This Policy applies to the Personal Data collected by Cowrywise when you use our website, mobile application, social media platforms, tools and any other platform belonging to Cowrywise (collectively, the "Services") or otherwise interact with us as described below. We may update this Policy from time to time and at our sole discretion. Where updates are made to the Policy, we will notify you of same by revising the date at the top of this Policy, and in some cases, we may provide you with additional notice ( by adding a statement to the homepages of our website or mobile application; or by sending you an email notification).
We encourage you to review the Policy whenever you interact with us to stay informed about our information privacy practices as well as ways in which you can protect your privacy. By accessing or choosing to use any of our platforms, you agree to be bound by this Policy.
You accept this Policy when you give consent upon access to our platforms, or use our Services, technologies, features, content or functions offered on our website, mobile applications, digital platforms, social media, amongst other platforms which may be contemplated to be used by Cowrywise.
You may be asked to provide your Personal Data, anytime you contact us or interact/access any of Cowrywise’s platforms, and we shall use your Personal Data in accordance with this Policy, relevant laws, regulations and implementation framework.
We collect Personal Data you provide to us when you apply for a Cowrywise account or when you communicate with us about your Cowrywise account. The types of Personal Data we may collect include, but not limited to, your name, address, phone number, email address, date of birth, bank account information, BVN, username, password, and next of kin details.
As you use your Cowrywise account to perform financial transactions, we collect Personal Data in connection with each transaction, including transaction time, Naira amount and merchant details. We may also collect photos, memos or other information that you attach to your transactions.
When you create a Cowrywise account, we may collect information about you, including Personal Data, prior addresses and names from non-affiliated third party service providers in order to verify your identity and for fraud prevention. Also, based on the fact that we work closely with third parties (including financial service providers, security agencies, etc), we will notify you when we receive information about you from them and the purposes for which we intend to use that information.
We may collect Personal Data you provide to us, such as your name, email address and any other information you choose to provide. For example, we may collect such information if you request an invite to join Cowrywise or if you enter into any contest or promotion. In a case where you choose to enable access to your contacts via our mobile application, we may upload your contact data to our servers so we can show you your friends who are also registered on the Cowrywise platform as users.
When you access or use our Services, we automatically collect Personal Data and other information about you as follows:
We may use your information, including Personal Data as follows:
Cowrywise is based in Nigeria and the Personal Data we collect is governed by the Nigeria Data Protection Act (NDPA) 2023 and the Implementation Framework 2020. By accessing or using the Services or otherwise providing your Personal Data to us, you expressly and clearly consent to the processing and transfer of your Personal Data in and outside Nigeria.
We will only use your Personal Data if we have a proper reason for doing so. We consider the lawful basis for using your Personal Data as set out in the Nigeria Data Protection Act (NDPA) 2023 and Nigeria Data Protection Regulation (NDPR) 2019. This includes:
We may disclose any information we collect about current and former customers, including Personal Data, to affiliates and non-affiliated third parties as follows:
With other non-affiliated companies for our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations or report to credit bureaus. For example, in connection with our everyday business purposes, we may share Personal Data about you as follows:
We may also share aggregated or de-identified Personal Data, which cannot reasonably be used to identify you. For example, we may share transaction zip codes with third parties to improve our accuracy in geo-locating transactions and to improve the clarity of transaction descriptions.
We will usually not share your Personal Data with other third parties without your consent. Where we need to transfer your Personal Data to another country, we shall ensure that such country to which the data is being transferred or the foreign institution receiving said Personal Data, shall have adequate and sufficient data protection laws. We will seek your consent where we need to send your data to a country without an adequate data protection law.
You may edit your Personal Data by logging into your account via our Services. If you wish to delete or deactivate your online account, please contact us, but note that we may retain certain Personal Data as required by law or for legitimate business purposes.
You may opt out of receiving promotional emails and text messages from Cowrywise by following the instructions in those messages. Please note that if you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.
If you initially consent to the collection of location information by Cowrywise or Google Maps within our mobile application, you may be able to subsequently stop this collection through your device operating system settings or through your online account settings. If either of these opt-out options are not available to you, you may also disable location information by following the standard uninstall process to remove our mobile application from your device.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
Our Services include social sharing features for common social networks to let users share content. These features are served from third-party services that may serve their own cookies. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
The Nigeria Data Protection Act (NDPA) 2023 and Nigeria Data Protection Regulation (NDPR) 2019 gives you certain rights in respect of the Personal Data we hold about you. Below is a highlight of some of those rights. It is not a complete, exhaustive statement of your rights in respect of your Personal Data:
Cowrywise takes reasonable measures to help protect all Personal Data about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. To prevent unauthorized access to your information, we have implemented strong controls and security safeguards at the technical and operational levels. Additionally, Cowrywise implements policies designed to protect the confidentiality and security of your nonpublic Personal Data, including a privacy protection policy. Cowrywise limits access to your Personal Data to employees that have a business reason to know such Personal Data, and implement security practices and procedures designed to protect the confidentiality and security of such Personal Data and prohibit unlawful disclosure of such Personal Data in accordance with its policies.
Where you have chosen a password that allows you to access certain parts of the website and mobile application, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. We have also taken measures to comply with provision of security facilities for the protection of your Personal Data through the set up of firewalls, limited access to specified authorized individuals, encryption and continuous capacity building for relevant personnel. We therefore have digital and physical security measures to limit and eliminate possibilities of data privacy breach incidents.
Although we use appropriate security measures once we have received your Personal Data, the transmission of data over the internet (including by email) is never completely secure. We endeavour to protect Personal Data, but we cannot guarantee the absolute security of Personal Data transmitted to us or by us. We will notify you and any applicable regulator of a breach where we are legally required to do so.
We will hold your Personal Data on Cowrywise’s systems in line with our Retention Schedule to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data, we shall, within 72 (Seventy-Two) hours of having knowledge of such breach, report the details of the breach to NDPC.
Furthermore, where we ascertain that such breach is detrimental to your rights and freedom in relation to your Personal Data, we shall within 7 (Seven) working days of having knowledge of the occurrence of such breach take steps to inform you of the breach incident, the risk to your rights and freedom and any course of action to remedy said breach.
This Policy is made pursuant to the Nigeria Data Protection Act (NDPA) 2023 and Nigeria Data Protection Regulation, 2019 and other relevant Nigerian laws and regulations. Where any provision of this Policy is deemed inconsistent with a law or regulation, such provision shall be subject to the overriding law or regulation.
You can also write us as follows:
Cowrywise Attention: Data Protection Officer
5C Reverend Ogunbiyi Street,