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Our Data Policy
Effective: October 17, 2023
Introduction

The Browpay data policy, (the "Agreement") are the set out provisions of adopted statutory data processing and data usage regulations as governed by the Nigeria Information Technology Development Agency (NITDA) and the Nigeria Data Protection Regulation (NDPR) Act 2019 in extension of the Global Data Protection Regulation (GDPR), implemented in compliance towards safeguarding your personal and financial information on Browpay.

By using Browpay, the Browpay Software and the Browpay Application Programming Interface (APIs), you consent to the practices described in this Data Policy.

Do not use Browpay if you do disagree with any of the provisions of this Data policy.

Definitions
  • Data: Data refers to any information, whether it's in digital or physical form, that is collected, stored, or processed by Browpay. This information can encompass a wide range of details, including customer information, transaction records, and any other information related to our services.
  • Data Protection Laws: Data Protection Laws are legal regulations and requirements that govern how personal data is collected, used, and protected. In our context, this includes laws such as the Nigeria Data Protection Regulation (NDPR) Act 2019 and subsequent amendments.
  • Data Subject: Data subjects are individuals whose personal data we collect and process. These individuals are often our customers or potential customers, and they have rights regarding the use and protection of their data.
  • Personal Data: Personal data refers to any information that can be used to identify an individual. This includes names, contact information, financial information, and any other data that can directly or indirectly identify a person.
  • Processing and Process: Processing refers to any operation or set of operations performed on personal data, whether automated or not. This can include collecting, recording, organizing, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing, transmitting, and more.
  • Processor: A processor is an entity that processes personal data on behalf of the the Data Controller (Browpay Technologies Limited). This may include third-party service providers or any other organization that assists in data processing.
  • Controller: the organization or entity that determines the purposes and means of processing and collecting personal data.
  • Security Incident: A security incident is any event that compromises the confidentiality, integrity, or availability of personal data. This can include data breaches, unauthorized access, or any other incident that might put data at risk.
  • Security Measures: Security measures are the safeguards and practices we implement to protect personal data. This includes encryption, access controls, regular security audits, and other measures to ensure the security and integrity of the data we handle.
  • Sub-processor: A sub-processor is a third-party entity that the processor (our organization) engages to assist in data processing activities. They must also adhere to data protection laws and comply with our data policies.

    • We are commited to complying with data protection laws and the security measures in place to safeguard personal data and by inference require that you understand how your data is being handled.

    Provisions

    In fulfilment of this this provision, the data processor shall:

  • Implement appropriate technical and organizational measures to ensure the security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.
  • Ensure that data processing is bound by a duty of confidentiality.
  • Assist the data controller in facilitating data subject rights, including the right of access, rectification, restriction of processing, data portability, and objections to processing.
  • not transfer personal data to another entity or party without the prior written consent of the data controller, and only when adequate data protection safeguards are in place.
  • Cooperate with the data controller in their efforts to demonstrate compliance with data protection regulations and to respond to requests and inquiries from data subjects and regulatory authorities.
  • Maintain records of all data processing activities carried out on behalf of the data controller. These records should be available for inspection by the data controller and relevant regulatory authorities.

    • In the bid that the Processor fulfils the obligations under this Agreement, the Controller shall:

  • Ensure that all data processing activities are carried out in compliance with relevant data protection laws, including the NDPR and NITDA.
  • Define the specific and legitimate purposes for which personal data is collected and processed. Data should not be used for any other purpose incompatible with the original intent.
  • Obtain in clear, informed, and unambiguous consent from users before processing their personal data.
  • Only collect and process personal data that is necessary for the specified purposes, ensuring that the data collected is relevant and limited to what is required.
  • Be accountable for data protection compliance within the organization and cooperate with regulatory authorities in case of inquiries or investigations.
  • Provide data subjects with clear and accessible information about how their data is processed, including data collection, storage, and use.
  • be responsible for maintaining the security of accounts, passwords (including but not limited to administrative and user passwords) and files, and for all uses of the Controller’s accounts with or without the Controller’s knowledge or consent.
  • Implement appropriate security measures to protect personal data from unauthorized access, disclosure, alteration, or destruction. This includes encryption, access controls, backup copies and regular security assessments.
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