Flutterwave Incorporated and its affiliates (“we”, “us”, “our” collectively, “Flutterwave”) is committed to protecting the rights and privacy of individuals in accordance with the Data Protection Legislation. This Privacy Notice (“Notice”) is designed to give you information on our privacy practices, the measures we take to protect the security of the data and to help you understand your rights and choices when we collect or process your Personal Information.

This Privacy Notice is applicable to all Flutterwave Services accessed by you.

Flutterwave focuses on the following core principles:

• To empower the individual: Flutterwave wants you to be in charge of your Personal information and to make your own voluntary choices about your Personal Information;
• To keep and secure Personal information: Flutterwave does not take your trusting us with your information for granted. We take responsibility in ensuring that appropriate security measures are put in place and your Personal information is protected;
• To be transparent and to educate users: For you to know what Personal information is, how we collect it, for what purposes it is collected and how we secure it;
• To abide by local laws: Flutterwave is a global company with local privacy expertise. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. Specific privacy notices may apply to some of our products and Services. Please visit the webpage or digital assets of the specific product or service to learn more about our privacy and information practices in relation to that product or service.
• To ensure that Personal information collected is up to date : We take steps to ensure that Personal information collected is kept accurate.
• To collect and store Personal information on a “need to collect” basis: Flutterwave collects Personal information to perform its Services for you. Where we store or retain Personal information, we do this in accordance with retention obligations and requirements imposed by applicable laws.

We may collect, use or process Personal information such as:

• Identity Data: Information such as, your full name, your government-issued identity number, and your date of birth. This data is to enable us to verify your identity in order to offer our Services to you. We also collect copy(ies) of your passport, driving licence or other any government-issued identity card, a photograph or image in photo or video form (if applicable) and any other registration information you may provide to prove you are eligible to use our Services and in compliance with regulatory requirements on Know Your Customer (KYC), Know-Your-Business (KYB) and Anti-Money Laundering Laws (AML) and regulations;
• Contact Data: This includes your country of residence, contact address, email address, contact number, details of the device you use and billing details. We require this data to reach out to you for the purpose of providing our Services to you and verifying your login requests.
• Log/Technical Data: When you access Flutterwave Services, our servers automatically record information that your browser sends whenever you visit a website, links you have clicked on, length of visit on certain pages, unique device identifier, information on your page interaction (e.g, scrolls and clicks), log-in information, internet protocol (IP) address, location and other device details.
• Financial Data: Information, such as your bank account number, international bank account number (IBAN), sort code, beneficiary details, the merchant’s name and location, the date and the total amount of transaction, and other information provided by financial institutions or merchants when we act on their behalf;
• Transactional Data: This is information relating to a payment when you as a merchant (using one or more of our payment processing Services) or as a customer, are using our products or Services;
• Marketing and Communications Data: This includes both a record of your decision to subscribe to or withdraw from receiving marketing materials from us or from our third parties. This also includes the content of your communication with us through mobile calls, call recordings, online chats or other means of communication.
• Records of your discussions with us, if we contact you and if you contact us.

We may also collect, store, use and transfer non-Personal Information or anonymized data such as statistical or demographic data.

As a principle, we do not collect any Sensitive Personal Information. However, If we do collect any Sensitive Personal Information, we will ensure compliance with the Data Protection Legislation.

This Privacy Notice applies to Flutterwave Services only. We do not exercise control over the sites displayed or linked from within our various Services. These other sites may place their own cookies, plug-ins or other files on your computer, collect data or solicit personal information from you. Flutterwave does not control these third-party websites and we are not responsible for their privacy statements. Please consult such third parties’ privacy statements and set appropriate controls from your settings when using any third-party services.

The Personal Information we have about you is directly made available to us when you:

• sign up or register to use a Flutterwave Account;
• use any of our Services;
• contact our customer support team or correspond with us;
• fill in our online forms or respond to surveys;
• apply for employment opportunities we advertise;
• register for and attend our webinars, events or online discussions;
• contact us for other reasons.

We may also collect Personal Information about you from third party sources, such as credit bureaus, merchants, fraud prevention agencies, identity verification providers, analytics providers and other publicly available sources such as online directories and websites for due diligence checks.

We may use your Personal Information that we collect to:

• create and manage any Accounts you may have with us, verify your identity, provide our Services, and respond to your inquiries;
• process your payment transactions (including authorization, clearing, chargebacks and other related dispute resolution activities) and provide other payment related services to you;
• protect against and prevent fraud, un-authorized transactions, claims and other liabilities;
• communicate with you about products, newsletters, advertisements, offers, programs and promotions of Flutterwave, financial institutions, merchants and other partners. You have the right to opt-out of this at any time;
• send communication on service updates (downtime, service support, regulatory notices, etc);
• communicate with you to resolve an inquiry, complaint or concerns with your Account. We also use your contact data to send you one-time passwords (OTP) for account authentication via short messaging service (SMS), email, whatsapp or other electronic mediums;
• evaluate and improve our business, including developing new products and Services;
• establish, exercise and defend legal rights, as necessary;
• comply with applicable laws and regulations, including for compliance with Know-Your-Customer, Know-Your-Business, Anti-Money Laundering, anti-corruption, fraud monitoring, sanctions screening and risk assessment requirements, or as requested by any judicial process, law enforcement or governmental agencies having or claiming jurisdiction over Flutterwave or Flutterwave’s affiliates;
• use data analytics to improve our website, products or Services, user experience and to optimise our Services.
• If you register for and/or attend any Flutterwave sponsored events, we collect your registration and contact details to complete your registration. We may also collect your images, in video or still form, audio-visual recordings or other forms of digital information gathered at such events by the media team and use them for promotion, publication or marketing of the event as Flutterwave may determine.
• Mobile applications: In order to experience the full range of our mobile application’s seamless services including the ability to send funds to your phone contacts through the application (where applicable), we would require your consent granting access to your contact list. You have the right to withdraw your consent allowing us access to your contact list at any time. Please note that where your consent is not given or withdrawn, we would require the email address or contact of the recipient, in order to facilitate the fund transfer through the application.
• Employment: if you apply for employment with Flutterwave, we use your Personal Information to evaluate your interest in employment, for compliance checks and to contact you regarding possible employment with Flutterwave;
• For other purposes, for which we provide specific notices at the time of collection.

By virtue of the Data Protection Legislation, below are the rights you have as a user in relation to your Personal Information:

• Right to be informed on how we process your data. This Privacy Notice explains our privacy practices.
• Right to request for access to all or copies of your Personal Information by signing into your Account or contacting us. We will not give you Personal Information we hold on other individuals. You can exercise this right provided that we are not mandated to provide access to Personal Information more than twice in a 12-month period.
• Right to request that Flutterwave delete or erase your Personal Information. Please note that this is a limited right which applies where the continued processing of your Personal Information has no legal justification. The exceptions to this right is where the applicable law requires Flutterwave, as a regulated financial services institution, to retain a historical archive of your personal information to fulfil regulatory requirements or where we retain a core set of your personal information to ensure we do not inadvertently contact you in future, where you object to your data being used for marketing purposes.
• Right to correct or rectify any Personal Information that you provide which may be incorrect, out of date or inaccurate. You also have the right to ask us to update information you think is incomplete or outdated.
• Right to opt-out of direct marketing. You have a right to ask us not to contact you for marketing purposes by adjusting your notification preferences on the settings page of our Sites or by opting out via the unsubscribe link in marketing emails we send you.
• Right to object to processing: You have the right to object to or restrict the processing of your Personal Information in certain circumstances. Please note that where you object to or restrict us from processing your Personal Information, we might be unable to provide our Services to you.
• Right to not be subject to a decision based solely on automated processing.
• Right to request that we move or transfer your Personal Information across different Services we provide, or have it moved or transferred from us to another company in a structured, commonly used and machine-readable format. The exception to this right is where your request is not technically feasible or possible.

If you are a resident of California, you have the following rights in addition to the foregoing:

• Right to opt-in and opt-out of the sale of Personal Information: You have the right as stipulated under the CCPA to opt in and out of the sale of your Personal Information. The CCPA defines a “sale” as the disclosure of Personal Information for monetary or other valuable consideration. Flutterwave does not offer the option of opting in and out of the sale of Personal Information because we do not sell Personal Information.
• Right to not be discriminated against: You also have the right to be free from discrimination by Flutterwave for exercising your rights under the CCPA.
• Right to limit the use or sharing of Sensitive Personal Information: We do not sell or share Sensitive Personal Information as defined by the CCPA.
• Right to request specific information: You shall have the right to request, in addition to access to the Personal Information we hold about you, that we disclose the following:
  
  • The business or commercial purpose for collecting or selling personal information;
  • The categories of Personal Information that it has sold;
  • The categories of third parties with whom the business has shared Personal Information in the preceding 12 months.

You may designate in writing, or through a power of attorney, an authorized agent to make a verifiable consumer request(s) on your behalf to exercise your rights under the Data Protection Legislation. Kindly note that the appointed agent would have to reach out to us via the email provided in the “Contact Us” section and we may reach out to you to verify your identity and confirm that the appointed agent was properly authorized to make the request on your behalf.

You can exercise your rights at no cost. However, we are permitted by law to refuse your request or charge a reasonable fee where your request is excessive or manifestly unfounded. If we decide to charge a fee, we will inform you before treating your request.

If you wish to exercise any of your rights set out above, please contact us at privacy@flutterwavego.com . Where we are unsure of your identity, we might ask you for proof of your identity for security reasons, before dealing with your request. Where a third party exercises any of these rights on your behalf, we would need sufficient proof that you have authorised them to act on your behalf.

We may disclose or share your Personal Information with third parties as may be reasonably necessary for the purposes set out in this Notice.

We share Personal Information with external third parties in the following limited circumstances:

• We provide such information to our subsidiaries or affiliated entities for the purpose of processing Personal Information on our behalf. We require that these parties agree to process such information based on our instructions, implement appropriate confidentiality and security measures and comply with the Data Protection Legislation.
• We share your data with our third party providers or service providers, financial partners or suppliers for the purpose of effectively providing our Services to you. These services include identity verification and fraud prevention, customer service and support, analytics, payment facilitation by our banking and financial service partners including the card networks, communication service providers and information technology services
• We may share your Personal Information to comply with a subpoena, court order, summons, police or other law enforcement agencies, regulatory requests (which may be outside your country of residence) or as required by law.;
• We may share your Personal Information where disclosure is reasonably necessary to:
  
  • satisfy any applicable law, regulation, legal process or enforceable governmental request;
  • Detect or prevent fraud including investigation of potential violations to our Terms of Service;
  • detect, prevent, or otherwise address security or technical issues, or
  • protect against imminent harm to the rights, property or safety of Flutterwave, its users or the public as required or permitted by law.
• We have your consent. In some instances, we may provide a service through a third party, which would require us to share your Personal Information to third parties authorised by you to receive such Information The use of your Personal Information by an authorised third party is subject to the third party's Privacy Notice and Flutterwave shall bear no liability for any breach which may arise from such authorization by you.
• If Flutterwave becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we may share your Personal Information with parties involved in the transaction and any entity that acquires our business will continue to process your Personal Information in line with this Privacy Notice, or a revised version that we will communicate to you.

The security of your Personal Information is important to Flutterwave. We are committed to protecting the information we collect. We maintain administrative, technical and physical controls designed to protect the Personal Information you provide, or we collect against loss or theft, as well as against any unauthorised access, risk of loss, disclosure, copying, misuse or modification.

Other security measures include but are not limited to, secure servers, firewalls, data encryption and granting access only to specific employees in order to fulfil their job responsibilities.

When you use any of your Accounts, we implore you to always use strong passwords (a combination of letters, numbers, upper and lower cases and special characters), enable two-factor authentication on your Accounts, ensure you do not share your password with anyone, and that your login credentials are kept confidential at all times.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of your Personal Information is protected and maintained. We would take all reasonable steps to ensure that your Personal Information is secured and well protected.

We will only retain Personal Information on our servers for as long as is reasonably necessary as long as we are providing Services to you. If you close your Account, your data is stored on our servers to the extent necessary to comply with regulatory and Anti-Money Laundering obligations and for the purpose of fraud monitoring, detection and prevention. Where we retain your Personal Information, we do so in compliance with limitation periods or retention obligations imposed by applicable law.

We may process your Personal Information in order to contact you or send you marketing content and communication about our products, Services or surveys. You may exercise your right to object to such contact from us or opt out from the marketing communication. Please note however that if you opt-out of marketing content, we may still send you messages relating to transactions and our Services, related to our ongoing business relationship.

We may ask you for permission to send notifications to you. Our Services will still work if you do not grant us consent to send you notifications.

When you visit our website, your browser may have the option to send a "Do Not Track" request, which is a request to prevent websites from sending cookies or other trackers to your device. However, please be aware that websites are not obligated to respond to such requests or modify their operations accordingly.

Our website is currently not set up to recognize "Do Not Track" requests. As a result, if we receive such requests from your browser, we will not treat you differently, and we may not comply with the "Do Not Track" settings on your browser. It's important to note that there is no consistent industry standard for how websites should respond to "Do Not Track" requests.

Our website is currently not set up to recognize "Do Not Track" requests. As a result, if we receive such requests from your browser, we will not treat you differently, and we may not comply with the "Do Not Track" settings on your browser. It's important to note that there is no consistent industry standard for how websites should respond to "Do Not Track" requests.

Flutterwave’s services and applications are not directed at persons under the age of eighteen (18) and we do not collect any Personal Information knowingly or directly from individuals who fall within this category.

Where you have any belief that Flutterwave has mistakenly or unknowingly collected information from a minor, please contact us to enable us to investigate and restrict such data collection.

Flutterwave has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Protection Legislation. To exercise your rights or if you have any inquiries, comments or concerns with our privacy practices, please contact us at privacy@flutterwavego.com. We will investigate and work on resolutions for your concerns within forty-five (45) days and/or in accordance with the Data Protection Legislation.

Where we require more time to resolve your inquiry, we would communicate with you. We may request additional details from you regarding your inquiries and keep records of your requests and resolution.

If you feel that we have not addressed your questions or concerns adequately, you may contact the Information Commissioner’s Office here