is made pursuant to the provisions of the NDPR and in any event that any part of this Notice is found to be inconsistent with the NDPR, such provision shall be deemed severed.

If you have any questions about this Notice, please contact us at hello@getanchor.co.