2.1

We will only collect and process your data based on consent and for each information we indicate that we collect under the Privacy Policy, you agree to have consented to their collection, processing, storage, use and disclosures.

2.2

For other information we may require which are not expressly stated under this Privacy Policy, we will request for your consent and authorisation before collection, storage and use;

2.3

We provide you with the option to accept this Privacy Policy by clicking on the “Accept” button on our Platform. When you withdraw your consent after using our Platform or Services, information collected prior to your withdrawal will be processed in accordance with the version of this Notice that was in place when you used our services

2.4

All data collected by us in your use of our services, will only be used for the purposes disclosed to you at the time of collection. Your information will not be used for any undisclosed or misrepresented purpose.

Because we are a financial institution regulated under the Gramm-Leach-Bliley Act, the Personal Information that we collect in connection with your request for consumer financial products and services constitutes “nonpublic personal information” subject to our Financial Privacy Notice, and we may be exempt from certain state privacy laws.

3.2.1

Social Media:

When you interact with us through a social media site or third-party service, such as when you like, follow, or share Cleva content on Facebook, Twitter, Instagram, or similar sites, we may receive information from the social network, including your profile information, picture, user ID associated with your social media account, and any other information you permit the social network to share with third parties.

3.2.2

Service Providers and Business Partners:

We are also working closely with third parties (including, for example, service providers, business partners, sub-contractors in technical, payment and delivery service providers, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

3.3.1

Device Technical Information

including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, activity logs, and other usage information.

3.3.2

Information About Your Visit

including the full Uniform Resource Locators (URL) clickstream to, through and from the website or other parts of the Platform (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

In operating the Services, we may use cookies, web beacons, fingerprinting, and similar technologies to collect and use Personal Information about you, including for analytics purposes, and to serve you interest-based advertising. This Privacy Policy covers the use of these technologies by Cleva only. Uses of these technologies by third-party advertisers or websites linked from the Services, including third parties with which we partner, are governed by each such third party’s privacy policy.

4.1

Eligibility check for onboarding

To use our services, users must be individuals who pass our CDD checks or corporate entities duly incorporated under their local laws. Consequently, we collect corporate information (including details of control persons and beneficial owners) to verify that these entities are legally established, operational, and meet our eligibility requirements. Additionally, we verify the identities of the individuals behind these corporate entities.

4.2

Regulatory compliance obligations

As participants in the financial services industry, we uphold stringent measures to prevent the misuse of our services for fraudulent purposes such as money laundering, terrorism financial, proliferation financing and other unlawful activities. For this purpose, we collect information relating to your business, personal information of your Beneficial Owners (BOs) and beneficiaries for screening against various public records and sanctions lists. Additionally, we retain transaction records as required by law to serve as vital support for law enforcement agencies during investigations.

To the extent permitted under the Nigeria Data Protection Regulation and the Data Protection Act, and any other applicable laws and regulations, we rely on our legitimate business interests to process your data for the following reasons:

• To provide our Services to you, which includes accessing and using our Platform, using our Remittance Services and any other Services provided to you;
• To process and fulfil your requests for sending money to the Recipients (as defined in our Terms of Service);
• To communicate with you, respond to your inquiries and provide customer support, including by managing your Cleva Account, and keeping you updated, e.g., with respect to updated terms;
• Detect, monitor, and prevent fraud or other illegal or unauthorized activities;
• Request and verify your financial-related information or other information provided;
• To enhance our user experiences and troubleshoot technical issues;
• Manage, operate, and improve the performance of our Services and our Platform;
• Protect you, our Services, and our Platform from malicious activity and other privacy and security risks;
• Enable network and information security throughout our Platform and Services;
• Investigate any misuse of our Services or our Platform in accordance with our terms of use;
• To conduct record keeping, training and quality assurance activities, resolving complaints, and otherwise manage our business, including our relationship with third parties and other opportunities;
• Providing you with marketing communications about our Services (see below regarding opt out procedures);
• To comply with our legal obligations
• For any other purpose with your consent.

In order to deliver and improve our Services, we may share your Personal Information :

6.1

With our partner banks or any other third-party payout and payment providers (“Third-Party Partners”) in order to comply with laws and regulations and the Third-Party Partner’s regulatory obligations;

6.2

With third parties party service providers that performs services on our behalf as needed to carry out their work for us, which may include providing the following services: tax and accounting, fraud prevention services, identity verification, services, web hosting, customer and support services or analytics services;

6.3

When needed to provide Services to you, e.g., to card networks in case you are issued a card by our partner banks, to other third parties when processing your transactions or maintaining your accounts;

6.4

When required by law or if reasonably necessary with regulators, law enforcement agencies or authorities: (1) to comply with a legal process, such as a court order, subpoena or search warrant, (2) to assist in the prevention or detection of a crime (subject in each case to applicable law), (3) to protect the health and safety of us, our users, or any person; or (4) as otherwise required by applicable law;

6.5

To independent external auditors, law firms or other service providers to us to support our audit, compliance and corporate governance functions;

6.6

In connection with change of ownership or control of all or part of our business, such as a merger, acquisition, reorganization or bankruptcy;

6.7

In order to enforce our legal rights, which may include: (1) to protect the security or integrity of our Platform or Services; (2) to exercise or protect the rights, property or personal safety of Cleva or other user; (3) to enforce our agreements with you; (4) protect against or mitigate legal liability;

6.8

With other entities within the Cleva group where it is necessary for operational reasons and for any administrative purposes to organize, develop and deliver our Platform and Services, run our organization and decide on future strategies;

6.9

With third parties or with entities within the Cleva group for marketing purposes or to provide you with their own products or services, which we shall do only with your consent (see below for opt out procedures); or

6.10

At your request;

We do not sell your Personal Information. Where consent is required, we will seek it in advance and provide opt-out options.

7.1

Cookies are text files with small pieces of data sent to your device to enable us to store information about you when you browse on our website if you agree.

7.2

We employ cookies to monitor your local computer settings so as to detect unauthorized access. We may also expand our use of cookies to include the collection of additional data such as passwords, preferences, and other details as improvements are made on our services.

7.3

We shall grant you an opportunity to either accept or reject cookies used on our browsers. However, if you choose to reject the cookies, you may not be able to access some functionalities and web pages on our site or mobile applications. You may also be able to disable or reject cookies through your browser’s settings.

7.4

Google Analytics: Please note that we use Google Analytics cookies for data analytics purposes. You can find more information on how Google uses data from these cookies at google.com/policies/privacy/partners. You may choose to opt-out of Google Analytics by installing their opt-out browser add-on https://tools.google.com/dlpage/gaoptout/.

We shall, as much as reasonably within our abilities, not collect any Personal Information from visitors to our website unless they become a user on our Platform or otherwise creates a Cleva Account, or otherwise provides us with Personal Information directly.

8.1

We maintain organisational, technical and administrative measures designed to protect your personal data against unauthorised access, disclosures, alteration, misuse and destruction.

8.2

We use secured web services that have been configured to run within a virtual private connection and an SSL certificate to make sure that all communications are made over HTTPs SFTP using SSL. We shall also use our best endeavors to safeguard the confidentiality and security of your Personal Information; however, please note that no method of transmission over the internet is completely secure therefore, we cannot assure you of an absolute security of your Personal Information.

8.3

We will retain your Personal Information for as long as you use our Services and access our Platform, if required by law and regulations, for the minimum amount of time as required under those laws and regulations.

10.1

You have the following rights in relation to your Personal Information held by us:

10.1.1

The right to have access to your Personal Information;

10.1.2

The right to be informed about the processing of your Personal Information by maintaining this Privacy Policy or the Financial Privacy Notice, or as otherwise required by applicable laws and regulations;

10.1.3

The right to correct any inaccurate Personal Information or any information about you; and

10.1.4

The right to limit the use of sensitive Personal Information (such as government ID, financial account information or geolocation data) to what is necessary for providing the requested service, unless we obtain your consent to use it for other purposes.

10.2

In addition, if you are one of our customers outside of the United States, you also have the following rights:

10.2.1

The right to request the deletion of Personal Information we have collected, subject to certain limitations under applicable law (e.g., for compliance with legal compliance or internal business needs);

10.2.2

The right to restrict the processing of your personal data;

10.2.3

The right to block the processing of your Personal Information that is done in violation of any applicable law or regulations;

10.2.4

The right to be informed about any erasure or rectification of your personal data or restriction of any processing carried out;

10.2.5

The right to the portability of your personal data; and

10.2.6

The right to lodge a complaint to a supervisory authority within your country of residence.

At your request, we will provide the personal data held by us in a structured manner, commonly used and machine-readable format. We will restrict you from transmitting those data in our database to another company where the processing is based on consent, on a contract, and processing is carried out by automated means.

To exercise any of your rights under this Privacy Policy, please email legal@getcleva.com. We may request that you complete a form and provide suitable identifications to verify your identity. Once the form is completed where required, we will provide you with the requested information within a period not exceeding two months. However, where permitted under applicable laws, we have a right to refuse your request where we notice that the request is repetitive or excessive.

Please note that your data access rights is subject to limitations provided by applicable laws and regulations, and that we may have the right to deny your request.

11.2

At your request, we will provide the personal data held by us in a structured manner, commonly used and machine-readable format;

11.3

We will restrict you from transmitting those data in our database to another company where the processing is based on consent, on a contract, and processing is carried out by automated means;

11.4

To exercise any of your rights under this Notice, you may contact us through the email address provided under this Notice. However, please note that we may request that you complete a form and provide suitable identifications to verify your identity. Once the form is completed where required, we will provide you with the requested information within a period not exceeding two months. However, we have a right to refuse your request where we notice that the request is repetitive or excessive;

11.5

Please note that your right to the erasure of your data does not apply to legal necessities like invoices, audit logs, subscription information, and the data archived on our backup systems. For such data, we shall securely isolate and protect their users from any further processing;

11.6

Where any of the rights as provided for under this Notice is breached, the resolution shall be in accordance with the dispute resolution mechanism in our Terms of use.

Our Platform and our Services are not intended for children under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected Personal Information from a child, we will take prompt steps to delete such information from our records.

You may opt out of marketing emails from us at any time by contacting us at contact@getcleva.com, or by clicking the “unsubscribe” link located in the footer of the emails you receive

This Privacy Policy is made pursuant to applicable privacy and data protection laws and regulations, including but not limited to the United Kingdom's General Data Protection Regulation (UK GDPR), Nigeria Data Protection Regulations (NDPR), and the Nigeria Data Protection Act, and any relevant privacy and data protection laws existing under the laws of the United States.