onDgo Privacy Policy

This Privacy Policy describes a user's privacy rights regarding our collection, use, storage, sharing and protection of personal information.It applies to the onDgo website and all related sites, applications, services, and tools regardless of how they are accessed or used.

About onDgo

onDgo is an innovative Nigerian company that deploys technological solutions to the needs of our partners, customers and clients thereby helping them to succeed. We are the first of its kind in Nigeria offering an all encompassing solution covering finance, payment, transport, hospitality and other industries that require distribution of goods and services to existing customers and would-be customers.This privacy policy will explain how our organization uses the personal data we collect from our customers and related partners when they use our website or subscribe to any of our products and services.

Introduction

onDgo conducts business in a responsible and sustainable manner and ensures customer information is securely collected, processed, and stored based on business requirements. In furtherance of this and compliance with industry regulations, onDgo has provided appropriate documentation, which includes a privacy policy. onDgo, therefore, provides notice about this policy and applicable procedures. It identifies the purposes for which personal information is collected, used, processed, disclosed, retained, and disposed. Throughout this Privacy Policy, we use the term "personal information or data" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been made anonymous such that it does not identify a specific user.

Scope and Consent

As a Customer, you accept this Privacy Policy when you sign up for, access, or use our products, services, content, features, technologies or functions offered on our website and all related sites, applications, and services (collectively referred to as “onDgo Services”).

This Privacy Policy is intended to govern the use of onDgo Services by users (including, without limitation those who use these onDgo Services in the daily course of their trade, practice, or business) unless otherwise agreed through contract. Users reserve the right to exercise their data protection right as listed under the Customer Data Protection Rights.

Personal Information Collection

We collect Personally Identifiable Information (PII), otherwise known as Personal Information or Personal Data. The Personal Data that we may collect and Process can vary depending on the onDgo products and services that you use, contract for or that you supply to us; how you may be using or delivering those products and services; and the means by which you may be interacting with us.

We will only collect the Personal Data of yours that is adequate, relevant and limited to what is needed in relation to the specific purposes for which we are collecting it, as described in this privacy notice.

The Personal Data collected and Processed by us may include:

• Account and contact information: which may include your name, contact information (email address, postal address, residential address, telephone number), date of birth, identifying numbers (identity document number, passport numbers and/or national identification number (NIN) other national ID numbers as required); billing information; financial information; any other information required to comply with regulatory requirements;
• Information we collect about contacts: we also collect your contacts’ information with your express approval, such as their name and email address or phone number, if you choose to upload or import it from a device, like by syncing an address book to ensure you have ease of access when buying our services or products.
• Location information: we collect information regarding your physical location / geolocation when you use your device, our products or services and they connect with cellphone towers, wifi routers, bluetooth, beacons, GPS satelites and/or other onDgo technologies or infrastructure;
• Network performance: we collect information which inform our network performance such as your use of our products, services or equipment;
• Financial information: such as your bank account or credit card details; financial history (including information to determine your creditworthiness);
• Usage of your devices, our services and products: data usage (including browsing history); telephone records (including information regarding your incoming and outgoing telephone calls); text message records; video streaming (including your selected packages and usage); purchase activities; and other similar information;
• Web browsing and application usage: we collect your Personal Data when you visit our website or use our mobile applications. This may include, your IP address, browser type; operating system; mobile carrier; your ISP; URLs of sites from which you arrive or leave the website and mobile applications and sites that have our platform technology embedded; time you spend on our website or mobile applications; links or advertisements you see; purchases made through our website; first party cookies and other webtracking technologies. We may also collect information identifying or related to equipment accessing our networks including the software, configuration, equipment type and other unique identifiers (such as your username and password). Third party cookies will also be collected from our selected marketing technology partner(s), third party websites and applications.
• Supplier, reseller, contract and service provider information: which may include name, contact information, billing information, background checks, financial history, employment history, tax information, information related to your performance; any other information which may be required in terms of regulatory requirements applicable to onDgo and/or our policies;
• Multimedia data: such as unaltered photographs, audio recordings, or video recordings;
• Social media information: social media information:we collect your information related to your interaction with our social media accounts, content and marketing campaigns (including your details when you enter into a competition or interact with an advertisements; your comments, your reactions (i.e. ‘likes’)), Personal Data available from your public profile and information you have allowed social media platforms to share with us in terms of your privacy preferences on that platform; and your social media handles;
• Biometric information: such as images of you, fingerprints, voice recording or voiceprint, scan of your face in order to identify you in respect of registration of your MSISDN, any form of account, or during your interaction with our customer service team etc;
• Demographic information: we may collect information related to your gender, race or ethnic origin, age, education, financial status;
• Views, opinions and interests: we collect information regarding your views, opinions and preferences (for example when you participate in a survey or when you provide feedback regarding our products or services or online based behaviour) as well as your interests. In the case of suppliers and resellers, we will obtain the views and opinions of others regarding your performance (e.g. references).
• Cookies: we use cookies to help you navigate efficiently and perform certain functions. You will find detailed information about all cookies on our website.

The cookies that are categorized as “Necessary” are stored on your browser as they are essential for enabling the basic functionalities of the site.

We also use third-party cookies that help us analyze how you use this website, store your preferences, and provide the content and advertisements that are relevant to you. These cookies will only be stored in your browser with your prior consent.

You can choose to enable or disable some or all of these cookies but disabling some of them may affect your browsing experience.

Our process of collecting personal information

Customers’ data is collected electronically when they visit our website and register to use any of our services. This is collected electronically with exchanges between your system (Computer, Server, Mobile Device) or service provider’s system and our system.

We collect Customers’ data manually when they complete our product and services registration forms in registering to use any of our services. Similar data are also collected when customers or visitors visit our physical locations for inquiries or business relationships.

We collect information from or about customers from other sources, such as through your contact with us, including our Customer Support interfaces – email, portal, phone calls, social media, and other communication channels; Customer support teams, Customer response to surveys, Training programs, Corporate Social Responsibility events, Promotional events, and interactions with any other companies related to onDgo (subject to their privacy policies and applicable law).

We may also obtain information about you from third parties such as credit bureaus and identity verification services.

The use of collected Information

We collect personal information to provide users of our services with a secure, smooth, efficient, and customized experience. Furthermore, the information collected may also be used to provide onDgo Services and customer support; process transactions and send notices about your transactions; verify your identity, including during account creation and password reset processes; resolve disputes, collect fees, and troubleshoot problems; manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities; detect, prevent or remediate violations of policies or applicable user agreements.

We also collect personal information to improve Services by customizing your user experience; to measure the performance of onDgo Services and improve their content and layout; manage and protect our information technology infrastructure; provide targeted marketing and advertising, provide service update notices, and deliver promotional offers based on your communication preferences; contact you at any telephone number, by placing a voice call or through text (SMS) or email messaging; perform creditworthiness and solvency checks, and compare information for accuracy and verify it with third parties.

Additionally, we may contact you via electronic means to notify you regarding your account, troubleshoot problems with your account, resolve a dispute, collect fees or monies owed, poll your opinions through surveys or questionnaires, or as otherwise necessary to service your account. Furthermore, we may contact you to offer coupons, discounts, and promotions, and inform you about onDgo Services or its group services.

Finally, we may contact you as necessary to enforce our policies, applicable law, or any agreement we may have with you. When contacting you via phone, to reach you as efficiently as possible we may use, and you consent to receive, auto dialed or prerecorded calls and text messages. Where applicable and permitted by law, you may decline to receive certain communications.

Personal information - protection and storage

We store and process your personal information on our computers in Lagos, Nigeria, and anywhere else where our facilities are located. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration.

Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. We have also taken additional measures by ensuring our system complies with industry information security standards.

Data Retention Period

We keep information as long as we need it to provide our Products, comply with legal obligations or protect our or other’s interests. We decide how long we need information on a case-by-case basis. Here’s what we consider when we decide:

If we need it to operate or provide our Products. For example, we need to keep some of your information to maintain your account. For example, we keep profile information, photos (and not deleted) and security information for the lifetime of your account.

• How long we need to retain the information to comply with certain legal obligations.
• If we need it for other legitimate purposes, such as to prevent harm; investigate possible violations of our terms or policies; promote safety, security and integrity; or protect ourselves, including our rights, property or products.

In some instances and for specific reasons, we’ll keep information for an extended period of time.

Marketing

We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may combine customers’ information with information collected from other companies and use it to improve and personalize onDgo Services, content, and advertising.

We have also included the opportunity for customers who had initially subscribed to receive notifications or information about their activities in relation to the use of onDgo’s service to unsubscribe or request to be removed from applicable databases.

Sharing personal information with other onDgo users

When transacting with others, we may provide those parties with information to complete the transaction, such as your name, account ID, contact details, shipping and billing address, or other information needed to promote the reliability and security of the transaction. If a transaction is held, fails, or is later invalidated, we may also provide details of the unsuccessful transaction.

To facilitate dispute resolution, we may provide a buyer with the seller’s address so that goods can be returned to the seller. The receiving party is not allowed to use this information for unrelated purposes, such as to directly market to you, unless you have agreed to it. Contacting users with unwanted or threatening messages is not authorized by onDgo.

We may provide or display customer information to a third-party while consummating transactions to validate that transactions are being exchanged with valid receivers.

We work with third parties, including merchants, to enable them to accept or send payments from or to Customers using onDgo Services. In doing so, a third party may share information about customers with us, such as email address or mobile phone number, to inform such customers that a payment has been sent. We use this information to confirm that users are onDgo customers and that onDgo as a form of payment can be enabled, or to send customer notification of payment status. Also, we may oblige requests to validate that a customer transacts business with onDgo.

Customers’ card information may be available for their subsequent reuse if they chose for it to be remembered at previous attempts. Do note that merchants, sellers, and users involved in transactions may have their own privacy policies, and onDgo does not allow the other transacting party to use this information for anything other than providing onDgo Services, onDgo is not responsible for their actions, including their information protection practices.

onDgo will not disclose your credit/debit card number or bank account number to anyone or with the third parties that offer or use onDgo Services, except with customers’ express permission or if we are required to do so to comply with credit/debit card rules, a subpoena, law enforcement or other legal processes.

Sharing personal information with other third parties

We may share customers’ personal information with:

1. Members of the onDgo related companies to provide joint content, products, and services (such as registration, transactions, and customer support), to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about their products, services, and communications. This information will only be used for marketing communications only if customers have requested the services.
2. Institutions that we partner with to jointly create and offer products, services, promotions, and rewards as well as institutions that we partner with to run events.
3. Credit bureaus and collection agencies to report account information, as permitted by law.
4. Banking partners as required by credit/debit card association rules for inclusion on their list of terminated merchants.
5. Companies that we plan to merge with or are acquired by. (Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to customer personal information. Customers will receive prior notice if personal information would be used contrary to this policy).
6. Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to onDgo or one of its affiliates; when we need to do so to comply with law or credit/debit card rules; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement.

Other unaffiliated third parties, for the following purposes:

1. Fraud Prevention and Risk Management: to help prevent fraud or assess and manage risk.
2. Customer Service: for customer service purposes, including to help service your accounts or resolve disputes.
3. Shipping: in connection with shipping and related services for purchases made using onDgo Services.
4. Legal Compliance: to help them comply with anti-money laundering and counter-terrorist financing verification requirements.
5. Service Providers: to enable service providers under contract with us to support our business operations, such as fraud prevention, bill collection, marketing, customer service, and technology services. Our contracts dictate that these service providers only use customer information in connection with the services they perform for us and not for their own benefit.

Other third parties with your consent or direction to do so.

1. Please note that these third parties may be in other countries where the laws on processing personal information may be less stringent than in our country of primary jurisprudence.
2. If customers open any of our products and services or related wallet accounts directly on a third-party website or via a third-party application, any information that is entered on such systems (and not directly on an onDgo website) will be shared with the owner of the third-party website or application. These sites are governed by their own privacy policies and customers are encouraged to review their privacy policies before providing them with personal information. onDgo is not responsible for the content or information practices of such third parties.

Other unaffiliated third parties, for the following purposes:

We may share your personal information with:

• Fraud Prevention and Risk Management: To help prevent fraud or assess and manage risk.
• Customer Service:For customer service purposes, including to help service your accounts or resolve disputes.
• Shipping:In connection with shipping and related services for purchases made using onDgo Services.
• Legal Compliance: To help them comply with anti-money laundering, counter-terrorist financing verification requirements and the Central Bank of Nigeria regulations on Know Your Customer (KYC).
• Service Providers: To enable service providers under contract with us to support our business operations, such as fraud prevention, bill collection, marketing, customer service, address verification and technology services. Our contracts dictate that these service providers only use customer information in connection with the services they perform for us and not for their own benefit.

Other third parties with your consent or direction to do so.

• Please note that these third parties may be in other countries where the laws on processing personal information may be less stringent than in our country of primary jurisprudence.
• If customers open any of our products and services or related wallet account directly on a third-party website or via a third-party application, any information that is entered on such systems (and not directly on an onDgo website) will be shared with the owner of the third-party website or application. These sites are governed by their own privacy policies and customers are encouraged to review their privacy policies before providing them with personal information. onDgo is not responsible for the content or information practices of such third parties.

Cross border transfers of personal information

onDgo is committed to protecting customers’ personal information regardless of where the data resides and to providing appropriate protection for where such data is transferred across borders, including outside of Nigeria. We have further taken measures to ensure our relationships are with countries that are governed by similar data protection regulations. onDgo conducts assessments of other entities to provide a reasonable assurance of the safety of customers’ information.

Customer data protection

Our customers have data protection rights and are entitled to the following:

Our customers have data protection rights and are entitled to the following: – Customers have the right to request copies of their personal data. onDgo may charge a fee for this service if it will require a substantial amount of resources to accomplish.

The right to rectification– Customers have the right to request that onDgo corrects any information they believe and have proven has been captured inaccurately. Customers also have the right to request onDgo to complete the information they believe is incomplete.

The right to erasure– Customers have the right to request that onDgo erases their personal data, under certain conditions. These conditions are not limited to regulatory requirements, law enforcement agencies, or where such action may cause disruption to our system.

The right to restrict processing – Customers have the right to request that onDgo restricts the processing of their personal data, under certain conditions. (as above)

The right to object to processing– Customers have the right to object to Our Company’s processing of your personal data, under certain conditions. (as above)

The right to data portability – Customers have the right to request that onDgo transfer the data that we have collected to another organization, or directly to them, under certain conditions. (as above)

Right to judicial review– if we refuse your request under rights of access, we will provide you with a reason to why. You have the right to complain as detailed below.

Right to complain- If you wish to make a complaint about how your personal data is being processed or how your complaint has been handled, you have the right to lodge a complaint directly to our in-house data officer or with the supervisory authority.

If we are unable to help, or you are not satisfied with our response, you also have the right to lodge a complaint with the National Information Technology Development Agency (NITDA).

NITDA can be contacted:

Post Address: No 28, Port Harcourt Crescent, Off Gimbiya Street, P.M.B 564, Area 11 Garki, Abuja, Nigeria.

Telephone:08168401851

Website: nitda.gov.ng.

Customer requests based on any of the rights above shall be handled between 2 to 4 working weeks. Customers may contact us by email or writing to details under the heading “Available Remedies” below.

The use of cookies and similar technologies

When Customers access our websites or use onDgo Services, we may place small data files on your computer or other devices. These data files may be cookies, pixel tags, "Flash cookies," or other local storage provided by your browser or associated applications (collectively referred to as "Cookies"). These technologies are used to recognize users as customers; customize onDgo Services, content, and advertising; measure promotional effectiveness; help ensure that account security is not compromised; mitigate risk and prevent fraud, and promote trust and safety across onDgo Services and related sites.

Users can freely decline our Cookies if the web browser or browser add-on permits unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with users’ use of our websites and onDgo Services.

The privacy policies of other websites

This privacy policy applies to only onDgo Nigeria Limited and not any other brands, though mentioned on our Websites. Neither does it apply to our Merchants, Vendors, or other related partners.

Customer Consent

Please refer to the end of this notice for providing your consent. Your consent to personal data collection and processing may be revoked by notifying us via our contact page. For users below the age of 13, the consent should be provided by the holder of parental responsibility of the child.

Please note, in case you choose to not provide us with the consent or withdraw the consent at any given point in time, we shall not be able to provide the services as detailed above.

Available Remedies

In the event of a violation of this Policy by the Company, we shall immediately upon becoming aware of such violation, assess the extent of the violation and take specific actions such as correction, modification, or transfer of the data, subject to the lawful demands of the data subject. The specific actions of correction, modification, and transfer shall be effected within 30 days, subject to external factors not within the reasonable control of the Company.

Changes to our privacy policy

We review our privacy policy periodically and when there is any substantial change to business or regulatory requirements. At the minimum, we shall review this annually and communicate via our communication channels such as Newsletter, on Website, Social Media Accounts.

How to contact us

Customers who have concerns, questions about the privacy policy or would like to exercise their protection rights can contact us through the following channels:

Email us at: [email protected]

Call us:  0708 860 8926

Or write to us at onDgo Nigeria Limited, Pent House 2, All Seasons Place, No 74, Ogunnusi Road, Beside FRSC Office, Ojodu Berger, Lagos State.