Privacy Policy

INTRODUCTION

This Privacy Policy governs your use of products, services, content, features, or technologies offered by Stow Technologies Limited and all related sites, applications, and platform (collectively "Stow" ,"we," "us," and "our") including, without limitation, when you provide any information to us in relation to your use of Stow services. You accept and consent to this Privacy Policy when you sign up for, access, or use the Stow platform. By accepting and consenting to this Privacy Policy, you expressly consent to our use and disclosure of your personal information, and direct us to do so in the manner described in this Privacy Policy.

USE OF DATA

In order to operate on the Stow platform and to reduce the risk of fraud, (“Stow”, “our”, “us” or “we”), the data controller, may ask you to provide us with information about yourself, including your bank account details and information about any other financial instruments that may be connected to your Stow account, as well as any other types of information specified in section 2 of this Policy. By consenting to, and agreeing to the terms of, this Privacy Policy, you expressly consent and agree to us processing your data in the manner set out herein. This Privacy Policy describes the information we collect and how we use that information. Stow takes the processing of your information very seriously and will use your information only in accordance with the terms of this Privacy Policy. For the purposes of this Privacy Policy, the term “information” means any confidential and/or personally identifiable information or other information related to users of Stow platform, specified in section 2 of this Policy. We will not sell or rent your information to third parties for their marketing purposes without your explicit consent. However, in order for us to offer Stow platform to our users; enhance the quality of the Stow platform from time to time; and protect the interests of our users, we will in limited circumstances share some of your information with third parties under strict restrictions, as described in greater detail in the following sections of this Policy. It is important for you to review this Privacy Policy as it applies to all Stow services. This Privacy Policy is intended to govern the use of Stow platform by our users (including, without limitation those who use the Stow platform in the course of their trade or business) unless otherwise agreed through contract.

Changes to this Privacy Policy:

All future changes to this Privacy Policy are incorporated by reference into the Terms and Conditions (our framework contract) with you and will take effect as specified in the Policy Updates, when they may occur. “Policy Update” means a prior notice of changes to any terms and conditions applicable to Stow services, which Stow will make available to you in writing, including in electronic form. If you disagree with the terms of this Privacy Policy, please do not register for or use the Stow platform.

Notification of Changes:

This Privacy Policy may be revised over time as new features are added to Stow platform, or as we incorporate suggestions from our customers. We may change this Privacy Policy at any time by posting a revised version of it on our website. Unless we have legal grounds to do otherwise, we will provide you with at least 30 days’ prior notice of the effective date of the revised Privacy Policy. We may post the notice on our website and/or send the notice by email. As of the effective date of the revised Privacy Policy, you will be considered as having consented to all changes to the Privacy Policy. If you disagree with the terms of this Privacy Policy, you may close your account at any time. In addition you may discontinue your use of any Stow service. Third Party Websites: Some pages on the Stow website include links to third-party websites. These sites are governed by their own privacy statements, and Stow is not responsible for their operations, including, but not limited to, their information practices. Users submitting information to or through these third-party websites should review the privacy statements of these sites before providing them with personally identifiable information. These third parties may include Advertisers, ad networks and ad servers, Analytics companies, your mobile device manufacturer, your mobile service provider. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Section 2: INFORMATION WE COLLECT


Required Information:

To open a Stow account or use the Stow platform , you may be required to provide your name, address, phone number, date and place of birth, nationality, the details of your identification document, BVN number and email address, or other information to be determined by Stow from time to time. In order to fund your balance with a Stow account or make certain transactions through the Stow platform, you must provide (where applicable) your bank (or another payment instrument, such as mobile wallet) account information. We may also ask you to choose different security questions to answer. We will also require other commercial and/or identification information if you conduct certain high-value transactions or high overall payment volumes through the Stow platform, or as is otherwise required in order for us to comply with our anti-money laundering obligations under applicable laws.

Using your device:

When you utilise Stow platform using any device (whether connected to Stow wirelessly or by a fixed line or otherwise), we may additionally collect and store device sign-on data (including but not limited to device ID) and geolocation data, in order to provide Stow services.

Photographs:

If you use certain functionalities provided by us, we may ask you to upload a photograph of you (for example, the photo of your ID) in order to provide these specific services. Your face must be recognizable.

Transaction Information:

When you use the Stow services to conduct certain transactions we will ask you to provide information related to that transaction. This information includes transactional details. We also collect the Internet address (IP address) and other identifying information about the computer or device you use to access your Stow account or use the Stow platform, in order to help us authenticate you and detect possible instances of unauthorised transactions.

Information about You from Third Parties:

In order to protect all our customers against potential fraud, we verify the information you provide with Payment Partners and/or Credit Reference and Fraud Agencies as well as information available through internet and publicly accessible social network data. In the course of such verification, we may receive personally identifiable information about you from such services. In particular, if you connect a debit or credit card or register a bank account connected with Stow account, we may use card authorisation and fraud screening services to verify that your bank or card or mobile wallet information and address match the information you supplied to Stow, and that the card has not been reported as lost or stolen. If you send or receive high overall payment volumes or display inconsistent transactional patterns through the Stow platform, or if you have a limited transactional history with us, in some circumstances we will conduct a background check on you by obtaining information about you and your business, and potentially (if legally permitted) also about your directors, shareholders and partners, from a credit reference or a fraud agency. Stow, in its sole discretion, reserves the right to periodically retrieve and review a business and/or consumer credit report supplied by such a credit reference or a fraud agency for any account, and reserves the right to close an account based on information obtained during this credit review process.

INFORMATION ABOUT YOU FROM OTHER SOURCES:

We may also collect information about you from other sources, including from other entities of the group to which Stow belongs, other companies (subject to their privacy policies and applicable law), and from other accounts we have reason to believe you control (whether in part or in whole).

ADDITIONAL VERIFICATION:

If we cannot verify the information that you provide, or if you request a withdrawal to an account, payment instrument or digital wallet not previously used by you, we may ask you to upload or send us additional confirmations, or to answer additional questions online to help verify your information.

WEBSITE TRAFFIC INFORMATION:

Because of the way Internet communication standards work, when you arrive at or leave the Stow website, we may automatically receive the web address of the site that you came from or are going to. We also collect information on which pages of our website you visit, IP addresses, the type of browser you use and the times you access our website.

COOKIES, WEB BEACONS, LOCAL STORAGE AND SIMILAR TECHNOLOGIES:

When you access our website, or use Stow platform, we (including companies we work with) may place small data files on your computer or other device. These data files may be cookies, pixel tags, “Flash cookies,” or other local storage provided by your browser or associated applications (collectively “Cookies”). We may use Cookies to recognise you as a customer, customise Stow services, content and advertising, measure promotional effectiveness, help ensure that your account security is not compromised, mitigate risk and prevent fraud, and to promote trust and safety across our sites and Stow platforms. You are free to decline our Cookies if your 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 your use of our website and Stow services

COMMUNICATIONS:

When you communicate with us for customer service or other purposes (e.g., by emails, phone calls, tweets, etc.), we may retain such information and our responses to you in the records of your account, for the purpose of proof of commercial transactions and communications.

QUESTIONNAIRES, SURVEYS AND PROFILE DATA:

From time to time, we offer optional questionnaires or surveys to our users for such purposes as collecting demographic information or assessing users’ interests and needs. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.

ACCOUNT INFORMATION:

For the purposes of this Privacy Policy, account information (“Account Information”) includes without limitation: name, address, date and place of birth, nationality, email address, phone number, fax number, BVN number, username, photograph, IP address, device ID, geolocation information, account numbers, account types, details of funding instruments associated with the account, details of payment transactions, details of commercial transactions, customer statements and reports, account preferences, details of identity collected as part of our “know your customer” checks on you, and customer correspondence.

HOW WE USE THE INFORMATION WE COLLECT

Personal information submitted to us through our website will be used for the purposes specified in this Privacy Policy or on the relevant pages of the Service. We may use your personal information to:
[a] To provide, operate, maintain, improve, and promote the Service, and any other information, products or services that you request from us;
[b] To enable you to access and use the Service, including uploading, downloading, collaborating and sharing content, photos, images, videos and information, with other users or third parties;
[c] To process, verify, and complete transactions, and send you related information, including purchase confirmations and invoices, to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing, collection and enforcement, and to build a user database;
[d] To send transactional messages, including responding to your comments, questions, and requests; providing customer service and support; sending you technical notices, updates, security alerts, and support and administrative messages sending statements, invoices and payment reminders to you, and collecting payments from you; and, when we have location information, we use it to tailor our Service for you and others.
[e] To send promotional communications, such as providing you with information about services, features, newsletters, offers, promotions, contests, events and sending updates;
[f] To monitor and analyze trends, usage, and activities in connection with the Service and for marketing, advertising, administrative, analytical, research, optimization, and other purposes. For example, we may use statistical analyses of usage data in order to measure interest in the various areas of the Service, for development purposes and to inform advertisers and partners in aggregate and anonymous terms about consumers who click on their advertising or other messages. IP addresses are also used for systems administration and troubleshooting purposes.
[h] To investigate and prevent fraudulent transactions, unauthorized access to the Service, and other illegal activities;
[i] To personalize the Service’s content, features or advertisements;
[j] To deal with enquiries and complaints made by or about you relating to the Service;
[k] To verify compliance with the terms and conditions governing the use of the Service; and
[l] To comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies. If you submit personal information, including User Content, for publication on the platform, we will publish and otherwise use that information in accordance with the license you grant to us, and by submitting such information to us, you hereby grant us a worldwide, revocable, sub licensable and royalty-free license to use such personal information for our business purposes. You shall be solely responsible for your own User Content and the consequences of submitting and publishing your User Content on the Service. You further agree that you will not submit to the Service any User Content or other material that is contrary to this Privacy Policy or contrary to applicable local, national, and international laws and regulations.

MARKETING

If you don’t wish to receive marketing communications from us, or to participate in our ad-customisation programs, simply update your preferences.

DISCLOSING PERSONAL INFORMATION.

Just like most banks or financial/payment service providers, Stow works with third-party service providers which provide important functions to us that allow us to be an easier, faster, and safer way to make payments, and other business partners. We need to disclose user data to them from time to time, so that the services can be performed. Stow will not transfer, disclose, sell or rent any of your personal information to third parties or their marketing purposes without your explicit consent, and will only disclose this information in the limited circumstances and for the purposes described in this Privacy Policy. In order to provide the Stow services, some information we collect from or about you, may be required to be transferred to other entities, in their capacity as payment providers, converters, payment processors or account holders (or similar capacities). You acknowledge that according to applicable legislations, such entities may be subject to laws, regulations, inquiries, investigations, or orders which may require the disclosure of information to the relevant authorities in Nigeria. Specifically, you consent to and direct Stow to disclose your information with the following:
- Service Providers. We engage service providers to perform functions and provide services to us. We may share your private personal information with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions.
- Authorized Personnel. Our employees, agents, consultants, contractors, or other authorized personnel, including those of our contractors, service providers, subsidiaries and affiliates, may have access to user information as necessary in the normal course of our business.
- Business Transfers. In some cases, we may choose to buy or sell assets, or have engaged in discussions with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Service users is among the assets transferred. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if the Service, the Company, or substantially all of its assets, were acquired, liquidated, or dissolved, personal information would be one of the assets that is transferred.
- Government, Law Enforcement or Third Parties. We may disclose any information, including, without limitation, Personal Information that we deem necessary, in our sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. We also may exchange information, including, without limitation, Personal Information, with other companies and organizations to protect the rights, property, or safety of the Company and its affiliates, personnel, users, third parties, or others. We reserve the right to disclose a user’s Personal Information if we believe, in good faith, that the user is in violation of the Terms of Service, even without a subpoena, warrant or other court order.
- Social Media Networks. We may include applications or widgets from social media networks that allow interaction or content sharing by their users. These widgets, such as a Facebook “Share” or “Like” button, are visible to you on the web page you visit. Integration between the Service and social media networks such as Facebook, Twitter and others may allow social media networks in which you participate to collect information about you, even when you do not explicitly activate the network’s application or widget. Please visit the applicable social media network’s privacy policy to better understand their data collection practices and choices they make available to you. The privacy policy of the social media network controls the collection, use and disclosure of all personal information transmitted to that network.

YOUR RIGHTS.

We will provide you with an opportunity to exercise certain controls and choices regarding our collection, use and sharing of your information through Opt-out options. In accordance with local law, your controls and choices may include:
[a] You may correct, update and delete your account information, as described below;
[b] You may change your choices for subscriptions and newsletters;
[c] You may choose whether or not to receive offers from us;
[d] You may choose whether you received targeted advertising from us or our partners.

OPT-OUT.

We have created the following mechanisms to provide you with control over certain uses and disclosures of your information:
● Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
● Location Information. You can choose whether or not to allow the Service to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Service may then be inaccessible or not function properly.
● Promotion by the Company. If you do not wish to have your email address or contact information used by the Company to promote our own or third parties' products or services, you can opt-out by following the unsubscribe instructions provided in the e-mail you receive or contacting us directly at admin@getstow.co If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
● Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by following the unsubscribe instructions provided in the e-mail you receive or contacting us directly at admin@getstow.co. You can also always opt-out by logging into the Service and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to admin@getstow.co.
● Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by following the unsubscribe instructions provided in the email you receive or contacting us directly at admin@getstow.co. You can also always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by providing us notice at admin@getstow.co. We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (the “NAI”) by visiting http://www.networkadvertising.org/index.asp.

ACCESSING AND CHANGING YOUR INFORMATION

You can review the personal information you have provided to us and make any desired changes to such information, or to the settings for your Stow account, at any time by logging in to your account on the Stow website. If you close your Stow account, we will mark your account in our database as “Closed”, but will keep your Account Information in our database. This is for instance necessary in order to fulfill our data retention requirements to comply with applicable laws and regulations, and for other legitimate business reasons, such as to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement authorities, or as required by law. The information you provide us with will not be kept for longer than necessary with regards to the purpose of its processing described above, subject to statutory retention periods imposed by applicable law.

SECURITY OF PERSONAL INFORMATION

We will take reasonable administrative, technical, organizational and physical precautions to safeguard against the loss, misuse or alteration of your personal information. These safeguards vary based on the sensitivity of the information that we collect and store. For example, when processing sensitive personal data (such as data about ethnic or racial origin, political opinions/union membership, data concerning health, sex life or sexual orientation, genetic data, or biometric data) or data that reveals sensitive personal data, especially when using data profiling extra safeguards will be added . We will store all the personal information you provide on our secure password- and firewall protected servers. We will notify consumers and regulatory authorities in case of breach without undue delay. You acknowledge that the transmission of information over the internet is inherently insecure, and any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that information will never be disclosed, altered or destroyed in a manner that is inconsistent with this Privacy Policy. You acknowledge that the safety and security of your information also depends on you. You are responsible for keeping the password you use for accessing the Service confidential; we will not ask you for your password (except when you log in to our Service).

USERS FROM OTHER JURISDICTIONS

The Service is controlled and operated by us from Nigeria. If you are not a resident of Nigeria or you are located outside Nigeria, you are only authorized to use the platform to the extent of dealing with other Multi-Currency Wallets offered on the Stow Platform. If you choose to use the Platform or provide information to us, please note that we may transfer the information, including personal information, outside of Nigeria and process it there. We do not represent or warrant that the service, or any portion thereof, are appropriate or available for use in any particular jurisdiction. Those who choose to access the Platform do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations, and are subject to the Foreign Country export controls in connection with your use of the Service and are responsible for any violations of such controls, including, without limitation, any of such country embargoes or other federal rules and regulations restricting exports. We may limit the availability of the Service, in whole or in part, to any person, geographic area or jurisdiction that we choose, at any time and in our sole discretion. Personal information that you publish on the Platform or submit for publication on our Website may be available, via the Internet, around the world. We cannot prevent the use or misuse of such information by others.You expressly agree to the transfers of personal information described in this Section.

CONTACT US AND EXERCISING YOUR RIGHTS

Our legal and privacy department is responsible for ensuring that our day-to-day procedures comply with this Privacy Policy. If you want to exercise your right to access your information, make changes or have any questions about this privacy statement, Stow information practices, or data protection, you can write to us at admin@getstow.co By writing to the above address, and subject to certain conditions set out by applicable data protection law, you may also exercise your rights to:
[a] object to the processing of your information;
[b] ask for erasure of your information within the limits permitted by applicable laws and regulations;
[c] ask for portability of your information;
[d] object to the use of your information for marketing purposes.