Date Updated: [27th July 2021]
The App/Site (i) provides an online digital ledger book/record book wherein the Users, can record their ledger entries with their respective customers and (ii) also allows users to generate a payment link which can be sent to their respective customers and the customers could use the payment link and make the payment of the amount to the Users in settlement of their obligations towards the Users (collectively, “Services”). Please note that ‘Services’ would include any other future services we may provide or propose to provide.
As we update, improve and expand the Kippa App Service, this Policy may change, so please refer back to it periodically. By accessing the Site, App or otherwise using the Kippa App Services, you consent to the collection, storage, and use of the personal information you provide (including any changes thereto as provided by you) for any of the services that we offer.
We respect the privacy of the users of the Kippa App Services (“Users” or “you”) and are committed to reasonably protect it in all respects. The information about the User as collected by us is: (a) information supplied by Users and (b) information automatically tracked while using a mobile device having Kippa App Services enabled (collectively referred to as “Information”). By using Kippa App Services, you agree to this Policy. If you do not agree with any term in this Policy, please do not use / avail of the Kippa App Services.
Information supplied by users
To provide certain Services on the Kippa App, Users are required to provide certain personal information for the registration process which may include: a) their name, b) email address, c) phone number, d) business entity information, (e) account number of the Users, (f) KYC details and any other such information as required. The Information as supplied by the Users enables us to provide the Services and improve the Kippa App Services and provide you the most user-friendly experience. In some cases / provision of certain service(s) or utility(ies), we may require your contact address as well. Further, upon downloading the App, Users are requested to share access to their contact list (as stored on their mobile device on which the App is downloaded), so as to enable the User to share payment/credit updates with his customers (who might be or might not be Users).
We may access a users inventory of installed apps and treat this data as personal or sensitive data subject to this Policy, secure transmission, and prominent disclosure requirements of User.
All Information is service-dependent and we may use the Information to provide the Services, maintain, protect, and improve the Kippa App Services, and for developing new services.
We may also use your email address and phone number without further consent for marketing, non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, providing information about updates to Kippa App Services, billing, etc.).
Any Information provided by you will not be considered as personal information if it is freely available and/or accessible in the public domain or is not deemed as personal information under the applicable law. Further, any reviews, comments, messages, blogs posted/uploaded/conveyed/communicated by Users on the public sections of the Site or an application store (like the App Store or Play Store) becomes published content and is not considered as personal information which is subject to this Policy.
In case you choose to decline to submit Information on the Kippa App/Site, we may not be able to provide certain services on the App/Site to you. We will make reasonable efforts to notify you of the same at the appropriate time. In any case, we will not be liable and or responsible for the denial of certain services to you due to not receiving necessary Information from you.
When you register with the Kippa App Services, we may (at our discretion) contact you from time to time about updates of your Information.
Information automatically tracked while using the App or Site
Credit/Payment Records: We store all your credit/payment records in a cloud-based environment using the services of third-party infrastructure service providers.
Customer Information: We store the contact information of your customers. We also keep a log of all the credit/payment-related communication to the customers.
Demographic and Related Information: We may reference other sources of demographic and other information in order to provide you with more targeted communications and promotions. We use Google Analytics, among others, to track the User behaviour on Site.
Log File Information: Our servers automatically collect limited Information about your device's connection to the internet, including your IP address, when you visit our Site or use the App. We automatically receive and log Information from the App and/or your browser including but not limited to IP address, your device or computer's name, and your operating system, We may also collect log Information from your device, including but not limited to your location, IP address, your device's name, device's serial number or unique identification number (e.g. UDID on your iOS device, Android ID or ADID on your Android Device), your device operating system, browser type and version, CPU speed, and connection speed etc.
Link to third party sites/ad-servers
The Information (including personal information) collected may be shared with our affiliates, and group companies to the extent required for our internal business and/or administrative purposes and/or general corporate operations and to any third party service providers including marketing partners, and the User hereby consents to the same. We will take reasonable steps to ensure that these third-party service providers are obligated to protect your personal information and are also subject to appropriate confidentiality/non-disclosure obligations and they comply with the applicable provisions of the data protection laws. These entities, with whom we share the Information, may market to you as a result of such sharing unless you explicitly opt-out.
The User explicitly consents that we may have access to your SMS, contacts in your directory, location and device information and we may request you to provide your PAN and Know-Your-Customer (KYC) details to check your eligibility for certain products/services including but not limited to credit and payment products, etc., to enhance your experience and provide you access to the services being offered by us, our affiliates or other third party service providers (including lenders).
By using the Kippa App Services and providing information to us, Users agree and consent to the disclosure, transfer, storage, and processing of the personal information (including the sensitive personal information) by us in Nigeria and / or in other countries to its affiliates, group companies and third parties. While our primary motive is to protect the disclosure of personal information (except in accordance with the provisions of this Policy) of Users, Users may note that countries where their Information may be stored, may not have data protection laws similar to the countries where they are located.
Accessing and updating personal information
When Users use the Site (or any of its sub-sites) / App, we make good faith efforts to provide Users, as and when requested by Users, with access to their Information and shall further ensure that any personal information or sensitive personal data or other information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such personal information or sensitive personal data or information to be retained by law or for legitimate business purposes. We ask individual Users to identify themselves and the Information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning Information residing on backup tapes), or for which access is not otherwise required. In any case, where we provide Information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services, after you delete your Information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
Information storage and backup
From time to time, we take backup of your data on Kippa App on our cloud database. This is done for the purpose of enabling Users to get their data back in case their phone's data becomes unusable, or phone gets lost, or the User moves to a new phone device. We also use this backup to provide useful insights and information related to their spends such as weekly spends in a month, insights related to spend behaviour, etc., and to provide information related to User spends, patterns and User data in the form of aggregated and anonymized statistics on data such as User spends by category, date, time, bank balances, etc.
'We shall keep User’s Information in our records till the period of time where we can potentially offer the Kippa App Services to the Users. After such period of time where Kippa App Services are no more relevant to a User, we remove all the Information pertaining to a particular User from our records.
We take appropriate security measures to protect against unauthorized access to or alteration, disclosure or destruction of data including accidental or intentional manipulation, loss from access by unauthorised parties. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. All Information gathered on the Kippa App is securely stored within the controlled database. Access to the servers is password-protected and is strictly limited.
Our security measures are regularly reviewed and updated to reflect technological developments. Regardless of where your personal information is transferred or stored, we take all steps reasonably necessary to ensure that personal information is kept secure, however, please understand that no transmission of data over the internet or any other public network can be guaranteed to be 100% (one hundred percent) secure.
We seek to ensure compliance with the requirements of the applicable data protection laws to ensure the protection and preservation of the User’s privacy and personal Information. We have physical, electronic, and procedural safeguards that comply with the laws prevalent in specific jurisdiction to protect User’s Personal Information. By accepting the terms of this Policy, you agree that the standards and practices being implemented by us, are reasonable and sufficient for the protection of your personal information.
We will contact you regarding any breach of the security, confidentiality, or integrity of your unencrypted electronically stored Personal Information to you via email or any other feasible manner in the most expedient time possible and without unreasonable delay, insofar as consistent with the legitimate needs of law enforcement and will undertake all measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Purpose of Data Processing
For example, we use your information where we need the Personal Information to perform the contract with you (for example, to provide the Platform or our services to you) so as to:
- Register you on our Platform
- Provide you with customer or technical support including addressing support queries related to, but not limited to, payment processing, or to diagnose any problems with our servers etc.
- Send you transactional emails/SMS or to provide you with information, direct marketing, online and offline advertising and other materials regarding products, services and other offers from time to time in connection with the Kippa Service or its parent, subsidiary and affiliated companies ("Platform Entities") and its joint ventures.
- Determine your geographic location, to provide you localized content including advertisements, personalized recommendations, allow you to continue watching/using previous content at another time, and to determine your Internet service provider to troubleshoot a technical issue, and help us quickly and efficiently respond to inquiries and requests;
- To provide you with a personalized service and experience; we do this by linking some or all of your Personal Information such as transactions done with Kippa with your activity on our Platform across all your devices and associating and storing this information with a unique platform generated identifier that is generated for each user (guest as well as registered user). When a guest user subsequently registers and creates an account, the information and data relating to such user's past activities gets added to and associated to the registered account.
- In other contexts, if the processing of your Personal Information is subject to the EU General Data Protection Regulation, we use your Personal Information where the processing is in our legitimate interests and not overridden by your fundamental rights and freedoms (for example, our direct marketing activities in accordance with your preferences) such as to: Display or target advertisements on the Platform based on your registration or profile information, location and/or your activity on the Platform across all your streaming devices (including inferred information through usage and log data) which is associated with your device advertising identifier – this is typically referred to as 'interest-based advertising'. We also display contextual advertisements on the Platform but these are not targeted to any particular user and does not make use of any information that personally identifies you or precisely locates you (contextual advertising is advertising which we target based on the content being viewed, for example, if you are watching a particular sporting event we may serve adverts of companies or products related to that particular sport or the age-group most likely to be watching).
- Research, analyze and understand our audience and what content and advertising they may view, watch or otherwise engage with, in order to improve our service (including our user interface experiences and security features); evaluate your eligibility for certain types of offers, products, or services and market such products or services to you; to perform analytics and conduct customer research, including general market research or surveying our customers' needs and opinions on specific issues, generating sales and traffic patterns, and to analyze advertising effectiveness, both on an anonymous basis (e.g., by aggregating data) or on an individual basis (if legally permissible), in combination with other information collected from tracking technologies and aggregate it with information collected from other Users using our Platform, to attempt to provide you with the Services and a better experience on the Platform. For example, one of the ways we use this information is to count the number of times an advert or other content is viewed because this might be the metric by which our advertisers pay us. This information is compiled and analyzed on an aggregated basis.
- Allow you to participate in interactive features such as Gameplay events on the Platform, providing you with relevant gameplay experience, determine and declaring winners, and providing you with prizes.
- Analyze and measure how effective our advertising is by determining which media sources should be paid for delivering a desired action e.g. users who install our application or subscribe (also known as 'attribution'), so that we pay for demonstrated value and don't overspend.
We will use your Personal Information with your explicit consent as follows:
- When you agree to share your precise location based on GPS data, we will combine this information with other information that you provide to us on the Kippa Service to provide personalized content and advertisements with better accuracy basis your geographic location e.g. you may see more regional content recommendations or advertisements for local establishments when you share your precise location based on GPS data
- When you agree to share information pertaining to the applications frequently used by you on your device, we will combine this information with other information that you provide to us on the Kippa Service, to display advertisements that are more relevant to your interest areas
Or otherwise whenever the law requires us to get your permission or where we have stated we may seek your permission in this Privacy Notice. In some contexts, we use your Personal Information where we have a legal obligation to do so or to protect your vital interests or those of another person:
- Prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and enforcing our terms (such as determining free trial eligibility);
- Confirming your identity if you are exercising legal rights;
- Carry out our obligations and enforce our rights arising from any contracts entered into between you and us/our distributor.
When you access or use the Services or send any data, query, request or communication to us via our Support email, you understand that you are communicating with us electronically, and that we may respond via electronic means from us, such as by email.
Revocation of consent
A User can revoke his consent to the processing of his personal information at any time with effect for the future. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal information where such collection, use, and disclosure without consent is permitted or required under applicable laws.
Responsible organization for the data collection
All the Kippa App Services are currently provided and regulated by Africave Inc and therefore Africave Inc is responsible for the collection, storage, and processing of personal information of the Users.
In the event you have any grievance relating to the processing of information provided by you, you may contact our Grievance Officer at email@example.com or write to us at the following address:
14 Williams Onoh Drive
Chevyview Estate, Chevron Drive
Lekki, Lagos, Nigeria
In case any personal information is shared by you with us, which is not requested by us during registration, (whether mandatorily or optionally), we will not be liable for any information security breach or disclosure in relation to such information. If you have any questions regarding this Policy or the protection of your personal information, please contact our data protection officer/grievance officer.