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PRIVACY POLICY

Copaly as a Data Controller recognizes the privacy rights of all natural persons who are part of Copaly or interact with us on all our data processing mediums or platforms. By falling amongst the users of any of our services, we recognize that you are a data subject. As a responsible establishment, we are committed to safeguarding the privacy rights of our data subjects through this strict privacy policy. It shall complement extant legal regulatory framework for the protection of privacy and data rights as may be enacted by authorities from time to time.

This Privacy Policy describes how Copaly technologies and its affiliates (“Copaly,” “we,” or “us”) collects, uses, stores, shares, and protects your information whenever you use the Copaly Site, mobile application, any API directly or through a third-party application, or buy a Copaly product (collectively, “Copaly Site and Services)

Copaly understands the importance of privacy for our users and only collects the information which is necessary. Your information is only shared with our third-party affiliates when necessary. Within Copaly, access to information is limited to only those in the company who require such information for matters related to compliance, customer support, and verification. Copaly will NEVER sell or rent your personal information to third parties.

Consent

We can only function and render services you need with your consent. When you access our platforms and give your consent upon such access, you accept this privacy policy together with the content of our terms and conditions; in particular, as you use the services offered on our website and digital platform or visit any of our offices and submit your data for official or non-official purposes.

Change of Policy

We reserve the right to change this policy at any given time, of which you will be promptly updated. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit this page.

In the event that Copaly makes changes, any changes will become effective when Copaly posts the updated Policy. If Copaly makes any material changes, Copaly will notify you by email or by means of a notice on the Site as to the changes becoming effective.

By using and continued usage of the Site and Services, you consent to the data and information policies and practices prescribed in this Privacy Policy.



Our Responsibilities as a Data controller

We shall to be best of our ability and with reasonable care within our control ensure that your personal data is —

(a) processed in a fair, lawful and transparent manner

(b) collected for specified, explicit, and legitimate purposes, and not to be further processed in a way incompatible with these purposes

(c) adequate, relevant, and limited to the minimum necessary for the purposes for which the personal data was collected or further processed

(d) retained for not longer than is necessary to achieve the lawful bases for which the personal data was collected or further processed

(e) accurate, complete, not misleading, and, where necessary, kept up to date having regard to the purposes for which the personal data is collected or is further processed

(f) processed in a manner that ensures appropriate security of personal data, including protection against unauthorised or unlawful processing, access, loss, destruction, damage, or any form of data breach.

Nature of data we collect

When you visit Copaly, we may collect data including but not restricted to the following;

  • Your IP address.

  • Your contact information and email address.

  • Other information such as interests and preferences.

  • Data profile regarding your online behavior on Copaly.

The above data we collect and more that will be as you provide to us directly when you use Copaly Site and Services. This information we may collect directly from you includes, but is not limited to, your name, email, phone number, date of birth, address, password, digital currency public key, document scans, government identification number, etc.

If you wish to link a bank account or other payment method, Copaly may collect your account number, routing number, bank card number, or other related account information. As Copaly expands to add additional features, you may be prompted to provide additional information. When we deem it necessary for verification, legal, or other reasons, Copaly may prompt you to provide additional contact information, biographic information, social security number or government-issued information including National Identity card/number, tax ID number, or financial information.

Why We Collect Your Data

We are collecting your data for several reasons including but not restricted to:

  • To better understand your needs.

  • To improve our services and products.

  • To send you promotional emails containing the information we think you will find interesting.

  • To contact you to fill out surveys and participate in other types of market research.

  • To customize our service according to your online behavior and personal preferences.

  • Improve and provide a full range of Copaly Site and Services

  • Provide information, such as customer service, notifications, and security notices

  • To detect and prevent fraud and crime

  • To detect and prevent money laundering

  • In compliance with applicable regulatory requirements

  • Send you important information, such as changes in terms, conditions, and policies and/or other administrative information

  • Personalize, manage, and improve Copaly Site and Services;

  • Combine your information with information obtained from elsewhere and others in order to help Copaly understand and improve your needs and personalize and improve Copaly Site and Services and our advertising efforts

  • Verify your identity and/or location in order to allow access to your accounts, conduct online transaction, secure your personal information, and in order to prevent fraud and illegal or unauthorized activity, enforce our user agreements, and comply with laws and regulations.

  • For business purposes, including data analysis, audits, developing and improving products and services, enhancing Copaly Site and Services, identifying usage trends and determining the effectiveness of promotional campaigns

  • Resolve disputes and troubleshooting problems

  • Respond to your inquiries and fulfill your requests

  • Direct marketing and promotional offers on behalf of Copaly and its partners and associates, including via SMS and email; and Fulfill any other purpose for which the information was collected. Copaly will never sell or rent your personal information to any third parties. We will only use or share your information according to the terms of this Policy.

Collection of Data

Our site uses technologies of third-party partners to help us recognize your device and understand how you use our site(s) so that we can improve our services to reflect your interests and serve you advertisements about the [products and/or services] that are likely to be of more interest to you. Specifically, these partners collect information about your activity on our site(s) to enable us to: measure and analyze traffic and browsing activity on our site(s);

Opting-Out

Our partners may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason, you can use the following third-party tools to decline the collection and use of information for the purpose of serving you interest-based advertising:

 

The NAI’s opt-out platform: http://www.networkadvertising.org/choices/ 

Information Collected Automatically

When you use Copaly Site and Services, the following information is collected automatically:

We collect the information you provide to us directly when you use Copaly Site and Services. This information we may collect directly from you includes, but is not limited to, your name, email, phone number, date of birth, address, password, digital currency public key, document scans, government identification number, etc.

Location

Haven given your consent, Copaly may collect your precise geolocation information and device location in order to offer you location-based services, such as a map of Copaly retailers in your area.

Copaly collects information about your transactions and payment activity on Copaly Site and Services, including the amount, time, date, recipient wallet, and type of trade.

Device

Copaly collects information about the device you use to access Copaly Site and Services, including language, type of device, operating system, mobile phone number, mobile network, and other device identifiers. Copaly also logs information about your activity on Copaly Site and Services, such as access times, pages viewed, other pages visited, and IP address.

 

Cookies

When you access the Copaly Site and Services, like most websites and apps, we use cookies or other tracking technologies to collect information. Cookies are small data files placed on your computer or other device that allow Copaly to identify you as a Copaly customer and customize the Copaly experience.

We use both session and persistent cookies when you access our website or content. Session cookies are temporary and expire and no longer have any effect when you log out of your account or close your browser. Persistent cookies remain on your browser until they expire or you erase them.

You are free to decline our cookies if your browser or browser add-on permits, but removing or disabling cookies may interfere with your use and the functionality of the Copaly Site and Services. Please refer to the help section of your browser or browser add-on for instructions and additional information on blocking, deleting, or disabling cookies.

 

Information from Third-Parties.

Copaly may collect information on you from third-party services, including, but not limited to, nonpublic personal information from identity verification sources or public databases.

Protection & Storage of Information

Protection and security of your personal data is a duty we hold dearly. Copaly protects your information, including any non-public personal information that can be used to identify you, such as your government-issued ID number, by using reasonable physical, technical, and administrative security measures. This includes limiting access of your information to employees with only information they need to know to reduce the risks of alteration, disclosure, loss, misuse, and unauthorized access. All of our procedural safeguards are designed to comply with generally accepted standards and applicable laws and regulations. Copaly will store and protect your information securely during and after the life of your Coplay account in compliance with our legal obligations. If you have any questions or concerns about our security measures, you may contact us through our Support Page.

Sharing of Information

Copaly may share the information we collect from you in the following ways.

  1. Copaly will sometimes need to share your information with third-party identity verification services in order to prevent fraud and confirm the validity of information provided against public records. By using Copaly Site and Services, you acknowledge and consent that these service providers may retain and use your information to perform services for Copaly and improve their own services, solely related to identity verification and fraud prevention services.

  2. Where permitted or required by law. We may share information about you with other parties for the interest of Copaly’s business and/or as permitted or required by law, including:

  3. If same is done in compliance with a court proceeding, other legal process or an applicable regulation;

  4. To law enforcement authorities or other government officials, or other third parties pursuant to a court order or other legal process or requirement applicable to Copaly or an affiliated entity;

  5. Where we reasonably believe that the disclosure is necessary or appropriate to prevent an imminent physical harm or financial loss, or in connection with an investigation of suspected (or actual) illegal and/or fraudulent activity;

  6. With credit agencies and data processors for credit reference checks and anti-fraud and compliance purposes – all in accordance to applicable data privacy regulations and laws;

  7. To investigate violations of or enforce a user agreement or other legal terms applicable to any service;

  8. To protect our property, services and legal rights;

  9. As reasonably and legally permitted, to facilitate a purchase or sale of all or part of Copaly’s business, or in the instance of some merger and acquisition;

  10. To support our audit, compliance, and corporate governance functions.

  11. Copaly will sometimes need to share information with service providers performing legal, marketing, and other services on our behalf, sometimes related to the analysis and improvement of the Copaly Site and Services experience.

  12. Copaly may need to share your information to complete a routine third-party financial, legal, or technical audit of Copaly’s operations.

  1. Copaly may need to share your information with local and foreign law enforcement, government officials, or other third parties when compelled to do so by a subpoena, court order, or other legal procedure, or when we believe in good faith that disclosure is necessary to prevent any physical harm, financial loss, to report suspected illegal activity, or to investigate potential violations of our User Agreement.

  1. In the event of a merger, acquisition, or other purchase of Copaly’s assets by another company or other ventures, that company or venture will have access to the information you have provided to Copaly. We will require that the new entity follow the procedures of this Privacy Policy and notify you of any such change in applicable policy.

  1. We will only share your information with other third parties with your given consent or direction to do so, unless we are lawfully permitted to do so without your consent.

  2. Copaly may also share, with affiliates or non-affiliated third parties, anonymized, de-identified information which cannot be reasonably used to identify you.

 

Transborder Transfers of Personal Data

We may transfer your personal data from the country where it was collected to any third party in a foreign country that may not have data protection laws similar to those of the country of collection, for cloud storage purposes or for any other legitimate purpose.

Rights you enjoy as a Data Subject

Your rights under the NDPR include but are not limited to the following:

1. right to data portability,

2. right to erasure,

  1. right to limit processing and

  2. right to obtain your data.

 

  1. Right to Data portability: 

If our processing is performed by computer and is necessary to fulfil a contract with you, or is based on your consent, you have the right to:

    • Receive any Personal Data you have provided to us in a structured, commonly used and machine-readable electronic format.

    • Send your Personal Data to another organization or have us do so for you if it is technically feasible for us to do so.

If your request relates to a set of Personal Data that also concerns other individuals, we may restrict the transfer to only the portion relevant to you, unless you establish that you have also gotten their consent.

  1. Right to erasure

You have the right to ask us to erase your Personal Data if:

      1. In your opinion, your Personal Data are no longer necessary for the purpose(s) they were collected for.

      2. In your opinion, your Personal Data have been unlawfully processed.

      3. Your Personal Data must be erased to comply with a regulation.

      4. Where you withdraw your consent for the processing of the Personal Data (and if this is the only basis on which we are processing your Personal Data).

      5. You object to the possession, provided there are no overriding legitimate grounds for continued processing, or

      6. You object to processing for direct marketing purposes.

If we receive your erasure request, we will also take reasonable steps to inform other data controllers processing the data so they can seek to erase links to or copies of your Personal Data. We may refuse to act on your request to erase your Personal Data if the processing of your Personal Data is necessary:

  • To exercise our right of freedom of expression and information.

  • To comply with the NDPR and relevant Nigerian laws.

  • For the performance of a task carried out in the public interest or to exercise some official authority vested in us.

  • To establish, exercise or defend legal claims.

In these cases, we can restrict the processing instead of erasing your Personal Data if requested to do so by you.

  1. Right to limit processing

You have the right to ask us to restrict the processing of your Personal Data if:

    • You contest the accuracy of your Personal Data and we are in the process of verifying the Personal Data we hold.

    • The processing is unlawful and you do not want us to erase your Personal Data.

    • We no longer need your Personal Data for the original purpose(s) of processing, but you need them to establish, exercise or defend legal claims and you do not want us to delete the Personal Data as a result, or

    • You have objected to processing carried out because of our legitimate interests while we verify if our legitimate grounds override yours.

If processing is restricted, we may process your Personal Data (excepting for storage purposes), only:

    • If you have given us your consent.

    • For establishing, exercising or defending legal claims.

    • For protecting the rights of another natural or legal person, or

    • For reasons of important public interest as defined under the NDPR and relevant Nigerian laws

Once processing is restricted following your request, we will inform you before we lift the restriction.

  1. Right to obtain Personal data

As permitted under law and applicable data privacy regulations, you have the right to ask us whether we hold any Personal Data relating to you and, if we do, to be provided with a copy of that Personal Data in electronic form, unless you want to receive it in any other way (for example, a paper copy). In addition, you can ask us for information on how we use your Personal Data, who we share it with, how long we keep it, where it is stored, and other information to help you understand how we use it.

You also enjoy other rights such as;

  • Requests to Rectify or Erase.

You have the right to ask us to correct your Personal Data (including by means of providing a supplementary statement) if it is inaccurate, or update outdated or incomplete Personal Data without undue delay. Where we cannot correct the Personal Data, we include a note on our files regarding your request to correct your Personal Data.

  • Requests to Object to Automated Decisions: Generally, you have the right to object to any legal decision concerning you or which otherwise significantly affects you if this is based solely on the automated processing of your Personal Data. This includes automated decisions based on profiling. In such instance, you may undertake a legal process to prevent or advance your rights.

Otherwise, we may refuse your request regarding such automated decisions where:

    • Necessary to enter into a contract with you, or for the performance of your contract with us.

    • Permitted by regulations, or

    • Based on your explicit consent.

Our actions on the automated processing involving your sensitive Personal Data (where you have given your explicit consent or the processing is necessary for reasons of substantial public interest), are in complete compliance with the Nigeria Data Protection Regulation (NDPR) and relevant laws.



Consent of Data Subject

Except as otherwise required by operation of law or principles of law, your consent as the Data Subject is the entry point for data processing. You have the right to give, withhold or otherwise withdraw your consent to data processing. Those who seek information and services provided on our website or other platforms shall be deemed to have given constructive consent to our Data privacy policy and to receiving information of specific or of general nature through us from time to time.

Privacy of children under 18

The services on Copaly and its affiliates are made available only to persons who are Eighteen (18) years and above. Hence you must be at least eighteen (18) years old to use Copaly Site and Services. Copaly does not intentionally collect any information from or about any individual under the age of 18.

How to access and edit your information

You can access, review, and edit your personal information from the Settings or Account page after you log in to your Copaly account. If you are unable to edit the information from your account, please contact us through our Support Page for assistance. Copaly may provide you with a copy of the information we keep on you upon request; however, not all information on your account will be made available, such as full government identification number, in order to protect your identity and privacy against fraud. If you close your Copaly account, we will retain your account information in our databases for the required number of years to comply with the various laws and financial service regulations governing Copaly.

Legal Proceedings

Notwithstanding anything in any other enactment, no suit against for any act done in pursuance or execution or intended execution of any enactment or law, or of any public duties or authority, or in respect of any alleged neglect or default in the execution of such enactment or law, duties or authority, shall lie or be instituted in any court unless it is commenced within twelve months next after the act, neglect or default complained of or, in the case of a continuance of damage or injury, within twelve months next after the ceasing thereof.

 

No suit shall be commenced against Copaly, its directors or any officer or servant of Copaly before the expiration of a period of one month after written notice of intention to commence the suit shall have been served upon the Corporation by the intending plaintiff or his agent; and the notice shall clearly and explicitly state the cause of action, the particulars of the claim, the name and place of abode of the intending claimant and the relief which he claims.

The Legal implication of above is that no Legal Proceedings or any such Judicial Process shall be Commenced against the Company without a Written Notice addressed to the Registered Address of The Company stating the details of the Complainant, Demands and Options of Settlement. Such Proceedings can only be Commenced after one Month from the Date the Company received the Notice without a Response or from the Last date of response from the Company.

No Legal Proceedings or any such Judicial Process shall be Commenced against the Company where such Action is not instituted within Six (6) months of the happening of the transaction or incidence Complained of.

Contact.

Please contact Copaly directly through support@copaly.com with any questions or concerns regarding this Privacy Policy.

Disclaimer

IN NO EVENT WILL COPALY, ITS AFFILIATES AND THEIR RESPECTIVE SHAREHOLDERS, MEMBERS, DIRECTORS, OFFICERS, EMPLOYEES, ATTORNEYS, AGENTS, REPRESENTATIVES, SUPPLIERS OR CONTRACTORS BE LIABLE FOR ANY INCIDENTAL, INDIRECT, SPECIAL, PUNITIVE, CONSEQUENTIAL OR SIMILAR DAMAGES OR LIABILITIES WHATSOEVER (INCLUDING, WITHOUT LIMITATION, DAMAGES FOR LOSS OF DATA, INFORMATION, REVENUE, PROFITS OR OTHER BUSINESSES OR FINANCIAL BENEFITS) ARISING OUT OF COPALY SERVICES, ANY PERFORMANCE OR NON-PERFORMANCE OF COPALY SERVICES, OR ANY OTHER PRODUCT, SERVICE OR OTHER ITEM PROVIDED BY OR ON BEHALF OFCOPALY AND ITS AFFILIATES, WHETHER UNDER CONTRACT, STATUTE, STRICT LIABILITY OR OTHER THEORY EVEN IF COPALY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES EXCEPT TO THE EXTENT OF A FINAL JUDICIAL DETERMINATION THAT SUCH DAMAGES WERE A RESULT OF COPLAY GROSS NEGLIGENCE, FRAUD, WILLFUL MISCONDUCT OR INTENTIONAL VIOLATION OF LAW. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION MAY NOT APPLY TO YOU.

NOTWITHSTANDING THE FOREGOING, IN NO EVENT WILL THE LIABILITY OF COPALY, ITS AFFILIATES AND THEIR RESPECTIVE SHAREHOLDERS, MEMBERS, DIRECTORS, OFFICERS, EMPLOYEES, ATTORNEYS, AGENTS, REPRESENTATIVES, SUPPLIERS OR CONTRACTORS ARISING OUT OF SERVICES OFFERED BY OR ON BEHALF OF COPALY AND ITS AFFILIATES, ANY PERFORMANCE OR NON-PERFORMANCE OF COPALY SERVICES, OR ANY OTHER PRODUCT, SERVICE OR OTHER ITEM, WHETHER UNDER CONTRACT, STATUTE, STRICT LIABILITY OR OTHER THEORY, EXCEED THE AMOUNT OF THE FEES PAID BY YOU TO COPALY UNDER THESE TERMS IN THE TWELVE-MONTH PERIOD IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM FOR LIABILITY.