BILLSNPAY PRIVACY NOTICE

This page contains BILLSNPAY Privacy Notice.

  1. Introduction

    BillsnPay ("We", "Our", or "Us") operate https://www.billsnpay.com (the "Website). We are a leading provider of online payments for the semi-formal and informal sector in Nigeria. We offer a diverse range of services such as bills payment, bills presentment (invoicing) and bills aggregation ("Services")

    This Privacy Notice (together with any other documents referred to in it) sets out in clear and concise form Our practices and procedures regarding the collection, use and disclosure of your personal data and sensitive personal data when you visit, access, browse through and/or use or Services. You have control over the type of data that you make available to Us. Using the controls highlighted in this Privacy Notice, you can limit or withdraw the information We collect about you or determine how We use such information.

    Please note that our Online Channels may contain links to other third-party websites and features that are not owned or controlled by BillsnPay. We advise that you review the privacy notices of these third parties before consenting to the submission of your information or data on their platforms, as this Privacy Notice will not apply to the practices of companies that we do not own or control.

    All information that you provide, by means of details entered onto Our Website, will be handled according to the provisions of applicable data protection laws and in the manner set forth in this Privacy Notice.

  2. The Data We Collect About You

    Visitors to Our Website can access the Website’s home page and browse some areas of the Website, without disclosing any personal or sensitive personal data. However, We may collect information captured in Our web logs, including the Website and App you came from (known as the referring URL), any BillsnPay online advertisements located on third party websites that you may have clicked on to access Our Services, your device information, unique identification numbers (e.g. IP address and device ID), browser information, website traffic and pages viewed, and other information about how you interacted with Our website.

    In addition, We collect information from you that includes personal data in the context of Our operation, personal data entails any information relating to you, through which We identify or can identify you as a living individual (such as your name, gender, email address, and telephone number).

    If you sign up to receive marketing communications from Us, We will collect your name and email address in order to email you regarding products and services that you have indicated are of interest to you.

    If you contact Us with a question, comment, or complaint, We may collect your name and contact information (such as your email address or mailing address) in order for Us to respond to your request. We may also keep a record of the correspondence in order to assist you in the future if you consent to it.

  3. How We Use Your Personal Data

    We will only use the information collected from you for the purpose for which We collected it, which may include the following:

    Where We need to process your information for additional purposes that We have not identified at the time of collection, We will make sure to obtain your consent or the appropriate legal basis for these additional uses to the extent required by applicable law.

  4. What is the Legal Basis For Processing Your Information?

    Here, we have set out the relevant basis upon which We process your information:

    1. Consent

      One of the legal basis for processing your Personal Data is consent. If we have to use consent as a legal basis, we will provide you with a consent form. You have the right to refuse to consent or withdraw your consent at any time by contacting us at info@billsnpay.com

      Consent is the legal basis we use to install non-function or essential cookies, which you will be allowed to consent to. However, we should mention that withdrawal of consent would not affect the lawfulness of any processing carried out before you withdraw your consent

    2. Performance of a Contract

      We may also process your information on the basis that we need to perform and fulfill a contract with you.

    3. Legal Obligation

      We may process your information if it is specifically provided in a legislation or where it is necessary to respond to a lawful request from a law enforcement or regulatory authority, body or agency; in the defense of legal claims or in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of any of our Platform(s)’ terms.

    4. Vital Interests

      We may process your personal and sensitive personal data where it is necessary to protect an interest which is essential for your life, health, and bodily safety. For clarity sake, please note that this basis is limited in scope and will come into play in matters of life and death, for instance where We have not obtained your consent (because you are physically or legally incapable of giving it) or have any other appropriate legal basis for processing your personal data and We have to manage a situation of emergency medical care involving you.

    Public Interest

    We may process your information where it is necessary for the performance of a task carried out in the public interest or in order to fulfil a public mandate imposed on us.

  5. Your Rights as a Data Subject

    Here is something we have not told you yet: because we determine the purposes for and the manner in which your Personal Data may be processed, we are regarded as a data controller.

    As a data subject, the law vests you with certain rights—they include the right to:

    1. access Personal Data we hold about you;
    2. correct such information where you believe it to be inaccurate;
    3. restrict the processing of your Personal Data in certain circumstances;
    4. object to the processing of your Personal Data where we intend to process such data for marketing purposes; where feasible, receive all Personal Data you have provided to us—in a structured, commonly used, and machine-readable format— and to transmit the information to another data controller;
    5. withdraw your consent;
    6. request the erasure of your Personal Data (also known as the right to be forgotten); and
    7. lodge a complaint with a relevant authority, where you have reason to believe that we have violated the term(s) of this Privacy Notice. (You may lodge a complaint or seek redress from us within 30 days from the time you first detected the alleged violation.).

    You may seek to exercise any of the above rights at any time by sending us an email at info@billsnpay.com

    For the purpose of this notice, the supervisory authority is the National Information Technology Development Agency (NITDA) and the complaint can be send via email at dpo@nitda.gov.ng

    Cookies and Web Beacons

    A cookie is a small text file, which includes a unique identifier, which is sent by a web server to the browser on your computer, mobile phone or any other internet-enabled device when you visit an on-line site. Cookies and similar technologies are widely used to make websites work efficiently and to collect information about your online preferences. For simplicity, we refer to all these technologies as "cookies". The cookies we use can be categorised into strictly necessary, functionality, and analytics cookies.

    We also use web beacons—electronic images (or single-pixel gifs) that we use to help deliver cookies on our Online Channels. We also use web beacons in our emails and newsletters. Therefore, when we send emails to you, we may track behavior such as who opened the emails. This allows us to measure the performance of our email and newsletters campaigns.

  6. Information Sharing with Third Parties

    BillsnPay will, in certain circumstances, share your information with third parties, such as service providers or partners to enable the functionality of Our Service(s) or improve our Services. This might also include sharing your information or the information you provide to Us or to make certain features of the Services available to you. When we do have to share your information with third parties, we take steps to protect your information by requiring these third parties to enter into a Third-Party Data Processing Contract with Us that requires them to use the information we transfer to them in a manner that is consistent with this Privacy Notice and applicable laws.

    We may also disclose your information to third parties:

      To monitor and analyse the use of our Service or to contact You;
    1. In connection with, or during due diligence or negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company;
    2. If you give your explicit consent;
    3. If we have to complete a contract on your behalf;
    4. If there is a legal obligation on us to share such data under existing laws and regulations. The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
      • Comply with a legal obligation;
      • Protect and defend the rights or property of the Company;
      • Prevent or investigate possible wrongdoing in connection with the Service;
      • Protect the personal safety of Users of the Service or the public; and
      • Protect against legal liability.

    Please note that we may also share your information (personal and non-personal) with our potential and current financiers and financial investors, and in connection with, or during due diligence or and negotiations of, any proposed or actual financing, merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of BillsnPay; or if we are duty bound to disclose or share your Personal Information in order to fulfil any legal requirements, or in order to administer or enforce customer agreements and applicable terms and policies.

  7. Data Security

    At BillsnPay, We are very particular about preserving your privacy and protecting your personal data. Therefore, to avoid the loss, theft, misuse and unauthorised access, disclosure, alteration, and destruction of your information, we have put in place a range of administrative, technical, organisational and physical safeguards. Despite this, we cannot completely guarantee the security of any information you transmit via our Online Channels, as the internet is not an entirely secure place. We are committed to doing our best to protect you.

  8. Retention of Personal Information

    We will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Also, a contract between us could also prescribe a retention period, we will not retain your data beyond the duration prescribed in the contract.

    We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

  9. International Transfer

    Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside Nigeria or other governmental jurisdiction where the data protection laws may differ than Nigeria.

    The Company will take all steps necessary to ensure that Your data is treated securely and in accordance with this Privacy Notice and no transfer of Your Personal Data will take place to an organisation or a country unless there are sufficient controls in place including the security of Your data and other personal information. We would also ensure your data is transferred outside the country with appropriate legal mechanisms in compliance with the applicable law.

  10. Links to Other Websites

    Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Notice of every site You visit.

    We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

  11. Changes to Our Privacy Notice

    We may update our Privacy Notice from time to time. We will notify You of any changes by posting the new Privacy Notice on this page.

    We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Notice. You are advised to review this Privacy Notice periodically for any changes. Changes to this Privacy Notice are effective when they are posted on this page

  12. Contact Us

    If you have any questions about this Privacy Notice, You can contact us by email: info@billsnpay.com

Last Updated 31 st August 2020