USE OF DATA
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).
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 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.
HOW WE USE THE INFORMATION WE COLLECT
[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
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.
- 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.
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.
We have created the following mechanisms to provide you with control over certain uses and disclosures of your information:
● 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 email@example.com 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 firstname.lastname@example.org. 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 email@example.com.
● 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 firstname.lastname@example.org. 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 email@example.com. 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
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
[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.