2. Collection of Information
2.1 Categories of Non-public Personal Information
We collect nonpublic personal information you provide to us when you apply for a NEST account or when you communicate with us about your NEST account. The types of information we may collect include your name, address, phone number, email address, date of birth, bank account information, BVN, username, password, and next of kin details.
2.2 Information About Your Transactions With Us
As you use your NEST account to perform financial transactions, we collect nonpublic personal information in connection with each transaction, including transaction time, Naira amount and merchant details. We may also collect photos, memos or other information that you attach to your transactions.
2.3 Information From Other Sources
When you create a NEST account, we may collect information, including non-public personal information about you from non-affiliated third party service providers in order to verify your identity and for fraud prevention, including your prior addresses and names.
2.4 Other Information we collect
We may collect information you provide to us, such as your name, email address and any other information you choose to provide. For example, we may collect such information if you request an invite to join NEST or if you enter into any contest or promotion.
2.5 Information We Collect Automatically from our Services
When you access or use our Services, we automatically collect information about you as follows:
- 1. Log Information: We log information about your use of our Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Services.
- 2. Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.
- 4. Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information on our Services and other websites, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve our Services and your experience, see which areas and features of our Services are popular and count visits. For more information about cookies, and how to disable them, please see “Your Choices” below. We may also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.
2.6 Information we receive from other sources
We work closely with third parties (including financial service providers, security agencies, etc). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
3. Use of Information
We may use your information, including non-public personal information as follows:
- Provide, maintain and improve our Services
- Provide and deliver the products and services you request, process transactions and send you related information, including confirmations.
- Verify your identity and prevent fraud.
- Send you technical notices, updates, security alerts and support and administrative messages.
- Respond to your comments, questions and requests and provide customer service.
- Communicate with you about products, services, offers, promotions, rewards, and events offered by NEST and others, and provide news and information we think will be of interest to you.
- Monitor and analyze trends, usage and activities in connection with our Services.
- Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests.
- Process and deliver contest or promotion entries and rewards.
- Link or combine with information we get from others to help understand your needs and provide you with better service.
- Carry out any other purpose for which the information was collected.
NEST is based in Nigeria and the information we collect is governed by the Nigerian law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to Nigeria and other countries.
4. Disclosure of Information
We may disclose any information we collect about current and former customers, including nonpublic personal information, to affiliates and non-affiliated third parties as follows:
- 1. With financial service providers, including the financial institutions identified in your cardholder bank agreement that provide banking services in connection with your NEST account.
- 2. With another user, when you sign up for NEST's services via a referral link. The user that referred you may receive information indicating that you have enrolled with NEST. You may avoid this sharing by not using a referral link to enroll.
- 3. With non-financial companies, such as email service providers that perform marketing services on our behalf, and fraud prevention service providers that use the information to provide services to NEST and other companies.
With other nonaffiliated companies for our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations or report to credit bureaus. For example, in connection with our everyday business purposes, we may share information about you as follows:
- 1. In response to a request for information, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process.
- 2. With relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud.
- 3. If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of NEST or others.
- 4. In connection with, or during negotiations of, any merger, sale of NEST's assets, financing or acquisition of all or a portion of our business to another company; and
- 5. With your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.
We may also share aggregated or de-identified Information, which cannot reasonably be used to identify you. For example, we may share transaction zip codes with third parties to improve our accuracy in geo-locating transactions and to improve the clarity of transaction descriptions.
We will usually not share your personal information with other third parties without your consent. Where we need to transfer your data to another country, we shall ensure that such country to which the data is being transferred shall have adequate data protection law. We will seek your consent where we need to send your data to a country without an adequate data protection law.
5. Your Choices
5.1 Account Information
You may edit your account profile information by logging into your account via our Services. If you wish to delete or deactivate your online account, please contact us, but note that we may retain certain information as required by law or for legitimate business purposes.
5.2 Promotional Communications
You may opt out of receiving promotional emails and text messages from NEST by following the instructions in those messages. Please note that if you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.
5.3 Location Information
If you initially consent to the collection of location information by NEST or Google Maps within our mobile application, you may be able to subsequently stop this collection through your device operating system settings or through your online account settings. If either of these opt-out options are not available to you, you may also disable location information by following the standard uninstall process to remove our mobile application from your device.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
5.5 Social Sharing Features
Our Services include social sharing features for common social networks to let users share content. These features are served from third-party services that may serve their own cookies. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
5.6 Analytics and Advertising Services Provided by Others
6. Your Rights
The law gives you certain rights in respect of the information we hold about you. Below is a highlight of some of those rights. It is not a complete, exhaustive statement of your rights in respect of your personal data:
- 2. You have a right to a copy of the personal data we hold about you, as well as the information about what we do with it, who we share it with and how long we hold it for. We may make a reasonable charge for additional copies of that data in the case of unfounded and excessive requests.
- 3. You have a right to freely transfer your data received from us to any other person.
- 4. You have the right to have the information we hold about you corrected, if it is factually inaccurate. You may contact us for this purpose.
- 5. In some circumstances, you have the right to the deletion of the information that we hold about you.
- 6. You have a right to lodge a complaint about the handling of your personal information with the National Information Technology Development Agency (NITDA).
- 7. You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
NITDA’s website has a wealth of useful information in respect of your rights over your personal data.
If you wish to exercise your rights, you may write to us at email@example.com
NEST takes reasonable measures to help protect all information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Additionally, NEST implements policies designed to protect the confidentiality and security of your nonpublic personal information, including a privacy protection policy. NEST limits access to your nonpublic personal information to employees that have a business reason to know such information, and implement security practices and procedures designed to protect the confidentiality and security of such information and prohibit unlawful disclosure of such information in accordance with its policies.
Where you have chosen a password that allows you to access certain parts of the website and mobile application, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. We have also taken measures to comply with provision of security facilities for the protection of your nonpublic personal information through the set up of firewalls, limited access to specified authorized individuals, encryption and continuous capacity building for relevant personnel. We therefore have digital and physical security measures to limit and eliminate possibilities of data privacy breach incidents.
Although we use appropriate security measures once we have received your personal information, the transmission of data over the internet (including by email) is never completely secure. We endeavor to protect personal information, but we cannot guarantee the security of data transmitted to us or by us. We will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Where we store your Data
Your personal information will not be retained for longer than is necessary for the purposes for which it was processed.
9. How long we keep your personal information
We will hold your personal information on NEST’s systems for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.