Version 1.0 18 May 2025

This privacy policy(“Policy”) applies to the website(s) and mobile application(s) (here interfered to as, the "Sites") provided by Energywallet Services Limited (“Energywallet”, “we”, “us”, “our”), and other products/services of Energywallet . This Policy discloses our data protection practices on our Sites, products and subscriber-based services (“Services”), inclusive of the type of personal data that we collect, our method of collection of personal data, use of personal data and procedures for sharing personal data with third parties. This Privacy Policy between Energywallet and you constitute our commitment to your continued privacy on all our Sites. It is designed to provide information regarding ourprivacy practices and help you understand how we handle your data. We are committed to protecting your personal data (i.e. any information you provide to us through which you can be identified) in accordance with the provisions of the Nigeria Data Protection Act 2023 and other applicable data protection laws (“Data Protection Laws”). By visiting Our Sites, you agree to the terms and conditions of this Privacy Policy. If you do not want your personal data processed in accordance with this Policy, please do not use or access the Sites or the Services.  We reserve the right, at our sole discretion, to alter and update this Policy from time to time. We therefore invite you to review the current version of this Policy each time you return to the Sites. 

‍ELIGIBILITY The Sites and Services are intended solely for persons who, if they are natural persons, are eighteen (18) years of age or older or have a valid NIN, and any registration by, use of or access to the Sites and Services by any natural person under eighteen (18) is unauthorized, unlicensed and in violation of this Policy.  

‍CONSENT By using the Sites, Services and by providing your personal data, you consent to the collection and use of the information you disclose to us in accordance with this Policy, including but not limited to your consent for sharing your personal data inline with the terms contained in this Policy. If we decide to change this Policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it. If you do not agree to give consent to the use of personal data as described in this Policy, please do not use or access the Sites or Services.   

‍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 Sites, we will collect Personal Data as necessary to offer and fulfil the service you request. Depending on the service you choose, we may require that you provide us with your name, email address, mobile number and debit card details to create an account. We may also require you to provide additional, necessary personal details as you use our services. 

‍Transaction information: When you use our Sites to send andreceive money, make purchases from merchants, pay bills, deposit & withdrawcash, we collect information about the transaction, as well as other associatedinformation as necessary to offer and fulfil the service (like transactionreceipt, account statement) that we are obliged to; such as: the amount sent orreceived, amount paid for products or services, merchant information –including information about your device. Time of visit, customer journey on oursite and geolocation. 

‍Participant Personal Data: When you use our services, we maycollect Personal Data about the other participants associated with thetransaction, 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 theparticipant who is receiving money from (or sending money to) you, when yousend 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 uploadevidence such as statements and checks. In addition, we may collect your image information in connection with regulatory KYC (Know Your Customer) purposes. 

‍Information from other sources: We may collect information fromother sources, such as our social media platforms when you reach out to us tolodge a complaint about our services or for other reasons. However, we will only ask for information relevant to the help required of us to you. 

‍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 withus, contact our customer support teams, respond to a survey or usefunctionality offered by third-party service providers through our Platform.For instance, when you initiate third-party applications through EnergyWalletSites, with your prior consent, your SMS may be collected and monitored to helpthird-party service providers reduce risks associated with your application through the relevant model/system to provide customized services. When you apply fora 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 organizations, 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 WE COLLECT INFORMATION We collect information you provide directly to us in all our sites, participate in any interactive features on our Services, fill out a form, take part in surveys, post on our message boards, upload any documentation, request customer support, make an enquiry, communicate with us by email, phone or post, interact with us on social media, etc. We will also collect your information where you partially complete and/or abandon anyinformation inputted in the Sites and may use this information to contact youto remind you to complete any outstanding information. We may also collecttechnical data from third parties/ public sources such as analytics providers,identity verification providers, advertising networks, search informationproviders. We may obtain contact, financial and transaction data from providersof technical, payment, credit referencing and delivery services based bothinside and outside Nigeria. We utilise third-party service providers to secureinformation related to financial crime, fraud, sanctions and politicallyexposed persons. We do not ownpersonal data provided and will only store such data for a period reasonablyneeded and we will do our best to ensure that such personal data is securedagainst all foreseeable hazards and breaches such as theft, cyber-attack, viralattack, unauthorised dissemination, manipulation of any kind, damage by rain,fire or exposure to other natural elements.  We will not sell,share, transfer or rent out any personal information to others in waysdifferent from what is disclosed in this Policy, and our terms and conditionsof use. We may share generic information not linked to any personalidentification information regarding visitors and users with our businesspartners, trusted affiliates and advertisers.  

‍HOW WE USE YOUR PERSONAL DATA The purpose of collecting your personal data is to give you an efficient, enjoyable, secureand seamless customer experience.  

‍We may use your personal data forthe following purposes: To provide the requested Services and support to you;ü  Toprocess transactions and send notices about your transactions to requisiteparties;ü  Toverify your identity; ü  Toresolve disputes and troubleshoot problems;ü  Tomanage risk, detect, prevent, and/or remediate fraud or other potentiallyprohibited or illegal activities;ü  Todetect, prevent or remediate violations of policies or applicable useragreements;ü  Toimprove our services by implementing aggregate customer preferences;ü  Tomanage and protect our information technology infrastructure;ü  Tocontact you at any time through your provided telephone number, email addressor other contact details; ü  Tonotify you about activities on your account, troubleshoot problems with youraccount and collect fees or monies owed; ü  Tomonitor traffic patterns and usage of the Sites to help to improve the Sitesdesign and layout;ü  Torecord and store communications made via phone, skype or the website chatfunction;ü  Topersonalise your experience on our Sites or communications/advertising;ü  Toprovide customer service, including to respond to your enquiries and fulfil anyof your requests for information;ü  Tosend you important information regarding the services and/or other technicalnotices, updates, security alerts, support and administrative messages;ü  Topoll your opinions through surveys or questionnaires; andAs EnergyWalletbelieves to be necessary or appropriate:ü  Tocomply with a legal obligation. This applies where the processing is necessaryfor EnergyWallet to comply with the law;ü  Toenforce or apply this Policy; andü  Toprotect EnergyWallet legitimate interests, privacy, property or safety, and/orthose of a third party as long as your rights do not override those interests.We may monitor andrecord our communications with you, including e-mails and phone conversationsfor training, quality assurance purposes, and to meet our legal and regulatoryobligations in general.  

‍Fraud preventionWe may process yourpersonal data on the basis that we have a legitimate interest to prevent fraudand money laundering, and to verify your identity, in order to protect ourbusiness and to comply with laws that apply to us. Such processing is also acontractual requirement of the services you have requested. We may carry outfraud prevention checks using a fraud prevention database. If false orinaccurate information is provided, and/or fraud is identified, details will bepassed to the Central Bank of Nigeria and the Economic and Financial CrimesCommission. Additionally, law enforcement agencies may access and use thisinformation. 
‍Data analytics and bench-marking We may useinformation generated and stored during your use of our Services for ourlegitimate activities to enable us to give you the best service and/orsolutions and the best experience. These purposes include to:ü  deliveradvertising or information to you which may be useful to you, based on your useof preferences;ü  carryout research and development to improve our Services;ü  developand provide new and existing functionality and Services (including statisticalanalysis, benchmarking and forecasting Services); andü  provideyou with location-based Services (for example location relevant content) wherewe collect geo-location data to provide a relevant experience.Whenever we useyour information for our legitimate interests, we will ensure that yourinformation is processed on a pseudonymised basis and displayed at aggregatedlevels, which will not be linked back to you or to any living individual.You have the rightto object to processing based on our legitimate activities but if you object,this may affect our ability to provide certain Services and/or solutions foryour benefit.  

YOUR RIGHTS AS A DATA SUBJECTRequests to Access, Rectify or Erase. Access Request As permitted underlaw and applicable data privacy regulations, you have the right to ask uswhether we hold any Personal Data relating to you and, if we do, to be providedwith a copy of that Personal Data in electronic form, unless you want toreceive it in any other way (for example, a paper copy). In addition, you canask us for information on how we use your Personal Data, who we share it with,how long we keep it, where it is stored, and other information to help youunderstand how we use it. 

‍Rectification Request You have the rightto ask us to correct your Personal Data (including by means of providing asupplementary statement) if it is inaccurate, or update outdated or incompletePersonal Data without undue delay. Where we cannot correct the Personal Data,we include a note on our files regarding your request to correct your PersonalData. 

‍Erasure Request You have the right to ask us to erase yourPersonal Data if:ü  YourPersonal Data are no longer necessary for the purpose(s) they were collectedfor.ü  YourPersonal Data have been unlawfully processed.ü  YourPersonal Data must be erased to comply with a regulation.ü  Youwithdraw your consent for the processing of the Personal Data (and if this isthe only basis on which we are processing your Personal Data).ü  Youobject to the possession, provided there are no overriding legitimate groundsfor continued processing, orü  Youobject to processing for direct marketing purposes.ü  Ifwe receive your erasure request, we will also take reasonable steps to informother data controllers processing the data so they can seek to erase links toor copies of your Personal Data. We may refuse to act on your request to eraseyour Personal Data if the processing of your Personal Data is necessary:ü  Toexercise our right of freedom of expression and information.ü  Tocomply with the NDPR and relevant Nigerian laws.ü  Forthe performance of a task carried out in the public interest or to exercisesome official authority vested in us.ü  Toestablish, exercise or defend legal claims.In these cases, wecan restrict the processing instead of erasing your Personal Data if requestedto do so by you. 

‍Requests to Object: You have the rightto object at any time to the processing of your Personal Data if we process itbased on our legitimate interests. This includes any so-called “profiling”. Ourprivacy notice informs you when we rely on legitimate interests to process yourPersonal Data. In these cases, we will stop processing your Personal Dataunless we can demonstrate compelling legitimate reasons for continuing theprocessing. We may reject your request if the processing of your Personal Datais needed to establish, exercise or defend legal claims. You have the right toobject at any time if we process your Personal Data for direct marketingpurposes. You may also object at any time to profiling supporting our directmarketing. In such cases, we will stop processing your Personal Data when wereceive your objection.Requests to Restrict:You have the right to ask us to restrict the processing of your Personal Dataif:You contest theaccuracy of your Personal Data and we are in the process of verifying thePersonal Data we hold.The processing isunlawful and you do not want us to erase your Personal Data.We no longer needyour Personal Data for the original purpose(s) of processing, but you need themto establish, exercise or defend legal claims and you do not want us to deletethe Personal Data as a result, orYou have objectedto processing carried out because of our legitimate interests while we verifyif our legitimate grounds override yours.If processing isrestricted, we may process your Personal Data (excepting for storage purposes),only:If you have givenus your consent.For establishing,exercising or defending legal claims.For protecting therights of another natural or legal person, orFor reasons ofimportant public interest as defined under the NDPR and relevant Nigerian laws Once processing isrestricted following your request, we will inform you before we lift therestriction. 

‍Requests for Portability:If our processingis performed by computer and is necessary to fulfil a contract with you, or isbased on your consent, you have the right to:Receive anyPersonal Data you have provided to us in a structured, commonly used andmachine-readable electronic format.Send your PersonalData to another organization or have us do so for you if it is technicallyfeasible for us to do so.If your requestrelates to a set of Personal Data that also concerns other individuals, we mayrestrict the transfer to only the portion relevant to you, unless you establishthat you have also gotten their consent. 

‍Requests to Object to AutomatedDecisions: Generally, you havethe right to object to any legal decision concerning you or which otherwisesignificantly affects you if this is based solely on the automated processingof your Personal Data. This includes automated decisions based on profiling. Insuch instance, you may undertake a legal process to prevent or advance yourrights.Otherwise, we mayrefuse your request regarding such automated decisions where:Necessary to enterinto a contract with you, or for the performance of your contract with us. Permitted by regulations, or Based on your explicit consent. Our actions on the automated processing involving your sensitive Personal Data (where you have given your explicit consent or the processing is necessary for reasons of substantial public interest), are in complete compliance with the NDPR and relevant laws.  

‍How Do We Protect Your Personal Data? Security We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our premises, CCTV cameras for public safety and quality control, as well as information access authorization controls. 

‍Confidentiality Your Personal Data is regarded as confidential and will not be divulged to any third party, except under legal and/or regulatory conditions. You have the right to request sight of, and copies of any and all information we keep on you, if such requests are made in compliance with the Freedom of Information Act and other relevantenactments. While we are dedicated to securing our systems and services and safeguarding the information entrusted to us, your role in fulfilling confidentiality duties includes, but is not limited to, adopting and enforcing appropriate security measures such as securing and maintaining the privacy of your password(s) and account/profile registration information, adherence with physical security protocols on our premises, verifying that the Personal Data we maintain of you is accurate and current. We will inform you of any breaches which may affect your Personal Data. 

‍Remedies for Violation andTime-frame for RemedyIn the event ofviolation of this policy, our Data Protection Officer shall within 7 daysredress the violation. Where the violation pertains to the disclosure of yourPersonal Data without your consent, such information shall be retractedimmediately, and confirmation of the retraction sent to the you within 48 hoursof the redress. 

‍Governing LawThis Privacy Policyis made according to the Nigeria Data Protection Regulation (2019) or any otherrelevant Nigerian laws, regulations or international conventions applicable toNigeria. 

‍Changes to our Privacy PolicyThis privacy policyis reviewed periodically and when there is any substantial change to businessor regulatory requirements. The revised Privacy Policy will be effective as ofthe published updated date. At the minimum, we shall review this annually andcommunicate via our communication channels such as Website, Social MediaAccounts etc. If the revised version includes a substantial change, we maynotify you of the change using emails or other means. 

‍How Does Your Personal Data MoveGlobally?Our operations aresupported by a network of computers, cloud-based services and otherinfrastructure and information technology. Your Personal Data will be stored inNigeria where we are providing Services to you, except where you provide yourconsent for your Personal Data to be processed outside Nigeria to enable usprocess your transactions. Data are stored with appropriate encryption methodand security standards. We will protect your information as prescribed in thePrivacy Policy if your Personal Data is transferred out of Nigeria. By usingour Platform and Services, you consent to your Personal Data being transferredout of Nigeria, to a jurisdiction which has adequate data protection laws asprescribed in the NDPR. 

‍Contact UsIf you have anygeneral questions or concerns about this Privacy Policy or the way in which wehandle your Personal Data, kindly contact us via the details below: ENERGYWALLET SERVICES LIMITED3 kaltungo street,Garki 2, Abuja info@energywallet.com