INTRODUCTION

“Prunny Technologies Limited” (“we” or “us” or “our”) respects the rights and privacy of its users (“user” or “you”). As a data processor, we handle all data within the ambits of the law and respect the rights of our users. This policy sets out the basis on which any personal data we request for or that is provided to us and how they are processed by us. Read the policy carefully to understand our translation of the use of data and practice.

By visiting www.prunny.com/privacypolicy (“our site”) and our Mobile application (the “Application”) you are accepting to the practices described in this policy. The collection and processing of your personal data is in line with the NITDA Agency Act 2007 (the “Act”), Nigeria Data Protection Regulation 2019 (the “Regulations”) and the provisions and prescription of section 5 on National Information Systems and Network Security Standards and Guidelines.

We reserve the right to make changes to this Privacy Policy at any time. We will advise you about any changes by updating the “Most recent Update” date of this Privacy Policy. You are encouraged to periodically review this policy to stay informed on updates. You will be deemed to be aware of any changes to the policy document and will be deemed to have accepted the changes in any of the revised privacy policy by the continuous use of the Application after the date of such revised Privacy policy.

This privacy policy does not apply to third-party applications. Please note that connecting to a third-party application button, you are agreeing to the third-party privacy policy for personal data processing.

INFORMARION WE COLLECT FROM YOU

We may collect information about you in a variety of ways. The information we may collect via the Application depends on the feature of the product that you want to access. You may give us information about you by filling information about yourself on www.prunny.com. This includes information you provide when you register to our site, apply for a loan, search for service features. The information you give us may include your name, address, email and phone number, login information, credit card information, personal description, passport photograph.

Mobile Device Access

We may request access or permission to certain features from your mobile device, including your mobile device’s [Bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage,] and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Data

Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.

Push Notifications

We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

USE OF YOUR INFORMATION

Having the right information about you helps us to provide customized experience and improves or efficiency in providing services to you. Specifically, we may use information collected about you via the Application to:

• Compile anonymous statistical data and analysis for use internally to improve overall experience on our application usage.
• Create and manage your account.
• Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Application to you.
• Email you regarding your account activities.
• Enable user-to-user communications.
• Fulfill and manage purchases, orders, payments, and other transactions related to the Application.
• Generate a personal profile about you to make future visits to the Application more personalized.
• Increase the efficiency and operation of the Application.
• Monitor and analyze usage and trends to improve your experience with the Application.
• Notify you of updates to the Application.
• Offer new products, services, mobile applications, and/or recommendations to you.
• Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
• Process payments and refunds.
• Request feedback and contact you about your use of the Application.
• Resolve disputes and troubleshoot problems.
• Respond to product and customer service requests.
• Send you a newsletter.

COOKIES

Cookies are small files that are placed on your device to store information. Specifically, cookies are small strings of text used to store information that may concern you, your behavior on the web, your preferences, or your device. Cookies are mainly used to adapt the operation of the Website to your expectations, offering a more personalized browsing experience and memorizing the choices you previously made. They do not contain or save any sensitive information about you:

• They don’t store your name
• They don’t store your address
• They don’t store any payment details
• You will not receive any calls or mail as a result of a cookie

How we use cookies:

Specifically, we use cookies to:

• Store information relating to time spent on the Website ( "Session Cookies");
• Store information used to recognize your browser or device; each time you visit our website or use the application
• Store your login name, password and other user information, (optional);
• Analyze your behavior on our website, so we can continue to improve;
• Allow others to advertise on our website or track information about you to tailor advertisements to your needs/preferences;
• Allow us to display advertisements to you on other websites.

Third party cookies:

We also utilize third-party cookies, which are cookies sent by a third-party to your computer or mobile device. The majority of third-party cookies consist of tracking cookies used to identify online behavior, understand interests and then customize advertising for you

Cookies on our Platform may collect information through log data, such as:

• internet protocol (IP) address
• type of browser and device
• operating system
• name of the Internet Service Provider (ISP)
• country information
• date and time of visit
• web page of origin (referral) and exit
• possibly the number of clicks
• Information about your choices, settings and surfing habits related to our Website

Managing Cookies

Your chosen browser will offer cookie management options within their tools. You can set the browser to accept cookies only from specific websites (e.g. this website). More importantly, browsers can also enable you to delete specific cookies. It is even possible to set a browser to reject all cookies. Please be aware that if you choose to block all cookies, our site will not function as intended and you will not be able to use or access many of the services we provide. Rather than blocking all cookies, you may choose to block third-party cookies: this will still allow our website to function as intended.

DATA TRANSFERS ACROSS COUNTRIES

Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate, to enable us to use the information in accordance with this policy and enhance our ability to improve the service continously. Any such information transferred to other countries shall be in compliance with the Act and the Regulations of each country.

DATA STORAGE

The data we collect from you is hosted on our secure servers with AWS. The login information you have choosen to enable you access part or a whole of our service suits are your responsibility for it’s confidentiality. We request that you do not share the login information with anyone.

TRANSMISSION OF DATA USING INTERNET PROTOCOL

The transmission of information via the internet is not completely secured. It is your responsiblity to ensure a secured connections through the internet to access our service. Although we will ensure best practice in protecting your personal data, we cannot guarantee the security of your data transmitted over the internet and the transmission of your data is at your own risk. When we receive your information, we will use our security features built into our platform to prevent unauthorized access.

DATA RENTENTION

Unless a longer retention period is required or permitted by law, we will only hold your data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy. Even if we delete your data, it may persist on backup or archival media for legal, tax or regulatory purposes.

DATA RENTENTION: YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing purposes and to withdraw your consent at any time. Please note that the withdrawal of your consent will not affect the lawful processing of data which we have obtained based on your previous consent. We will usually inform you (before collecting your data) if we intend to use your data for the aforementioned purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us electronically via [email protected]. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

REMEDIES

Each of the parties will be entitled to enforce its rights in the event of a breach of the terms of this privacy policy, to recover damages caused by any breach of the provisions herein and to exercise all other rights existing under law. Any claim or dispute arising in relation to this privacy policy shall be subject to the jurisdiction of the courts of the Federal Republic of Nigeria. We shall not be liable for any breach where a claim in respect of such breach is not brought within one month of the date that such breach arose.

LIMITATION OF LIABILITY

Notwithstanding any other provision in this privacy policy, neither CFIL, its affiliates, officers, directors, employees, attorneys or agents shall have any liability with respect to, and you hereby waive, release and agree not to sue any of them upon, any claim for any special, indirect, incidental, consequential damages suffered or incurred by you in connection with, arising out of, or in any way related to, a breach of this privacy policy.

CUSTOMER CONSENT

By clicking the “I agree to the Terms and Conditions”, which you hereby adopt as your electronic signature, you consent and agree that:

- We can provide materials and other information about your legal rights and duties to you electronically.

- We are authorised to share, receive and use data/information collected from your transaction with other affiliated third parties including but not limited to switching companies, mobile network operators, electricity companies, aggregators, credit bureaus, other financial institutions, e-commerce platforms etc.

ACCESS TO INFORMATION

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee in providing you with details of the information we hold about you.

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you understand any changes to this policy.

CONTACT

All request, concerns, comments and questions regarding this privacy policy should be address to [email protected].