We’re Pava Technologies Ltd (‘we’, ‘our’, ‘us’) and operate under the name Pava. We’re registered with the Corporate Affairs Commission with the number RC7442643.
This policy describes what information we collect about you, how we collect and use the information you share with us, and with whom we share that information. You don’t have to share any information with us, but to use our services, we’ll need some information from you. This policy also contains information about when we share your personal information with third parties (such as our service providers).
Lawful basis for processing your data
Depending on the circumstances of our interactions with you, our legal basis for processing your personal data may be one of the following:
• For the performance of a contract, we have or are about to enter with you;
• Based on your consent; or
• For our legitimate business interest or that of a third party.
Consent
You give your consent to our processing of your personal data when you access our platforms or, when you accept our cookies policy; or in particular, as you use the services offered on our website and digital platforms or visit any of our offices and submit your data for official or non-official purposes.
What Personal Data do we collect?
We collect Personal Data about you when you use the services offered on our website and digital platform, including the following:
Sign-up information: When you register to use the services offered on our digital platform, we will collect Personal Data as necessary to offer and provide the service you request. Depending on the service you choose, in line with regulatory requirements for Know Your Customer (KYC) purposes, we may require that you provide us with your name, age, gender, birthday, facial photo, residential address, ID information (photo, number), utility bill, email address, mobile number to create an account. We will also require your NIN and/or your BVN in line with regulation and in furtherance of our KYC computation processes. We may also require you to provide additional, necessary personal details as you use our services.
Transaction information: When you use our digital platform to send and receive money, make purchases from merchants, pay bills & deposit, we collect information about the transaction, as well as other associated information as necessary to offer and fulfil the service (like transaction receipt, account statement) that we are obliged to; such as: the amount sent or received, amount paid for products or services, merchant information – including information about your device and geolocation.
Participant Personal Data: When you use our services, we may collect Personal Data about the other participants associated with the transaction, including your phone contacts with your consent, so you can easily transact with your friends and contacts and enable instant messaging (IM). We collect Personal Data such as name and financial account information about the participant who is receiving money from (or sending money to) you, when you send or receive money through the Services.
Image Information: We may collect your image (upload, storage, and use) information to support account opening, such as uploading your portrait. We may also collect information from your images when you use our customer support to upload evidence such as statements and checks. In addition, we may collect your image information in connection with regulatory KYC purposes. When you visit any of our offices as well, our CCTV cameras may also process your images.
Information from other sources: We may collect information from other sources, such as our social media platforms when you reach out to us to lodge a complaint about our services. However, we will only ask for information relevant to the help required of us to you. In addition, we also indirectly collect information from NIBSS, credit bureaus, NIMC, or other third-party KYC verification service providers.
Other information we collect related to your use of our website or Services: We may collect additional information from or about you when you communicate with us, contact our customer support teams, respond to a survey or use functionality offered by third-party service providers through our Platform. For instance, when you initiate third-party applications through the Pava mobile application, with your prior consent, your SMS may be collected and monitored to help third-party service providers reduce risks associated with your application through the relevant model/system to provide customized services.
When you apply for a job with us: We may request Personal Data about your education, employment and state of health. As part of your application, you will be asked to provide your express consent to our use of this information to assess your application and any monitoring activities which may be required of us under applicable laws as an employer. We may also carry out screening checks (including reference, background and criminal record checks). We may exchange your Personal Data with academic institutions, recruiters, health maintenance organisations, law enforcement agencies, referees and your previous employers. Without your Personal Data, we may not be able to process your application for positions with us.
We do not collect the information of minors: If you are under the age of 18, you are not eligible to use the service offered on our digital platform.
How do we use your information?
The Nigerian Data Protection Regulations 2019 (NDPR) requires that we have a lawful basis for processing your personal information. At least one of the following lawful basis must apply before we process your personal information: contractual or legal obligations, legitimate interest of the data controller, public interest, vital interest of the data subject or consent.
Contractual Obligation
We collect certain data from you to fulfill the contract we have with you, or to enter into a contract with you. We use this data to:
Give you the services we agreed to in line with our terms and conditions.
Send you messages about your account and other services you use if you get in touch, or we need to tell you about something..
Exercise our rights under contracts we’ve entered into with you, like managing, collecting and recovering money you owe us.
Investigate and resolve complaints and other issues.
Legal Duty
We have to ensure we aren’t breaking any laws by banking you by preventing illegal activities like money laundering, terrorism financing and fraud. To do this, we need your data to;
Confirm your identity when you sign up or get in touch.
Prevent illegal activities like money laundering, tax evasion and fraud.
Keep records of information we hold about you in line with legal requirements.
Adhere to banking laws and regulations (these mean we sometimes need to share customer details with regulators, tax authorities, law enforcement or other third parties).
Legitimate Interest of the data controller
In some instances, we need to use the data you supply us for our legitimate interests. This means we’re using your data in a way that you might expect us to, for a reason which is in your interest and doesn't override your privacy, interests or fundamental rights and freedoms.
Consent
For certain information, we’ll ask for your consent. We’ll ask for your consent to:
Market and communicate our products and services. You can always unsubscribe from receiving these if you want to;
Help protect you against fraud by tracking the location of your phone if you’ve authorised it;
View your contact list for airtime purchases.
Who do we share your information with?
In some instances, we will share the information provided with some third parties that we do business with, like card producers and credit bureaus, or with law enforcement agencies when required. Sharing of confidential customer information with these related third parties would be done in a secure manner.
How long do we keep your data?
We keep your information as long as you are a Pava customer and for any additional period as required under applicable law or regulations.
These retention requirements supersede any right to erasure requests under applicable data protection laws. We cannot therefore erase your data in relation to your Pava Account until after this time period, however we can assure you that your data will be held safely and securely whilst under our supervision.
When do we delete your data?
We are basically storing and processing your personal data only as long as it is necessary to perform our obligations under the agreement with you or as long as the law requires us to store it.
That means, if the data is not required anymore for statutory or contractual obligations, your data will be deleted.
If you choose to delete your Pava account, we will delete any data you have previously given us, including the picture of your face uploaded during the liveness check. However this is subject to the retention regulations that apply to such data as stipulated by the regulators.
What are your rights?
You have the right to access and request the information that we have on you in our records. You may also ask us to delete your information on our record, restrict the way in which we use your personal information, ask that we update the personal information we hold about you or correct such personal information which you think is incorrect or incomplete, and we will grant this request as long as we’re legally allowed to. You also have the right to object to us using your information for our marketing purposes or any additional services we may be offering you. Lastly, you may also withdraw any consent you’ve previously given us.
How to make a complaint
At Pava, we’re extremely committed to respecting and protecting your personal information. If you have any worries, reservations or complaints about your personal information, please contact our Data Protection Officer by:
Sending a message via the app
Emailing us at dpo@joinpava.com
Writing to us at 55 Burrow Pit Rd, Okpanam, Delta
We will do our best to fix the problem.
Changes to this document
This document will be reviewed on a yearly basis, or more frequently if occasioned by changes or amendment to applicable data protection regulations. If we make any changes, we’ll add a note to this page and if there are significant changes we’ll let you know by email.
This policy was last updated on October 08, 2024.