Terms & Privacy Policy

CAFÉ ONE by STERLING!

This Policy details how we Process Personal Data or Personal Information.

For the purpose of this policy “you” or “your” means you as a user of the Café One platform (“Website”) of the Services on the Website. “We”, “our” or “us” means Sterling Bank Plc of Sterling Towers, 20. Marina, Lagos, the platform provider of Café One by Sterling accessed via the website www.cafeoneng.com

Application of this Policy

This privacy policy applies to all Personal Information we collect through our Services from current and former users, including you. “Services” here means any products, services, content, features, technologies, or functionalities on the website.

By using the website or the Services available on the website you accept and consent to the practices described in this policy.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law(s). We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

Objectives of this Policy

This Privacy Statement is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use the Cafeone website and Services. It does not apply to online websites or services that we do not own or control, including websites or services which we may link.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We give you choices about the ways we use and share your personal information, and we’ll respect the choices you make.

Your Personal Information

“Personal information” or “Personal Data” means information that identifies or can be used to identify you directly or indirectly. Examples of personal information include, but are not limited to, first and last name, email address, telephone number, Bank Verification number, National Identification Number, device information, bank account details etc.

Our aim of collecting your Personal information is to provide you with a safe, and efficient service.

Why we collect Your information

To the extent permissible under applicable law, we use your information to:

· provide, maintain, protect and improve the Website, products, services and information that you may have requested from us;

· manage risks and protect the Website, the Services and you from fraud by verifying your identity;

· undertake internal testing of the Website, systems and services to test and improve their security, provision and performance, in which case, we would pseudonymise any information used for such purposes, and ensure is it only displayed at aggregated levels which will not be linked back to you or any living individual;

· enable the use of any partner service and facilities securely and to enable us deliver the services you have requested;

· address any issue(s) or concerns you have raised

· enable us take your suggestion on what you may be interested in;

· contact you to see if you would like to take part in our customer research (for example, feedback on your use of our applications, products and services);

· provide the services any customer support you may request;

· process transactions and send notices about our products and services, including promotional messages about such products and services;

· resolve disputes, collect fees, and troubleshoot problems;

· prevent potentially fraudulent, prohibited or illegal activities, and enforce these Terms;

· create an account connection between your account and any third-party account or website;

· customize, personalize, measure, and improve our services and the content and layout of our website for your beset user experience;

· send you updates about new products and services that we are offering to our customers;

· compare information for accuracy and verify it with third parties; and

· perform other duties as required by law

How we may share your Personal Information

It is important that you share some personal data with us to enable you use our services and facilities securely and for us to deliver the services you have requested. To provide the services that you have requested from our platform, we may need to share your data with:

· Our affiliates and/or subsidiaries we control, but only for purposes allowed by this document.

· Law enforcement, government officials, or other third parties if we are compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of a User of the Platform;

· Third party service providers who assist us in providing services to you whether payment service or otherwise.

· deliver targeted advertising, marketing (which may include in-product messaging) or information to you which may be useful to you, based on your use of our applications and services;

Our website, and Services may contain technology that enables us to:

· check specific information from your device or systems directly relevant to your use of the website, or services against our records to make sure the websites, or services are being used in accordance with our end-user agreements and to troubleshoot any problems;

· obtain information relating to any technical errors or other issues with our website, and services;

· comply with our legal or regulatory obligations;

· collect information about how you and users use the functions of the features of our website, and services; and

· gather statistical information about the operating system and environment from which you access our or services.

Information Automatically Collected

We (or our service providers acting on our behalf) may collect information about your use of our Services. This information may include Personal Information as well as statistical information that does not identify you (“Analytics”). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy.

Information that we automatically collect in connection with your access or use of our Services may include:

Device Information: We may collect Device-specific information (such as hardware model, operating system version, unique Device identifiers, and mobile network Information, including your mobile phone number). We may associate your Device identifiers or mobile phone number with your Healthbanc account.

Log Information: We may record or log information from your Devices, their software, and your activity accessing or using our Services. This information may include:

· The Device’s Internet Protocol (“IP”) address

· Identification numbers associated with your Devices

· Device event information, such as crashes, system activity, and hardware setting

· Location preferences

· Date and time stamps of transactions

· System configuration information

· Other interactions with our Services

Promotional messages

We may from time to time use your information to contact you with details about our product offerings and services which we feel may be of interest to you. We may also share your information with our affiliate companies and carefully selected third parties so that they (or we) may contact you with information about their products or services which we feel may be of interest to you too. We or they may wish to contact you for this purpose by telephone, post, SMS or email. You have the right at any time to stop us from contacting

you for marketing and promotional purposes. You may also request at any time that we do not share your information with third parties referred to in this paragraph. To opt-out from receiving such promotional messages, please send us an email to cafeone@sterling.ng or follow the instruction on the bottom of our Website to unsubscribe from any email marketing.

How we use Cookies

When you visit the Website, use our Services, or visit a third-party website for which we provide online Services, we and our affiliates or third party providers may use cookies and other tracking technologies (collectively, “Cookies”) to recognize you as a user and to customize your online experience, measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety on the CaféOne website as you use access and use the platform. Certain aspects and features of our Services and Website are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Website and Services may be limited or not possible.

IS YOUR PERSONAL INFORMATION PROTECTED?

We understand that you care about how your personal information is used and shared, and we take your privacy seriously. Whilst our primary objective is to provide you with exceptional services, we also recognize that you may have questions or concerns regarding your personal information and how it will be used.

Whilst we will continue to strive to ensure security on our systems, we cannot guarantee that security breaches will not occur or Personal Information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards.

Accordingly, we are not responsible for the matters, which include actions of hackers and other unauthorized third parties that breach our reasonable security procedure. No method of electronic transmission or storage is 100% secure. Therefore, we do not guarantee absolute security of your Personal Information. However, we have put in place industry best practices to protect your Personal Information.

In order to protect your personal data, we maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorized.

If we learn of a system’s security breach, we may attempt to notify you electronically so that you can take appropriate protective steps.

Can Minors Use Our Services?

The services on the Website are not directed to anyone under the age of 18. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use the Website. If we obtain actual knowledge that we have collected Personal Data from a person under the age of 18, we reserve the right to delete it, unless we are legally obligated to retain such data.

IP Address and traffic data

We keep a record of traffic data which is logged automatically by our servers, such as your Internet Protocol (IP) address, device information, the website that you visited before ours and the website you visit after leavingthe Website. We also collect some website, and service statistics such as access rates, page hits and page views. We are not able to identify any individual from traffic data or statistics.

How long do we keep your Personal Data?

We will only keep your personal data for the following period:

· as long as we need it to deliver the services requested by you (including provision of information you have requested); or

· in order to comply with any legal or regulatory requirements.

Information Update

You must notify us of any change in your Personal Information by updating your account profile through our Services. Any changes will affect only future uses of your Personal Information. Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information. Otherwise, we will hold your Personal Information for as long as we believe it will help us achieve our objectives as detailed in this Privacy Policy.

Your rights under this Policy

Under the Nigerian Data Protection Regulation, in certain circumstances you have the following rights:

· the right to be told how we use your information and obtain access to your information;

· the right to have your information rectified or erased or place restrictions on processing your information;

· the right to object to the processing of your information e.g. for direct marketing purposes or where the processing is based on our legitimate interests;

· the right to give and withdraw consent to the processing of your personal information. We may however be unable to provide some services that you may request unless your consent to process your personal Data is obtained.

Links to Other Sites

· Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

· We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. You should note the privacy policy, terms of use and security practices of the linked third-party website before providing any information on that website.

Changes to This Privacy Statement.

· We may revise this Privacy Statement from time to time to reflect changes to our business, the Website or Services, or applicable laws. The revised Privacy Statement will be effective as of the published effective date.

· If the revised version includes a substantial change, we may provide you with 10 days’ prior notice by posting notice of the change our website or notify Users of the change using email or other means.

· Your continued use of the Platform after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

Contact Us

If you would like more information on our Privacy Policy, your rights, or want to exercise them, please contact us via cafeone@sterling.ng