Purpose of this privacy policy

This privacy policy aims to give you information on how Jagoo Tech Ltd (Meelow) collects and processes your personal data through your use of Meelow, including any data you may provide through Meelow when you sign up to our newsletter, purchase a product or service, provide feedback or in any other manner interact with us.

Please read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

The Services are not intended for children, and we do not knowingly collect personal data from children.

Controller

Jagoo Tech Ltd (Meelow) is the controller and responsible for your personal data (collectively referred to as “Meelow” "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

You have the right to make a complaint at any time to the National Information Technology Development Agency (NITDA), the Nigerian regulator for data protection issues (www.nitda.gov.ng). We would, however, appreciate the chance to deal with your concerns before you approach the NITDA so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes.

We may update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect.

You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications. You may obtain historic versions by contacting us.

Third-party links

This website may contain links to third-party websites, plug-ins, applications and services. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. A link to any third-party websites does not mean that we endorse it or the quality or accuracy of information presented on it.

If you decide to visit these third-party websites, you are subject to their terms and conditions, and not these terms. We encourage you to carefully review the legal and privacy notices of all other digital services that you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data: includes first name, maiden name, last name, company name, RC number, username or similar identifier, marital status, title, date of birth and gender.
• Financial Data: includes bank account and payment card details.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Transaction Data: includes details about payments to and from you and other details of bundles, and other services you have purchased from us.
• Usage Data: includes information about how you use our website, products and services.
• Contact Data: includes email address, phone number, billing address.
• Device Data: includes device identifiers, mobile OS, device model, app version and mobile network information.
• Location Data: includes your live/real-time location and/or approximate location when you enable location permissions and the security feature is on (including background location if you allow it).
• Verification/KYC Data (if applicable): includes government ID, selfie/liveness checks, BVN/NIN or similar identifiers, and verification results.
• Payee/Bill Data: includes biller name, customer/reference number, bill amount, service address (if provided), and bill payment history.
• Security and Fraud Data: includes login timestamps, failed login attempts, device fingerprinting, risk signals, and location-based risk indicators.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Failure to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services).

In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Direct interactions

  You may give us your Identity, Contact, Financial and Verification Data by filling in forms or by corresponding with us by post, phone, email, within the mobile application or otherwise. This includes personal data you provide when you:

  • Apply for our products or services;
  • Create an account on our website/mobile application;
  • Subscribe to our service or publications;
  • Request marketing to be sent to you;
  • Enter a competition, promotion or survey; or
  • Give us feedback or contact us.

• Automated technologies or interactions

  As you interact with our website or mobile application, we will automatically collect Technical, Usage, Device and Location Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, mobile SDKs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

• Third parties or publicly available sources

  We will receive personal data about you from various third parties as set out below:

  • Technical Data
    • (a) analytics providers such as Google;
    • (b) advertising networks; and
    • (c) search information providers.

  • Identity and Contact Data from data brokers or aggregators.

  • Identity and Contact Data from publicly available sources such as the Corporate Affairs Commission (CAC).

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• i.Where we need to perform the contract we are about to enter into or have entered into with you.
• ii.Where it is necessary for our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests.
• iii.Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a list format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out below.

Location Use

If you enable the live location security feature, we will collect and use your location to:

• (i) detect and prevent fraudulent access or transactions
• (ii) verify that high-risk sign-ins are legitimate
• (iii) support account recovery and incident response, and
• (iv) comply with legal obligations.

You can disable location permissions at any time, but some security features may not function.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

We may use in-app notifications and push notifications for service-related messages and, where permitted, marketing. You can manage push notifications in your device settings.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may share your personal data with our affiliate companies or external third parties. This may involve transferring your data outside Nigeria. We ensure your personal data is protected by requiring all our affiliate companies to follow the same rules when processing your personal data.

Whenever we transfer your personal data out of Nigeria, we ensure a similar degree of protection is afforded to it. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Nigeria.

This may include transfers to cloud providers and payment/security vendors outside Nigeria. We use appropriate safeguards (for example, contractual protections) where required.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Under certain circumstances, you have rights under data protection laws in relation to your personal data and if you wish to exercise any of the rights, please contact us at admin@meelow.ng.