We are Sheroes Empowerment Initiative (‘we’, ‘our’, ‘us’), dedicated to uplifting women. We are registered with the Women’s Empowerment Commission.

This policy outlines the information we gather about you, how we utilize the information you provide, and the parties with whom we share that information. While sharing information is not mandatory, it is essential for accessing our services. This policy also details the circumstances under which we may share your personal information with third parties, including our service providers and credit agencies.

What information do we collect to empower women?

Information you provide through Sheroes Applications

We collect and utilize any information you provide when engaging with our platforms. When you register with us, you share details such as your name, identification documents, address, and photographs. By using our services, you also share transaction details with us. Additionally, we may request your permission to access other information such as your contacts, location, and photos. Other details we collect include:
– Information provided during registration, such as your name, date of birth, gender, phone number, residential address, and email, to comply with regulatory requirements.
– Your profile picture.
– A video of your face during a verification check to confirm your identity. This video is shared with a trusted service provider to facilitate the verification process. You may opt not to upload a video, but this may limit your account functionalities.
– We will not share the verification video with advertisers or anyone else, except the service provider involved in the verification process. If you withdraw consent for the video usage, we will delete it, but this may affect your account access.

Information you provide when contacting us through other channels

If you reach out to us through channels other than the app, we collect the following information to assist you:
– The phone number you are calling from and any information shared during the call.
– The email address you use and the content of your email (including attachments).
– Public details from your social media profiles (like Facebook, Instagram, or Twitter) if you contact us through these platforms, along with the content of your messages.

Information we gather when you use Sheroes channels

• The mobile network operator and operating system you use,
• Your IP address and device ID,
• Your phone contacts to facilitate purchases or payments through Sheroes.

Information we obtain from third parties

As part of our Know Your Customer (KYC) process, we verify the identity information you provide during registration. We will attempt to confirm the authenticity of your identification documents directly with the issuing authorities or through authorized service providers. Additionally, when you request credit or lending products, we conduct further checks with licensed credit bureaus to ensure eligibility in accordance with regulations.

How do we utilize your information?

The Nigerian Data Protection Regulations 2019 (NDPR) mandates that we have a lawful basis for processing your personal information. At least one of the following lawful bases must apply before we process your personal information: contractual or legal obligations, legitimate interests of the data controller, public interest, vital interest of the data subject, or consent.

Contractual Obligation

We collect specific data from you to fulfill our contract with you or to enter into a contract. We use this data to:
– Provide the services we agreed upon in line with our terms and conditions.
– Send you updates regarding your account and other services you use.
– Exercise our rights under contracts with you, such as managing and recovering funds owed to us.
– Investigate and resolve complaints and issues.

Legal Duty

We must ensure compliance with laws by preventing illegal activities such as money laundering, terrorism financing, and fraud. To achieve this, we need your data to:
– Verify your identity during registration or when you contact us.
– Prevent illegal activities like money laundering and fraud.
– Maintain records of information in accordance with legal requirements.
– Comply with banking laws and regulations, which may require sharing customer details with regulators or law enforcement.

Legitimate Interest of the data controller

In certain situations, we need to use the data you provide for our legitimate interests. This means we are using your data in a manner you would reasonably expect, for a purpose that benefits you without overriding your privacy rights.

Consent

For specific information, we will seek your consent. We will ask for your consent to:
– Market and communicate our products and services, with the option to unsubscribe at any time.
– Help protect you against fraud by tracking your phone’s location if you authorize it.
– Access your contact list for purchases.

Who do we share your information with?

In certain cases, we will share the information you provide with third parties we collaborate with, such as card manufacturers and credit bureaus, or with law enforcement agencies when necessary. Sharing confidential customer information will be conducted securely.

How long do we retain your data?

We retain your information as long as you are a Sheroes customer and for any additional period required by applicable laws or regulations. These retention requirements take precedence over any right to erasure requests under data protection laws. Therefore, we cannot erase your data related to your Sheroes account until the specified time period has elapsed, but we assure you that your data will be securely held during this time.

When do we delete your data?

We store and process your personal data only as long as necessary to fulfill our obligations under our agreement with you or as required by law. If the data is no longer needed for statutory or contractual obligations, it will be deleted. If you choose to delete your Sheroes account, we will remove any data you have provided, including any verification videos uploaded. However, this is subject to retention regulations as stipulated by the regulators.

What are your rights?

You have the right to access and request the information we hold about you. You may also request the deletion of your information, restrict how we use your personal information, or ask us to update or correct any personal information you believe is incorrect or incomplete, and we will comply as long as legally permissible. Additionally, you have the right to object to the use of your information for marketing purposes or any additional services we may offer. You may also withdraw any consent you have previously given.

How to file a complaint

At Sheroes, we are deeply committed to respecting and protecting your personal information. If you have any concerns or complaints regarding your personal information, please reach out to our Data Protection Officer by:
– Sending a message through the website
– Emailing us at [email protected]
We will do our utmost to resolve the issue.