30th November, 20231.0 Introduction
This policy also contains information about when we share your personal information with third parties (such as other service providers).
2.0 Interpretations and Definitions
‘Application’ means the software program provided by the Cognideck downloaded by You on any electronic device
‘Company’ (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Cognideck 24 Ibrahim Onashokun, Gbagada Lagos
‘Cookies’ are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
‘Country’ refers to: Nigeria
‘Device’ means any device that can access the Service such as a computer, a cell phone or a digital tablet.
‘Personal Data’ is any information that relates to an identified or identifiable individual.
‘Service’ refers to the Application or the Website or both.
‘Service Provider’ means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.
‘Third-party Social Media Service’ refers to any website or any social network website through which a User can log in or create an account to use the Service.
‘Usage Data’ refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
‘Website’ refers to Cognideck, accessible from http://www.cognideck.com/ ‘You’ means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
3.0 Types of Data Collected
3.1 Categories of Personal Data
We collect the Personal Data you provide to us when you apply for an account within any of our applications or when you communicate with us about your account. The types of Personal Data we may collect include your name, address, phone number, email address, date of birth, bank account information, BVN, NIN, username.
3.2 Personal Data About Your Transactions With Us
As you interact with any of our applications to perform transactions, we collect Personal Data in connection with each transaction, including transaction time, amount and merchant details. We may also collect photos, memos or other information that you attach to your transactions.
3.3 Personal Data From Third Parties
When you create an account, we may collect information, including Personal Data about you from non-affiliated third-party service providers in order to verify your identity and for fraud prevention, including your prior addresses and names. We also work closely with third parties (including financial service providers, security agencies, etc) and will notify you when we receive information about you from them and the purposes for which we intend to use that information.
3.4 Personal Data We Automatically Collect
Information that we automatically collect in connection with your access or use of our Services may include:
Device Information: We may collect Device-specific information (such as hardware model, operating system version, unique Device identifiers, and mobile network Information, including your mobile phone number). We may associate your Device identifiers or mobile phone number with your account.
Log Information: We may record or log information from your Devices, their software, and your activity accessing or using our Services. This information may include:
The Device’s Internet Protocol (“IP”) address
Identification numbers associated with your Devices
Device event information, such as crashes, system activity, and hardware settings
Date and time stamps of transactions
System configuration information
Other interactions with our Service
4.0 Information Collected by Cookies and Other Tracking Technologies
Flash Cookies: Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
Web Beacons: Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies: Cookies: What Do They Do?: https://www.freeprivacypolicy.com/blog/cookies/
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies Administered by: Us Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies Administered by: Us Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
5.0 Use Of Personal Data
We may use your information, including Personal Data as follows: Provide, maintain and improve our Services
Provide and deliver the products and services you request, process transactions and send you related information, including confirmations.
Verify your identity and prevent fraud.
Send you technical notices, updates, security alerts and support and administrative messages.
Respond to your comments, questions and requests and provide customer service.
Communicate with you about products, services, offers, promotions, rewards, and events offered by Cognideck and others, and provide news and information we think will be of interest to you.
Monitor and analyse trends, usage and activities in connection with our Services.
Personalise and improve the Services and provide advertisements, content or features that match user profiles or interests.
Process and deliver contest or promotion entries and rewards.
Link or combine with information we get from others to help understand your needs and provide you with better service.
Carry out any other purpose for which the information was collected.
Cognideck is based in Nigeria and the Personal Data we collect is governed by the Nigeria Data Protection Regulation (NDPR). By accessing or using the Services or otherwise providing your Personal Data to us, you consent to the processing and transfer of your Personal Data in and to Nigeria and other countries.
5.1 Lawful Basis For Processing Personal Data
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 Regulation (NDPR). These include:
To comply with our legal and regulatory obligations.
To perform a contract with you or to take steps at your request before entering into a contract.
To use your Personal Data as is necessary for our legitimate interests or the legitimate interests of others.
To protect your interest, the interest of another Data Subject or for the performance of a task carried out in the public interest or in exercise of official public mandate vested in us.
6.0 Disclosure Of Personal Data
We may disclose any information we collect about current and former customers, including Personal Data, to affiliates and non-affiliated third parties as follows:
If you request or authorize it;
If the information is provided to help complete a transaction for you;
If the information is required to:
(a) comply with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas;
(c) protect our rights, property, or safety or the rights, property, or safety of our users or others (e.g., to a consumer reporting agency for fraud protection, etc.);
If the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets);
If the information is provided to our third-party service providers to perform functions on our behalf (e.g., analysing data, providing marketing assistance, providing customer service, processing orders, etc.);
For our everyday business purposes;
For publication of our events and competitions on digital and print media.
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 shall have adequate data protection law. We will seek your consent where we need to send your data to a country without an adequate data protection law.
We do not share your Personal Information with:
Other financial companies for joint marketing purposes;
Affiliated companies for their everyday business purposes; or
Any third parties so they can market to you
6.1 Your Rights
The Nigeria Data Protection Regulation (NDPR) 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:
You have a right to a copy of the Personal Data we hold about you, as well as the information about what we do with it, who we share it with and how long we hold it for. We may make a reasonable charge for additional copies of that data in the case of unfounded and excessive requests.
You have a right to freely transfer your data received from us to any other person.
You have the right to have the Personal Data we hold about you corrected, if it is factually inaccurate. You may contact us for this purpose via email@example.com In some circumstances, you have the right to the deletion of the information that we hold about you.
You have a right to lodge a complaint about the handling of your personal information with the National Information Technology Development Agency (NITDA).
You have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your Personal Data to any third party for such purposes.
7.0 Security Of Your Personal Data
We have suitable security measures in place to prevent your Personal Information from being accidentally lost or used or accessed in an unauthorised way by a third party. 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 Information on our instructions. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We have and require our third-party service providers that receive Personal Information from us to have, a comprehensive written information security program that contains administrative, technical, and physical safeguards for our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, or alteration.
No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your username and password for your accounts and do not share them with others. If we receive instructions using your account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your account or any other breach of security.
We reserve the right, in our sole discretion, to refuse to provide our Services, terminate accounts, and to remove or edit content.
8.0 Retained Data
We shall retain your information for as long as your account is active or as needed to provide you with our services or comply with our legal and statutory obligations.
9.0 Breach Of Personal Data
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 NITDA.
Furthermore, where we ascertain that such breach is detrimental to your rights and freedoms in relation to your Personal Data, we shall within 7 (Seven) 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 freedoms resulting from such breach and any course of action to remedy said breach.
10.0 Deletion Or Erasure Of Personal Data
We store data until it is no longer necessary to provide our services and Cognideck Products, or until your account is deleted – whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.
When you delete your account, we delete all the things you have posted, such as your photos, communication, status updates, and you won’t be able to recover that information later. Information that others have shared about you isn’t part of your account and won’t be deleted. If you don’t want to delete your account but want to temporarily stop using the Products, you can deactivate your account instead.
11.0 Children’s Privacy
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers. If you believe we may have information from or about anyone under the age of 13, please contact us using the information provided in the ‘Contact Us’ section below.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.
12.0 Links to Other Websites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Your continued use of the service after we make changes is deemed to be acceptance of those changes.
14.0 Your Acceptance Of These Terms
By using this Application, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our application. Your continued use of any Cognideck application following the changes to this policy will be deemed your acceptance of those changes.
24 Ibrahim Onashokun,