Privacy Policy

About Us

Welcome to Stereo Technology Limited’s (“Stereo Pay”) Privacy Policy. Stereo Technology Limited is a Limited Liability Company, incorporated under the Laws of the Federal Republic of Nigeria, with RC: 1885480 and address at 2 Tom Ogboi Aveneue, Denike Court, Lekki Phase 1, Lagos, Nigeria. Stereo Pay is responsible for this Website or Mobile Application.

We have appointed a Data Protection Officer (“DPO”) to oversee the implementation of this Privacy Policy. If you have any questions or complaints about this Privacy Policy or need to exercise your legal rights, please contact the DPO using the details below:

Stereo Technology Limited

[Email address]: support@stereopay.co
[Postal address]: 2 Tom Ogboi Aveneue, Denike Court, Lekki Phase 1, Lagos, Nigeria
[Telephone number]: +234 810 576 4324

Your Privacy Rights

At Stereo Pay, we respect your privacy rights, and we are committed to protecting your personal data.

This Privacy Policy (together with our Terms of Use) describes how Stereo Pay and/or its affiliates collect, use, store, share, and protect your personal data when you visit our Websites or use our Mobile Applications.

Consent

You accept this Privacy Policy when you sign up for access or use the products, services, content, features, technologies, or functions offered on Stereo Pay’s Websites, Mobile Applications, and all related sites, applications, and services.

The Personal Data We Collect Directly from You

Stereo Pay and/or its Affiliates collect Personal Data from you when you visit our Websites or use our Mobile Applications. The type of information we collect from you depends on your interaction with the Website or Mobile Application. We may collect, use, store, and transfer different kinds of personal data about you which we have grouped, as follows:

  • Account Data includes your Stereo Pay ID, and related account details including, but not limited to email address, registered devices, account status, and age.
  • Identity Data includes your name, Stereo Pay ID or similar identifier, title, and gender.
  • Profile Data includes your Stereo Pay ID, password, purchases, or orders made by you, your interests, preferences, feedback, and responses to surveys.
  • Contact Data includes your name, email address, physical address, and telephone numbers.
  • Bank or Financial Data includes your billing address, method of payment, account, and payment card details.
  • Content Data includes the content, communications, and other information you provide when you use our Websites or Mobile Applications including when you sign up for an account, create or share content, and message or communicate with others. This can include data in or about the content you provide such as audio and visual content and texts.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type, and version, time zone setting and location, browser plug-in types, and versions, operating system and platform, and other technology on the devices you use to access our Websites or Mobile Applications.
  • Usage Data includes information about how you use our Websites, Mobile Applications, products, and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Other Data includes details of the content of your communications with Stereo Pay

If you choose to purchase or subscribe to a product or service through our Website or Mobile Application, we may collect your financial data. Currently, we use third-party service providers to process your card transactions on our behalf. The third-party service providers will collect your identity data, bank, or financial data in accordance with the provisions of a written contract between Stereo Pay /its affiliates and the third party. We will be verifying your bank or financial data and by your use of our Websites or Mobile Applications, you consent to the validation of your bank or financial details.

We will only collect personal data that is necessary for the provision of the product or service that you have subscribed to.

Automated Processing

Stereo Pay/its affiliates may engage in activities that involve the automated processing and/or profiling of your personal data. This type of processing will be carried out under lawful basis.

You can contact us to request that we provide you with information about the basis for processing and that automated processing be reviewed by a human being if you detect any inaccuracies in your personal data.

How We Use Your Personal Data

We will only use your personal data when we have a valid legal basis to do so. We will use your personal data in the following circumstances:

  • Where you have consented to it, or where it is necessary to perform a contract, we are about to enter or have entered with you.
  • Where it is necessary for our legitimate interests (or those of a third party), taking into consideration your interests and rights.
  • Where we need to protect your vital interests or those of other persons.
  • Where we need to comply with a legal obligation.
  • Where we need to perform a task in the interest of the public.

If you have questions about the legal basis, you can contact the DPO whose contact information has been provided above.

Purposes for Which We Will Use Your Personal Data

We will use your personal data to provide you with our products and services, to process your transactions, to communicate with you, for security, to prevent fraud, and to comply with the applicable law. We may use your personal data to:

  • Install our Mobile Applications and register you as a new Website or Mobile Application User.
  • Administer our products and services to you.
  • Facilitate your activities on our Websites and Mobile Applications.
  • Identify and authenticate you when you log on to our Websites or Mobile Applications.
  • Process your transactions such as in-App purchases and deliver products and services including managing payments and collecting money owed to us.
  • Communicate with you including responding to your queries, comments, and feedback, and notify you about changes to your subscriptions or products and services.
  • Manage our relationship with you.
  • Comply with legal and/or regulatory obligations.
  • Provide you with personalized products and services.
  • Identify and investigate fraudulent or illegal activities.
  • In line with your communication preference and as permitted by law, deliver marketing communications, and content to you, and make recommendations to you about goods or services which may interest you including products and services offered by third parties.
  • To monitor trends and improve our Websites or Mobile Applications, products, and services.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or to perform a contract we are about to enter or have entered with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with our products or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

Cookies

We may use cookies to improve your experience on our Websites or Mobile Applications. Cookies are small files, often encrypted, are used to identify your computer as you use a computer network.

Cookies allow our Websites and Mobile Applications to store your preferences to present you with personalized contents, options, or functions.

If you do not want cookies, you can disable or refuse them. If you disable or refuse cookies, please note that some parts of our Websites or Mobile Applications may become inaccessible or not function properly.

Third-Party Links

Our Websites and Mobile Applications may include links to third-party websites, plug-ins, products, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Please note that we do not control these sites or applications and are not responsible for the Privacy Policies or the content of these sites. Stereo Pay will not be liable for any breach resulting from your disclosure of your personal data to such third parties. When you leave our Websites or Applications, we encourage you to read the privacy policy of every website or application you visit.

Change of Purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data Security

We take the security of your personal data very seriously and we have put in place appropriate administrative, technical, and physical security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed.

We limit access to your personal data to those staff, agents, affiliates, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We regularly update our security controls and processes to help keep your personal data secure. We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

You have an obligation to keep your personal data secure. If you have chosen or have been provided with a password to access specific areas of our Websites or Mobile Applications, we recommend that you maintain (a)a unique password(s) and do not share your password(s) or other authentication details with anyone.

Disclosure of your Personal Data

We may share your personal data with our staff, agents, affiliates, contractors, strategic partners, external auditors, service providers, regulators/supervisors, government agencies/courts where necessary by law, and/or requests from public and governmental authorities within or outside your country of residence, to disclose your personal data. We may also disclose your personal data if we determine that disclosure is necessary for purposes of national security or other issues of public importance.

We may assign our rights and obligations under this Privacy Policy to an affiliate or successor entity and your personal data may be among the assets transferred by Stereo Pay.

We may share your personal data with third parties to whom we may choose to sell, merge, or transfer our business or part of our business or assets or any other successor entity or a third party whom we may choose to acquire their business. In the event of a change in the ownership of our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy and you acknowledge and consent that such disclosures and transfers may occur and are permitted by this Privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Our Users

We respect the privacy of children and we do not knowingly collect the personal data of children. Our services are not directed to children, and you may not use our services if you are under the age of 18. You must also be old enough to consent to the processing of your personal data in your country (in some countries we may allow your parent or guardian to do so on your behalf)

Advertisements and Other Sponsored Content

We may sometimes use your personal data to select and personalise ads, offers and other sponsored content that we think will be relevant to your interests. If you would like to modify the information, we and our advertising partners use to select these ads, please contact us.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

We will hold your personal data securely and only retain it for as long as reasonably necessary to fulfil the purposes we collected it for unless you have provided us with your consent to use the data for any additional purposes.

We may retain your personal data to satisfy any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation concerning our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements, any time limits for making a claim, any relevant proceedings that may apply, our legitimate interest as a business and any period for retaining your personal data as set by law or recommended by relevant regulators, professional bodies or associations or in line with best practice.

Personal data which is not retained is securely destroyed.

International Transfers

We may need to transfer your personal data to Stereo Pay affiliated entities or other third-party entities for processing activities such as those described in this Privacy Policy in connection with your use of our products and services.

Whenever we make such a transfer of your personal data out of Nigeria, we will ensure a similar degree of protection is afforded to it and if appropriate, put in place such a contract that imposes obligations on such entity to protect your personal information.

Please contact us if you need further information on the specific mechanism we use when transferring your personal data out of Nigeria.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. At any time, you can do any of the following by contacting us:

  • Request access to your personal data.
  • Request correction of your personal data after providing the required documentation and if it is within your purview to correct it.
  • If allowable, request the deletion of your personal data. We may continue to retain such data if there are valid legal, regulatory, or operational reasons.
  • Request for the purpose and legal basis for processing your personal data.
  • Request for the duration of data retention.
  • Restrict or object to the processing of your personal data. We might continue to process your data if there are valid legal or operational reasons.
  • Request that an electronic copy of your personal data is made available to you or transferred to a third party.
  • Withdraw consent for processing personal data where consent has been previously given.
  • Request for details of automated decision-making.
  • Request for recipients or categories of recipients that the data is/will be disclosed to.

If you wish to exercise any of the rights set out above, please contact our DPO, support@stereopay.co

You will not be required to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

As part of our security measures to ensure that your personal data is not disclosed to any person who has no right to receive it, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. If we ascertain that it will take us longer than a month particularly if your request is complex or you have made a number of requests, we will notify you and keep you updated. We may also contact you to ask you for further information in relation to your request to speed up our response.

Changes to the Privacy Policy and your Duty to Inform Us

We keep our Privacy Policy under regular review and may amend this Privacy Policy at any time by posting a revised version on our Websites, or Mobile Applications, placing such notice at conspicuous points at our office facilities. The revised version will be effective 7-days after publication.

We understand that your personal data may change during our relationship. It is important that the personal data we hold about you is accurate and current, and we request that you please inform us of any such changes to your personal data.

Language

This Privacy Policy and the contents of our Websites or Mobile Applications are available in English.

Governing Law and Jurisdiction

The laws of the Federal Republic of Nigeria will govern all matters relating to this Privacy Policy and the use, or inability to use our Websites or Mobile Applications, and shall apply without regard to the principles of conflict of laws. By accessing the products and services on our Websites or Mobile Applications, you agree to submit to the exclusive jurisdiction and venue of the Courts in the Federal Republic of Nigeria. This shall be without prejudice to Stereo Pay’s right to seek recourse in any jurisdiction worldwide to restrain the unlawful use of our Websites or Mobile Applications or any material contained in the Websites or Mobile Applications.

Remedies for Breach of this Privacy Policy

Any party who is found to be in breach of this Privacy Policy shall be liable to the penalties provided in the Nigerian Data Protection Regulation.

Contact Stereo Pay

If you have questions, comments, requests, and feedback regarding this Privacy Policy or would like to contact our Data Protection Officer, or would like to submit a complaint, kindly contact our Data Protection Officer at: support@stereopay.co

We take your privacy concerns seriously. Our team will review your query, comments, or feedback and endeavour to respond within 14 days[MOU4]. In cases where we may require additional information or need more time to respond, we will notify you.

If you are not satisfied with Stereo Pay’s response, you may refer your complaint to the National Information Technology Development Agency (“NITDA”), the Nigerian regulator for data privacy issues.