(a) Direct Collection

Such as Information you provide when creating an account, Data you input when using our services (e.g., initiating transfers, exchanging currencies), Information shared during customer support interactions, and Surveys or feedback forms you complete.

• Information you provide when creating an account
• Data you input when using our services (e.g., initiating transfers, exchanging currencies)
• Information shared during customer support interactions
• Surveys or feedback forms you complete

(b) Automated Collection

Such as through cookies and similar technologies when you use our website or mobile app, via server logs and analytics tools, and through your device when you use our mobile app.

• Through cookies and similar technologies when you use our website or mobile app
• Via server logs and analytics tools
• Through your device when you use our mobile app

(c) Third-Party Sources

Such as Identity verification services, Credit reference agencies, Public databases, and Social media platforms (if you choose to link your account).

• Identity verification services
• Credit reference agencies
• Public databases
• Social media platforms (if you choose to link your account)

(a) Consent

Where you have given clear consent for us to process your personal data for a specific purpose.

• Where you have given clear consent for us to process your personal data for a specific purpose.

(b) Contract

The processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.

• The processing is necessary for a contract we have with you.
• Because you have asked us to take specific steps before entering into a contract.

(c) Legal Obligation

The processing is necessary for us to comply with Nigerian law or international laws applicable to our operations.

• The processing is necessary for us to comply with Nigerian law.
• Or international laws applicable to our operations.

(d) Legitimate Interests

The processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.

• The processing is necessary for our legitimate interests.
• Or the legitimate interests of a third party.
• Unless there is a good reason to protect your personal data which overrides those legitimate interests.

(a) Service Provision and Account Management

Such as Facilitating the creation and management of your BaseWallet account, Processing transactions, including currency exchanges and remittances, Managing multicurrency accounts and balances, and Providing customer support and responding to your inquiries.

• Facilitating the creation and management of your BaseWallet account
• Processing transactions, including currency exchanges and remittances
• Managing multicurrency accounts and balances
• Providing customer support and responding to your inquiries

(b) Enhanced Functionality and User Experience

Such as Personalizing your experience within the app, Offering tailored financial advice and product recommendations, Implementing and improving our financial management tools, and Facilitating the subscription model for added benefits (e.g., health and travel insurance).

• Personalizing your experience within the app
• Offering tailored financial advice and product recommendations
• Implementing and improving our financial management tools
• Facilitating the subscription model for added benefits (e.g., health and travel insurance)

(c) Communication

Such as Sending transactional notifications (e.g., transfer confirmations, balance updates), Providing important account-related information, Delivering marketing communications about our products and services (with your consent), and Conducting surveys and collecting feedback to improve our services.

• Sending transactional notifications (e.g., transfer confirmations, balance updates)
• Providing important account-related information
• Delivering marketing communications about our products and services (with your consent)
• Conducting surveys and collecting feedback to improve our services

(d) Security and Fraud Prevention

Such as Verifying your identity and conducting Know Your Customer (KYC) checks, Detecting and preventing fraudulent activities, unauthorized access, and other illicit uses of our platform, and Enhancing the security of our services and protecting your account.

• Verifying your identity and conducting Know Your Customer (KYC) checks
• Detecting and preventing fraudulent activities, unauthorized access, and other illicit uses of our platform
• Enhancing the security of our services and protecting your account

(e) Legal and Regulatory Compliance

Such as Verifying your identity and conducting Know Your Customer (KYC) checks, Detecting and preventing fraudulent activities, unauthorized access, and other illicit uses of our platform, and Enhancing the security of our services and protecting your account.

• Verifying your identity and conducting Know Your Customer (KYC) checks
• Detecting and preventing fraudulent activities, unauthorized access, and other illicit uses of our platform
• Enhancing the security of our services and protecting your account

(f) Business Operations and Improvement

Such as Analyzing usage patterns to improve our products and services, Conducting research and development for new features, Generating aggregated, anonymized data for business intelligence and market analysis, and Maintaining and enhancing the technical functionality of our platform.

• Analyzing usage patterns to improve our products and services
• Conducting research and development for new features
• Generating aggregated, anonymized data for business intelligence and market analysis
• Maintaining and enhancing the technical functionality of our platform

(a) Service Providers and Business Partners

Such as Payment processors to facilitate transactions, Banking partners for account linking and fund transfers, Identity verification services for KYC compliance, Cloud storage providers for secure data storage, Analytics providers to help us understand app usage and improve our services, Customer support tools to assist with inquiries, and Insurance providers for subscription-based insurance services.

• Payment processors to facilitate transactions
• Banking partners for account linking and fund transfers
• Identity verification services for KYC compliance
• Cloud storage providers for secure data storage
• Analytics providers to help us understand app usage and improve our services
• Customer support tools to assist with inquiries
• Insurance providers for subscription-based insurance services

(b) Financial Institutions and Networks

Such as Banks and other financial institutions to process transactions, International remittance networks to facilitate cross-border transfers, and Currency exchange platforms for real-time currency conversion.

• Banks and other financial institutions to process transactions
• International remittance networks to facilitate cross-border transfers
• Currency exchange platforms for real-time currency conversion

(c) Regulatory Authorities and Law Enforcement

Such as Financial regulatory bodies as required by law, Law enforcement agencies in response to valid legal requests, and Government bodies for tax reporting and other legal compliance matters.

• Financial regulatory bodies as required by law
• Law enforcement agencies in response to valid legal requests
• Government bodies for tax reporting and other legal compliance matters

(d) Other BaseWallet Users

Limited information (such as name and transaction details) may be shared with other users when necessary to complete peer-to-peer transfers or other user-initiated transactions.

• Limited information such as name and transaction details

(e) Corporate Transactions

In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred to the acquiring entity.

• Your information may be transferred to the acquiring entity

(f) With Your Consent

We may share your information with other third parties when you have given us your explicit consent to do so. We do not sell your personal information to third parties for their marketing purposes or other commercial use.

When sharing data with third parties, we take steps to ensure that these entities maintain appropriate security measures to protect your information. We enter into data processing agreements that restrict how these parties can use your data and require them to implement adequate security controls.

(a) Encryption

All sensitive data is encrypted in transit using TLS/SSL protocols and Data at rest is encrypted using industry-standard encryption algorithms.

• All sensitive data is encrypted in transit using TLS/SSL protocols.
• Data at rest is encrypted using industry-standard encryption algorithms.

(b) Access Controls

Such as Strict access controls and authentication mechanisms for our systems, Regular audits of access privileges and Multi-factor authentication for critical operations.

• Strict access controls and authentication mechanisms for our systems.
• Regular audits of access privileges.
• Multi-factor authentication for critical operations.

(c) Network Security

Such as Firewalls and intrusion detection systems to monitor and protect our networks and Regular vulnerability scans and penetration testing.

• Firewalls and intrusion detection systems to monitor and protect our networks.
• Regular vulnerability scans and penetration testing.

(d) Physical Security

Secure data centers with 24/7 monitoring, biometric access controls, and surveillance.

• Secure data centers with 24/7 monitoring.
• Biometric access controls and surveillance.

(e) Employee Training

Comprehensive security awareness training for all employees and Background checks for employees with access to sensitive data.

• Comprehensive security awareness training for all employees.
• Background checks for employees with access to sensitive data.

(f) Incident Response

A dedicated team for monitoring and responding to security incidents and Regular testing of our incident response plans.

• A dedicated team for monitoring and responding to security incidents.
• Regular testing of our incident response plans.

(g) Compliance

Adherence to international security standards and best practices and Regular third-party security audits.

While we implement these security measures, it's important to note that no method of electronic storage or transmission over the internet is 100% secure. We strive to protect your personal information but cannot guarantee its absolute security.

(a) Legal and Regulatory Requirements

Such as Anti-money laundering regulations, Tax laws, and Financial record-keeping requirements.

• Anti-money laundering regulations
• Tax laws
• Financial record-keeping requirements

(b) Operational Needs

Such as Ongoing account management, Fraud prevention and security, and Customer support and dispute resolution.

• Ongoing account management
• Fraud prevention and security
• Customer support and dispute resolution

(c) Contractual Obligations

Duration of your agreement with BaseWallet and Post-termination periods as specified in our terms of service

When your data is no longer needed for these purposes, we will securely delete or anonymize it. If it is not possible to delete or anonymize your data (for example, because it has been stored in backup archives), we will securely store your data and isolate it from any further processing until deletion is possible.

(a) Right to Access

You can request a copy of the personal information we hold about you.

• You can request a copy of the personal information we hold about you.

(b) Right to Rectification

You can ask us to correct or update any inaccurate or incomplete personal information.

• You can ask us to correct or update any inaccurate or incomplete personal information.

(c) Right to Erasure (Right to be Forgotten)

In certain circumstances, you can request that we delete your personal information.

• In certain circumstances, you can request that we delete your personal information.

(d) Right to Restrict Processing

You can ask us to temporarily or permanently stop processing your personal information.

• You can ask us to temporarily or permanently stop processing your personal information.

(e) Right to Data Portability

You can request a copy of your personal information in a structured, commonly used, and machine-readable format.

• You can request a copy of your personal information in a structured, commonly used, and machine-readable format.

(f) Right to Object

You can object to our processing of your personal information for certain purposes, such as direct marketing.

• You can object to our processing of your personal information for certain purposes, such as direct marketing.

(g) Right to Withdraw Consent

Where we rely on your consent to process your data, you can withdraw this consent at any time.

• Where we rely on your consent to process your data, you can withdraw this consent at any time.

(h) Right to Lodge a Complaint

You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe we have not handled your personal information in accordance with applicable laws.

To exercise these rights or to make any requests regarding your personal information, please contact our Data Protection Officer using the information provided in Section 2. We will respond to your request within the timeframe specified by the NDPA.

Please note that some of these rights may be limited where we have compelling legitimate grounds or legal obligations to continue processing your personal information.

(a) Adequacy Decisions:

Where applicable, we rely on adequacy decisions about certain countries for data transfers.

(b) Standard Contractual Clauses:

We use standard contractual clauses approved by the Nigeria Data Protection Commission in our agreements with service providers and partners

(c) Consent:

In some cases, we may obtain your explicit consent for international transfers.

(d) Necessity:

We may transfer data internationally when it's necessary for the performance of a contract with you or for your benefit.

For international transfers, we ensure compliance with the NDPA's requirements for cross-border data transfers, including obtaining authorization from the Nigeria Data Protection Commission where necessary.

By using BaseWallet, you acknowledge and consent to these international transfers of your personal information. If you have questions about our international data transfers, please contact our Data Protection Officer.