This privacy policy applies to our website and mobile application provided by Workfave Limited and discloses our data protection practices
Last updated: January 19, 2025
This privacy policy ("Policy") applies to the website and mobile application (hereinafter referred to as, the "Sites") provided by Workfave Limited ("Workfave", "we", "us", "our"), and other products/services of Workfave. This Policy discloses our data protection practices on our Site, products and subscriber-based services ("Services"), inclusive of the type of personal data that we collect, our method of collection of personal data, use of personal data and procedures for sharing personal data with third parties.
The Sites covered by this Policy include our existing website, mobile applications and all other additional websites and mobile applications produced and managed by Workfave - www.workfave.com
We are committed to protecting your personal data (i.e. any information you provide to us through which you can be identified) in accordance with the provisions of the Nigeria Data Protection Act 2023 and other applicable data protection laws ("Data Protection Laws").
By visiting the Sites (including all websites and mobile applications which may be added or removed from time to time) you agree to this Privacy Policy. By continuing to visit our website and use our services you accept and consent to the practices contained in our privacy policy.
In compliance with the provisions of Data Protection Laws, we process your personal data in line with the following legal basis:
Consent: where you have consented to our processing of your personal data for one or more specific reasons. Such consent is given by you through your continuous use of the Services and the Sites.
Performance of a contract: in order to perform a contract we have with you or a contract to which you are a party to and in order to take necessary steps at your request prior to entering into such a contract.
Legal obligation: where processing of personal data is required by law. We are required by law to retain certain account opening information and personal data of our customers beyond the date such customers cease to carry on business with us.
Legitimate interest: in order to protect legitimate interests of data subjects, and in order to carry out the purposes of our business, such as account opening, and processing financial transactions. In addition to this, we have a legitimate interest to prevent fraud, money laundering and to verify identity of data subjects, in order to protect our customers and business, to understand how people interact with our Sites, to provide communication which we think will be of interest to you and to determine the effectiveness of promotional campaigns and advertising.
Vital interest: in order to process data for data subjects when they are in critical life-threatening situations where they may not be able to provide consent for data processing, and which may be vital for the subjects survival.
Public interest: such processing is necessary for the performance of a task carried out in the interest of the public on in exercise of an official public mandate vested on us.
When you use the Sites or Services, we collect and store your personal data which is provided by you from time to time. Personal data/information in this context shall include all data such as: any means of information relating to an identified or identifiable natural person who can be identified by:
A name
An identification number
Location data, an online identifier
Address, a photo, an email address
Facial recognition data
Bank details
Posts on social networking websites
MAC address, IP address, IMEI number, etc.
For the purpose of accessing our Services, the personal data we may collect include: your full legal names, title, date of birth, gender, photo, facial recognition data, business name, email address, mailing address, telephone number, bank account number, payment card details, bank verification number, national identification number, international passport number, means of identification, guarantors contact details, bank statements, usernames, password, your preferences, interests, feedback and survey responses, preference in receiving marketing information from us and our third parties and your communication preferences, etc.
Our primary goal in collecting the above stated personal data is to provide you with a safe, efficient, smooth and customised experience. This allows us to provide services and features that most likely meet your needs.
We collect information you provide directly to us, for example, we collect information when you register or log on to the Site, create an account, subscribe to a Service, participate in any interactive features on our Services, fill out a form, take part in surveys, post on our message boards, upload any documentation, request customer support, make an enquiry, communicate with us by email, phone or post, interact with us on social media, etc.
We will also collect your information where you partially complete and/or abandon any information inputted in the Sites and may use this information to contact you to remind you to complete any outstanding information.
Every computer connected to the internet is given a domain name and a set of numbers that serve as that computer's internet protocol "IP address". When you use the Site, our web servers automatically recognize your domain name and IP address. The domain name and IP address reveals nothing personal about you other than the IP address from which you have accessed the Sites. We are able to see information relating to your browsing patterns and technical data about the equipment you use to access the website through the use of cookies, server logs and other similar technologies.
We may also collect technical data from third parties/public sources such as analytics providers, identity verification providers, advertising networks, search information providers. We may obtain contact, financial and transaction data from providers of technical, payment, credit referencing and delivery services based both inside and outside Nigeria.
We do not own personal data provided and will only store such data for a period as required by law and we will do our best to ensure that such personal data is secured against all foreseeable hazards and breaches such as theft, cyber-attack, viral attack, unauthorised dissemination, manipulation of any kind, damage by rain, fire or exposure to other natural elements.
The purpose of collecting your personal data is to give you an efficient, enjoyable, secure and seamless customer experience. We may use your personal data based on your consent for the following purposes:
To respond to your enquiries and fulfil any of your requests for information
To process transactions and send notices about your transactions
To verify your identity
To resolve disputes and troubleshoot problems
To improve our services by implementing aggregate customer preferences
To manage and protect our information technology infrastructure
To monitor traffic patterns and usage of the Site
To record and store communications made via phone, Skype or chat
To personalise your experience on our Sites
To send you important information regarding the services
To poll your opinions through surveys or questionnaires
To comply with legal obligations and protect vital interests
Your personal data is protected by legal rights enshrined in Data Protection Laws. These rights include the following:
Right to be informed - confirmation as to whether Workfave is storing or otherwise processing personal data relating to you
Right to request a copy of your personal data in a commonly used electronic format
Right to correction of your personal data that is inaccurate, out of date, incomplete, or misleading
Right for erasure of your personal data, without undue delay
Right to withdraw consent at any time to the processing of personal data
Right to object to the processing of your personal data
Right to data portability
Right to lodge a complaint with the Nigeria Data Protection Commission (NDPC)
To exercise any of the above stated rights, please put your request in writing and send it to us at privacy@workfave.com through your usual registered channel and specify the right you wish to exercise.
We will endeavour to process all subject access requests within thirty (30) days and if any further extension is required, we will communicate same through existing consented channels at no cost.
We will not retain your personal data for longer than is necessary for the purposes for which such personal data is processed. This means that your personal data will only be retained for as long as it is still required by law to provide you with the Services or is necessary for legal reasons.
Our Payment Card Industry Data Security Standard ("PCIDSS") obligation means that we are obliged to retain personal data for a minimum of ten (10) years from the end date of our business relationship with you.
When we determine that personal data can no longer be retained (or where you request that we delete your personal data in accordance with your rights contained in Data Protection Laws) we ensure that such personal data is securely deleted, anonymised or destroyed.
On at least a quarterly basis, we systematically remove and destroy all cardholder data details that has exceeded its retention period, and review and ensure the remaining stored cardholder data remains within the formal retention requirements.
In order to protect your personal data, we have put in place appropriate organisational and technical security measures. These measures include storing data on a dedicated and secure server with at least 256-bit encryption, restricting access to your personal data to certain employees, ensuring that our internal information technology systems are suitably secure, and implementing procedures to deal with any suspected data breach.
In the unlikely event of a data breach, Workfave will take steps to mitigate any loss or destruction of data and, if appropriate, will notify you and any applicable authority of such a breach.
We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. We will do our best to protect your personal data, but we cannot guarantee the security of your personal data which is transmitted to other websites via an internet or similar connection.
As a user of the Services, you understand and agree that you assume all responsibility and risk attached to safeguarding your account with us. You shall at no time whatsoever disclose your password to anyone, nor shall you allow anyone make use of your account.
Due to the fact that we operate in a regulated environment, we cannot ensure that all your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Policy. By way of example (without limiting the foregoing), we may be required to disclose information to the government, regulatory bodies, law enforcement agencies, and third parties for the performance of a task carried out in the interest of the public interest.
We will do our reasonable best to ensure personal data provided by you to us and shared with a Third Party Provider is done in accordance with the provisions of Data Protection Laws.
Workfave may transfer your personal data to third parties ("Third Party Providers") of the following types:
Companies providing employment or identity validation services
Financial product providers
Payment services companies
Banks
Companies providing analytics services
Data, service and software providers
Regulatory and law enforcement bodies
Cookies are small text files stored on your device when you visit a website. These files contain information that helps enhance your browsing experience by remembering your preferences, enabling functionalities, and providing personalised services.
The types of cookies we use:
Necessary Cookies: These are essential for the website to function properly and cannot be disabled.
Performance and Analytics Cookies: These cookies help us analyse site performance and improve its functionality.
Advertising and Targeting Cookies: These cookies are used to deliver relevant advertisements to you.
You have the option to manage your cookie preferences. Most web browsers allow you to control cookies through their settings. You can enable or disable cookies, delete cookies stored on your device, or adjust browser settings to notify you before accepting cookies.
We are constantly trying to improve our Sites and services, so we may need to change this Policy from time to time as well. We will alert you of material changes by, for example, placing a notice on our websites and/or by sending you an email (if you have registered your e-mail details with us) when we are required to do so by applicable law.
We reserve the right to update this Policy as we deem fit, from time to time, without any intimation to you and your continued use of the Sites will signify your acceptance of any amendment to these terms.
Our updated terms will also be displayed on our website www.workfave.com. It is your responsibility to check this Privacy Policy from time to time to verify such updates.
If you believe at any time that we have not handled your personal data in accordance with this Policy, or if you have any questions, comments and requests regarding your privacy and rights, please contact our Data Protection Officer at privacy@workfave.com
We have appointed a Data Protection Officer (DPO) who is responsible for dealing with all such concerns, in addition to overseeing questions relating to this Policy and handling requests in relation to the exercise of your rights.