Privacy policy

1. General Information

This data privacy, protection and cookie policy (“Privacy Notice”) describes your privacy rights regarding how Xebar and its Affiliates (“Xebar”, “we”, “us”) collect, process, use, store, and share your personal data when you use our website and all related sites, applications, and services.

This Notice is to inform you about the personal data we collect from you, how we collect the data and how we use the data, your rights relating to the Personal Data when You use this Service or purchase the Products and Services offered on the Application. By continuing to use our Application, You acknowledge that You have reviewed the Privacy Notice and agree to its terms. This also means that You have consented to the use of Your Personal Data and have accepted the applicable disclosures. You may, however, reach out to us if you have any questions regarding your data with us, via: [email protected]

We always ensure to handle personal data in our care in strict compliance with applicable data privacy and protection laws.

2. How we collect personal data

We collect your personal data when you register to use any of our services.

3. The Information We Collect

a. Personal Information

We collect certain types of information, such as name, telephone numbers, email address, physical address, financial information, and other information relevant for us to carry out our know your customer (KYC) or due diligence on them. This due diligence may be carried out during and/or after onboarding with us. We may retain this information for a period of time after use. This timeline is guided by our data retention policy, data protection laws, and industry regulations and guidelines applicable to us.

In addition to using your Personal Information for KYC and due diligence, we may also use them for the following purposes:

Provide you with the required services, including opening an account, carrying out necessary monitoring, ongoing compliance and reporting to regulators.
Respond to your questions or requests.
Address inappropriate use of our app.
Prevent, detect and manage risk against fraud and illegal activities using internal and third party screening tools.
Verify your identity and the information you provide in line with Xebar’s statutory obligations using internal and third party tools.
Resolve disputes that may arise, including investigations by law enforcement or regulatory bodies.
Any other legal obligation which we may have with respect to the provision of our services.

We may retrieve additional Personal Information about you from third parties, such as our partners which you deal with, and other identification/verification services.

b. transaction data

During a transaction, we collect certain data from you depending on which of our services you are using. This information is collected and processed on an absolute necessity basis as required by law and industry standards to which we are mandated to comply.

c. Other Information

Analytics we analyse our relationship and transactional information to derive unique data. For example, we may generate propensities, attributes and/or scores for marketing, security or fraud purposes.

Information derived from your use of our website and other technical products this includes information regarding your interactions with our websites, applications or advertisements, including IP address, device identifiers, settings, characteristics, advertising ID, browsing history, web server logs, server log records, activity log records, keystroke timing and other information collected using cookies and similar technologies. We may also use such data to improve features, website content and analyse data to develop products and services.

Audio and Visual Information -this includes audio, electronic, visual or similar information relating to your interactions with us.

Government-Issued Identification Numbers - we may request a government issued ID to carry our verification of your identity. We may use third party services for this verification.

4. Purposes and Lawful Basis for Processing Personal Information

We may rely on one of more of the following lawful basis to process your personal data:

Purpose of Collecting and Processing

KYC Verification and Onboarding.
Transaction Processing and Monitoring.
Issues Resolution
Sales and marketing.
Generating de-personalized information for product development and improvement
Fraud Monitoring, Chargebacks and Dispute Resolution.

Categories of Data Collected

Personal Data; Government- Issued Identification Numbers; Information derived from your use of our website and other technical products.
Transaction Data; Government-Issued Identification Number; Geolocation Information;
Personal Data; Transaction Data
Analytics Data

Lawful Basis

Your Consent
Lawful purpose - we are required by our regulators to collect this information
Legitimate interests (ours and those of others) such as to protect you, us, or others from threats (such as security threats or fraud); to enable or administer our business, such as for quality control, compliance, consolidated reporting and customer service; to manage corporate transactions, such as mergers or acquisitions; and to understand and improve our business or customer relationships generally
To fulfil the terms of the contract which you sign with us at the point of onboarding

5. Purpose Limitation

Xebar collects Personal Information only for identified purposes and for which consent has been obtained. Such Personal Information cannot be reused for another purpose that is incompatible with the original purpose, except consent is obtained for such purpose.

6. Data Minimization

Xebar limits Personal Information collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed.

Xebar will evaluate whether and to what extent the processing of Personal Information is necessary and where the purpose allows, anonymized data will be used.

7. Cookies

We use cookies to identify you as a User and make your user experience easier, customise our services, content and advertising, amongst others.

8. Age Restriction

Our website and Services are not directed to children under 18. We do not knowingly collect information from, or conduct business with, children under 18. If as a parent or guardian, you become aware that your child or ward has provided us with any information without your consent, please contact us through the details provided in this Privacy Notice.

9. How We Protect your Information

Xebar shall establish adequate controls in order to protect the integrity and confidentiality of Personal Information, both in digital and physical formats and to prevent Personal Information from being accidentally or deliberately compromised.

Xebar is committed to managing your Personal Information in line with global industry best practices. We protect your Personal Information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration, we also use industry recommended security protocols to safeguard your Personal Information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to our building and files and only granting access to Personal Information to only employees who require it to fulfil their job responsibilities. Any Personal Information processing undertaken by an employee who has not been authorised to carry such out as part of their legitimate duties is unauthorised.

Employees may have access to Personal Information only as is appropriate for the type and scope of the task in question and are forbidden to use Personal Information for their own private or commercial purposes or to disclose them to unauthorised persons, or to make them available in any other way.

10. Transfer of Personal Information

a. Third Party Processor within Nigeria

Xebar may engage the services of third parties in order to process your Personal Information collected by us. The processing by such third parties shall be governed by a written contract with Xebar to ensure adequate protection and security measures are put in place by the third party for the protection of Personal Information in accordance with applicable laws and regulatory standards.

b. Transfer of Personal Information to Foreign Country

We use third party services which may be located outside of the country in which the Xebar entity which collected or is processing your data is located. We ensure that when we share your personal data with such third party service providers, we ensure to put in place appropriate safeguard mechanisms, in accordance with best practices and applicable data protection law, to ensure the protection of your personal data.

11. Choices and Rights

Individuals who have Personal Information held by Xebar may exercise any of the rights listed below:

Right to request and access their Personal Information collected and stored. Where data is held electronically in a structured form, such as in a database, you have a right to receive that data in a common electronic format;
Right to information on their personal information collected and stored;
Right to objection or request for restriction;
Right to object to automated decision making;
Right to request rectification and modification of Personal Information which Xebar keeps;
Right to request for deletion of your data;
Right to request the movement of data from Xebar to a third party; this is the right to the portability of data; and
Right to object to, and to request that Xebar restricts the processing of their information.

Such requests will be reviewed by Xebar’s Data Protection Officer and carried out except as restricted by law or Xebar’s statutory obligations. You may decline to provide your personal Information when it is requested by Xebar, however, certain services or all the services may be unavailable to you. You may review your account settings and update your Personal Information directly or by contacting us.

12. Contact

If you have any questions relating to this Privacy Notice or would like to find out more about exercising your data protection rights, please reach out to us via email at “[email protected]”.

13. Updates, Modifications & Amendments

We may need to update, modify or amend our Privacy Notice as our technology evolves and as required by law. We reserve the right to make changes to this Privacy Notice from time to time and notify Users of material changes. The Privacy Notice will apply from the effective date provided on our website at the time of publishing the updates.

We advise that you check this page often, referring to the date of the last modification on the page. If a User objects to any of the changes to this Privacy Notice, the User must cease using this website or any of our Services. Where such User continues to use this website and/or any of our Services, it shall continue to be bound by the terms of this Privacy Notice.