Pagatech Limited (“Pagatech”, “Paga”, the “Company”, or “we” or “us”) values your Personal Data and we are committed to protecting your privacy whenever you interact with us. Please read this Privacy Notice (the “Notice”) to understand our policies, processes, and procedures regarding the processing of your personal data.

By this Notice, we explain to you how your Personal Data is collected, used, managed, transferred and or deleted by Pagatech and also explain how you can update your Personal Data with us and exercise your rights in respect of the Personal Data provided to us.

To access the Paga Services and for optimal use of the Paga mobile application/website, we collect personally identifiable Information which you voluntarily provide to us.

Personally identifiable information refers to the personal information you submit, when you sign up or any information that can be used to identify or contact you (e.g. email address, password, name, address, telephone number, business name, camera sensor data, selfie image, facial ID, bank details, and other unique identifiers including but not limited to MAC address, IP address, IMEI number, IMSI number, SIM and others). For ease of transacting, we may also collect your contact details, only if your permission to do so is granted.

For face recognition and liveliness check, we capture a three-dimensional map of your face and analyze your facial expressions. This face data is processed in real time to confirm your identity and to ensure that the selfie being taken is of a live user.

We also collect non-personally identifiable information including but not limited to dynamic IP address, geolocation data, screen size and cookies data. We use technical methods to collect and store personal information such as cookies, JWT, web beacons etc. We will not share or disclose this information with third parties except as a necessary part of providing our users with access to our website and services. By visiting and using our website, you agree to our use of cookies in line with Pagatech's policies.

We may request permission to access your contacts in your phonebook on your mobile device to enable you to sync your contacts and list them as beneficiaries on the Paga mobile application. You can manage access to your contact list through the application settings at any time.

• - provide our services and supporting customer support
• - profile Paga users and administer Paga pre-paid accounts
• - resolve disputes, collect fees and troubleshoot problems
• - prevent potentially prohibited or illegal activities and enforce our User Agreement
• - customise, measure and improve our services
• - customise and improve the layout of our website
• - compare information for accuracy and verify with third parties
• - update our databases and provide user support
• - provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about.
• - authenticate your identity and prevent unauthorized access and fraud. The biometric/ face data collected is solely used for this purpose. We do not use this data for any other purpose. The information is processed in a manner that is secure and in compliance with applicable laws and regulations concerning biometric data.

Where processing of Personal Data is based on consent, Pagatech shall obtain the requisite consent at the time of collection of the Personal Data. In this regard, you consent to the processing of your Personal Data when you access our platforms, or use our services, content, features, technologies, or functions offered on our website or other digital platforms. You can withdraw your consent at any time, but such withdrawal will not affect the processing of your data which we carried out lawfully based on consent given before your withdrawal.

We may retrieve Personal Information about you from third parties and other identification/verification services such as your financial Institution, payment processor and verification services. With your consent, we may also collect additional Personal Information in other ways including emails, surveys, and other forms of communication. Once you begin using our services through your Paga account, we will keep records of your transactions and collect information of your other activities related to our services. We will not share or disclose your Personal Information with a third party without your consent. We will not use your information or seek your consent to use your information for the propagation of atrocities, hate, child rights violation, criminal acts and anti-social conducts.

Pagatech assures you that it shall only obtain your data with your consent and that your data shall only be used for the purpose for which it was obtained. However, we may share your Personal Data with companies within the Pagatech group, and service providers engaged by us to provide services to Pagatech subject to appropriate data security and protection. In addition, we may transfer your Personal Data out of Nigeria in line with the requirements of the Nigeria Data Protection Act, 2023. Paga shall also share your Personal Data with third parties directly authorized by you to receive Personal Information, such as when you authorize a third-party service provider to access your account. The use of your personal information by an authorized third party shall be subject to the privacy policy of the third-party and Paga shall not bear any liability for any breach which might arise due to your authorization. Paga shall also share your Personal Information if it is believed that such sharing is required to satisfy any applicable laws, regulation or government request.

Our website may contain third-party links or links to other websites. Please be advised that we are not responsible for the privacy practices or contents of these sites and shall not be responsible for your use of such websites. We encourage our users to be aware of when they leave our website and to read the privacy statements of these sites. You should evaluate the security and trustworthiness of any other site connected to this site or accessed through this site before disclosing any personal information to them. Paga will not accept any responsibility for any loss or damage in whatever manner resulting from your disclosure of your personal information to third parties. However, Paga shall also make all reasonable efforts to ensure that adequate safeguards have been put in place to prevent unauthorized access and to ensure confidentiality of your personal information.

You acknowledge that by using the Paga services, some of your personal information will be passed on to any person whom you receive Paga money from, or send Paga money to, and will be available to any third party involved in the operation of the service including without limitation, Paga Agents and partner banks.

• a) request for and access your Personal Data collected and stored by Pagatech;
• b) withdraw consent at any time. For example, you can withdraw your consent to receipt of our marketing or promotional materials or unsubscribe to our newsletters;
• c) object to automated decision making;
• d) request rectification and modification of Personal Data kept by Pagatech;
• e) request for deletion of your Personal and Face Data;
• f) be informed of and entitled to provide consent prior to the processing of Personal Data for purposes other than that for which the Personal Data were collected;
• g) request that Pagatech restricts processing of your Personal Data; and
• h) request for information regarding any specific processing of your personal data.

You may exercise any of these rights by sending an email to service@paga.com where your requests will be treated promptly.

You accept that Paga shall have the right to monitor your account usage and if required, will disclose personal information to local enforcement or investigative agencies or any competent regulatory or governmental agencies to assist in the prevention, detection or prosecution of money laundering activities, fraud or criminal activities.

Paga employees who handle personal information are under an obligation to treat it confidentially and may not disclose it to third parties. Paga employees are also responsible for the internal security of the information. Employees who violate Paga’s privacy policies are subject to the company’s disciplinary procedures.

Any person submitting information to Paga through our platform may be granted access rights to that information. Paga has developed systems that enable users to access and correct their personal information submitted to it. Paga is committed to ensuring that personal data processed by the company is accurate and up to date in line with the provisions of the Nigeria Data Protection Regulation (NDPR) 2019. In order to ensure that your personal data with the company is current, complete and accurate, please update us if there are changes to your personal information by informing the company?s DPO via the stated contact details or the Human Resources Unit. We shall take it that your records with the company is current, complete and accurate if we do not receive any update from you.

Paga may at any time amend, delete or add to its Privacy Policy by giving notice of such changes or posting a revised version of our Privacy Policy on Paga?s online portals. Any change will be made unilaterally by us and you will have been deemed to have accepted these changes by your continuous use of Paga?s services after the revised Privacy Policy is uploaded. You further agree that it is your sole responsibility to check for updates of the Privacy Policy.

If you have a Paga Account, Paga will give you 1 month notice of any changes, with the changes taking effect once the 1-month notice period has elapsed. The 1-month notice period will not apply where a change relates to the addition of a new service, extra functionality to any existing services or any other change which we believe in our reasonable opinion to neither reduce your rights nor increase your responsibilities. In such instances, the change will be made without prior notice to you and shall be effective immediately upon giving notice of it.

If you do not accept any change, you will be required to close your Paga prepaid account, otherwise you will be deemed to have accepted it. Any closure of account still renders you liable to Paga for any liability incurred by you prior to closure.

Should you send us correspondence including chats, calls, emails and letters, we will retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from Paga to you. The rationale for this retention is to keep records of our relationship, measure and improve customer service and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.

From time to time, Paga may offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users' interests and needs. The use of information collected will be explained in detail in the survey itself. If we collect personal identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.

Paga is committed to managing customer information with the highest standards of information security. We protect your personal information using physical, technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. We use computer safeguard such as firewalls and data encryption, enforce physical access to our buildings and files and only authorise access to personal information to only employees who require it to fulfil their job responsibilities.

The security of your Paga prepaid account also rests on the protection of your PIN. You should not share your PIN with anyone and no employee of Paga will ever ask you for either of these so any email or correspondence requesting for such information should be treated as unauthorised and suspicious and forwarded to info@pagatech.com. We will endeavor to respond to such emails as soon as possible.

Should you share your PIN with any third parties, such third parties will have access to your account and your personal information, and you may be responsible for any actions taken using this information. In the event you suspect a third party has gained access to your PIN, please log into your Paga profile, change it and notify us straightaway.

Paga takes appropriate measures to ensure that your Personal Data (i.e email address, password, name, address, telephone number, business name, camera sensor data, selfie image, facial ID, bank details, and other unique identifiers including but not limited to MAC address, IP address, IMEI number, IMSI number, SIM and others) is only processed and retained for a period in line with the purposes set out in this Notice, as is stated under our Terms and Conditions or as required by applicable laws, until a time it is no longer required or has no use. We will also determine what action is to be carried out after period stated in policies expired.

The security of your Paga prepaid account also rests on the protection of your PIN. You should not share your PIN with anyone and no employee of Paga will ever ask you for either of these so any email or correspondence requesting for such information should be treated as unauthorised and suspicious and forwarded to info@pagatech.com. We will endeavor to respond to such emails as soon as possible.

All personal information, (including imported contact information) you provide to us or give us access to is stored on our secure servers as well as secure physical locations and cloud infrastructure (where applicable) for the purposes of providing seamless services to you, including but not limited to business continuity. The data we collect from you may be transferred to or stored in cloud locations at globally accepted vendors? data center. Whenever your information is transferred to other locations, we will take all necessary steps to ensure that your data is handled securely and in accordance with this privacy policy.

Paga is responsible for ensuring that our day-to-day procedures are aligned with this Privacy Policy. Should you have any questions about this privacy statement, Paga's information services or your transactions on Paga, you can contact us via our customer help lines or by email to rmc@paga.com.