Privacy Policy.

This privacy policy governs your use of products, services, content, features, technologies or functions offered by central bank of Nigeria or through any of its agents/representatives (collectively referred to herein as “the bank”) and all related sites, applications and services (collectively referred to herein as “enaira services”) including, without limitation, when you provide any information in relation to your use of e-naira services.By voluntarily providing us with personal and other information, signing up for, accessing, or using the e-naira services, you accept and consent to this privacy policy.

Thereby, acknowledging and agreeing that such information may be transferred from your current location to the offices and servers of the bank and authorised third parties. For the avoidance of all doubt, by accepting and consenting to this privacy policy, you expressly consent to the bank’s collection, use, disclosure and protection of your personal information and hereby direct the bank to collect, use, disclose and/or protect such data in a manner consistent with the requirements of the law and this privacy policy.

The Bank (hereinafter referred to as “we” or “us”) has adopted this Privacy Policy to govern the use of eNaira Services by all users (hereinafter referred to as “you”), which includes, without limitation, individuals who use eNaira Services for personal purposes (the “Customers”) and those who use the eNaira Services in the course of their trade or business (the “Merchants”).
For the avoidance of doubt, this Privacy Policy applies to all users, unless otherwise expressly excluded by written agreement. By consenting to, and agreeing to the terms of this Privacy Policy, you expressly consent and agree to us processing the data you submit and/or generate in the manner set out herein. The Bank takes its access to such information very seriously and will use it only in accordance with the terms of this Privacy Policy, which describes the information we collect and how we use, share and protect that information.

For the purposes of this Privacy Policy, the term “information” means any confidential and/or personally identifiable information or other information related to users of eNaira Services, including but not limited to Customers and Merchants

Data SubmittedWe collect and may use information such as:

1. your account information (the “Account Information”), which includes without limitation: name, address, phone number(s), email address, username, photograph, IP address, account number(s), account types, government-issued identification number(s), date of birth, physical address, source of funds, statements and reports, currency and other account preferences as may be determined by the Bank from time to time;
2. Communications between you and us for customer service and/or other purposes (e.g., by emails, faxes, phone calls, tweets, etc.);
3. The emails and phone numbers of your contacts, if you choose to invite them to use one or more of the eNaira Services as part of a referral programme (unless your contact opts to unsubscribe from our commercial mailing list(s));
4. Data generated by or about transactions you complete using eNaira Services, including information related to the value, volume, nature and other details of a transaction.
5. The unique identification number associated with your mobile device used to access any of our applications. For iOS users, we also collect the Apple-recommended CFUUID (the Core Foundation Universally Unique Identifier)); and
6. Other commercial and/or identification information required for us to comply with our anti-money laundering obligations under applicable laws and regulations.

We also automatically collect and may use the following data:

Cookies: We use cookies on our website to collect data about your visit and to allow you to navigate from page to page without having to login again on each page. We use cookies to recognise you as a customer, customise eNaira Services, content and advertising, measure promotional effectiveness, help ensure that your account security is not compromised, mitigate risk and prevent fraud, and to promote trust and safety across our eNaira Services. Cookies also allow us to count visits and see which areas and features of our website are most popular. We do not link the information we store in cookies to any information you submit while on our website. However, our use of cookies and other technologies may allow us and third parties to collect information about your browsing activities over time and across different websites following your use of eNaira Services.

Analytics: When you visit our website, we use third party analysis tools to collect data about your computer and internet connection. That information includes the IP address of your computer and/or internet service provider, when you access our website, the internet address of websites from which you link to our website and from which you came before landing on our website, the browser that you are using, and your navigation and preferences on our website. All this information is used internally for the purpose of understanding how our website is being used and improving our website. We also use third party analysis tools to collect data about your use of our applications. The information collected identifies the nature and timing of the actions you take within our applications, including installation, registration, uploading, and certain types of navigation. All this information is used internally for the purpose of understanding how our applications are being used and to facilitate the improvement of said applications.

Action Tags: When you visit our website, we use action tags (also called pixel tags, clear GIF or beacons) to identify some of the pages that you visit and how you use the content on those pages. Action tags may collect and transmit this data in a manner that identifies you if you have registered with our website or are logged into our website. We also use action tags in our emails to determine whether an email was opened or whether it was forwarded to someone else. When you use our mobile apps, we use action tags where you are accessing websites from links in our mobile apps. These may identify the pages that you visit and how you use the content on those pages.

Site Management: We aggregate data that we collect about the use of our website for administration purposes, to protect and improve our website and our systems, to better understand the preferences of our website visitors and optimize the content that we serve, to identify server problems, to compile aggregated statistics about our website usage, and to improve our marketing and research.

Data Protection: The Bank is committed to observing high standards of information security. We use computer safeguards such as firewalls and data encryption, enforce physical access controls to our buildings and files, and authorise access to personal information only for those employees who require it to fulfil their job responsibilities.While we use reasonable physical, electronic and procedural safeguards to protect your personal information from loss, misuse, unauthorised access or disclosure, alteration and destruction, please be advised that we do not accept responsibility for the security of any data transmitted over the internet or information stored, posted or provided directly to a third party website, which is governed by that third party’s policies.

Password Protection:  ability to securely use eNaira Services also depends on your protection of your login credentials such as your product password. We strongly recommend that you do not share your password(s) or security information with anyone. The Bank will never ask you for your password. Therefore, any email or other communication requesting your password or any similar security information should be treated as unauthorised and suspicious. In the event that you receive such a communication, please promptly forward it to eNaira HelpDesk ([email protected], +234800MYENAIRA)If you do share your password(s) with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you will generally be considered responsible for any and all actions taken using your password. If you believe that someone else has obtained access to your password, please change it immediately by logging in to your account and changing your profile settings. We also strongly recommend that you also contact eNaira HelpDesk ([email protected], +234800MYENAIRA) immediately.

If you wish to permanently close an account/wallet associated with one or more eNaira Services, please let us know by submitting a request to eNaira HelpDesk ([email protected], +234800MYENAIRA). We may retain information about you in our databases for as long as your account/wallet is active or as needed to provide eNaira Services to you.

Additionally, our retention and use of your information will be in accordance with applicable law, including our legal obligations, interest in resolving any disputes, and the enforcement of all relevant agreements. It is important to note that the retention period may extend beyond the end of your relationship with us, as required by law or as deemed necessary in our absolute discretion.

The Bank works with third-party service providers that offer important functions to us, which facilitate or support our eNaira Services in some way. We, therefore, disclose user data to such third-party service providers from time to time so that their services can be effectively performed.
The Bank may also share your information for the purposes of fraud prevention, risk management, customer service, legal compliance and the provision of our services, particularly in circumstances where:

• You have consented or otherwise given us permission to share said information;
• We have aggregated or de-identified the information, so that it cannot reasonably be used to identify you;
• It is required by a third party service providers who we use in delivering our service, including certain advertising, referral, operations, financial services and technology services (such as hosting providers, identity verification, support, payment, and email service providers);
• It is, or we reasonably believe it to be, required by applicable law or legal process;
• It becomes necessary in order to protect the rights, property and safety of the Bank , our users and the public, including, for example, in connection with court proceedings, or to detect or prevent criminal activity, fraud, material misrepresentation, or to establish our rights or defend against legal claims; and
  It relates to the sale, merger, transfer, or reorganization of all or part(s) of our business.

Our eNaira Services may incorporate links to other websites, social media platforms or online services, whose privacy policies may differ from those of the Bank. Please be aware that if you submit information to any such website, social media platform or online service, your information is governed by their privacy policies, which should be read carefully prior to use. The Bank is not responsible for the practices or procedures of such third parties.

This Privacy Policy may be revised over time as new features are added to the E-Naira Services or as we incorporate suggestions from our Users. We may change his Privacy Policy at any time by posting a revised version of it on our website. Unless we have reasonable cause to do otherwise, we will provide you with at least 30 days’ prior notice of the effective date of the revised privacy policy. This notice may take the form of a post on the “Policy Updates” page of our website(s) and/or an email. As of the effective date of the revised privacy policy, you will be considered to have consented to all changes if you continue to use E-Naira Services. If, however, you disagree with any terms of this Privacy Policy, you may close your account at any time.

The Bank is responsible for ensuring that our day-to-day practices and procedures comply with this Privacy Policy. Should you wish to access your information or have any questions about this Privacy Policy, the Bank’s information practices, or your relationship with the Bank, please feel free to contact us at eNaira HelpDesk ([email protected], +234800MYENAIRA)

This Terms and Conditions shall be governed, construed and enforced in accordance with the laws of the Federal Republic of Nigeria. Central Bank of Nigeria.