Klump Technology Company Ltd (“Klump, us, it,our, or we”) is committed to protecting and respecting your privacy.

This privacy policy (Policy), together with our Terms and Conditions and Terms of Service as set out on our website useklump.com and apps, applies to your use of our website, apps, and general services.

This policy sets out the basis on which any personal data we collect from you or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By clicking on “I ACCEPT,” you confirm that you have read, understood, and accepted the terms of this policy set out hereunder. You also consent to the collection, use, storage, processing, and disclosure of your personal information in the manner set out in this policy.

A. INFORMATION WE MAY COLLECT FROM YOU.

We may collect and process the following data about you.

a. Information you give us about you.

This information may include your name, address, e-mail address, and phone number, the Device's phone number, SIM card details, age, username, password, and other registration information, financial and credit information (including your mobile money account details, bank account details, and bank verification number, where applicable), personal description; and photograph.

b. Information we collect about you and your device.

When you send email or other communications to us, we may retain those communications in order to process your inquiries, respond to your requests, and improve our services.

Each time you visit one of our Sites or use one of our Apps we may automatically collect the following information:

• technical information, including the type of mobile device you use, unique device identifiers (for example, your Device's IMEI or serial number), information about the SIM card used by the Device, mobile network information, your Device’s operating system, the type of browser you use, or your Device’s location and time zone setting (Device Information);
• information stored on your Device, including contact lists, call logs, SMS logs, Facebook friends, contact lists from other social media accounts, photos, videos or other digital content (Content Information);
• data from your use of any other third-party application on the Device or the Service Sites; and
• details of your use of any of our Apps or your visits to any of Our Service Sites; including, but not limited to, traffic data, location data, weblogs and other communication data (Log Information).

c. Location information.

We may also use GPS technology OR other location services to determine your current location. You can withdraw your consent to our collection, processing, or use of this information at any time by logging out and uninstalling the Apps from your Device.

d. Third Party Information (Information we receive from other sources).

Due to the nature of the Services which we provide, we are required to work with a number of third parties; Service Providers (including banks, credit reference agencies and mobile network providers) and we may receive information about you from them.

e. Unique application numbers.

When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

B. Tracking and Cookies.

We may use mobile tracking technologies and/or website cookies to distinguish you from other users of the website, Apps, App Sites, or Service Sites. This helps us to provide you with a good experience when you use the Apps or browse any of the Service Sites and also allows us to improve the Apps and Our Service Sites.

C. How we Collect and Use the information.

Klump Technology Company Ltd may collect your personal information by:

• a. filling the forms our website, apps or service sites (hereinafter called “our sites”)
• b. correspondence with us (for example by e-mail or chat);
• c. registering to use our sites;
• d. subscribing to our Services (such as applying for loan), searching for an app or Service, sharing data via the Apps’ social media functions, entering a promotion or survey, and reporting a problem with the Apps, our Services, our Apps’ Site or any of Our Service Sites

We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this Policy for as long as it is combined.

Information collected by us shall be used for the purpose of determining whether or not to provide a credit/loan to the customer, the amount of such credit/loan and the terms and conditions applicable to such credit/loan or for the provision of any of our products and services to you.

Save for compliance with an order of the Court, Arbitral Panel, Tribunal, Regulatory Directive or Order or any other legal or regulatory obligation, we do not disclose information about identifiable individuals to other parties.

D. Consent and Access Rights.

You hereby consent to the processing of your data by us. We shall obtain your consent for individual matters, where any document deals with different matters.

We can process your personal data in the absence of consent where:

1. processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract or for the provision of any of our products and services;
2. processing is necessary for compliance with a legal obligation to which we are subject;
3. processing is necessary in order to protect your vital interests or that of another natural person; and
4. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official public mandate vested in us.
5. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party to whom the data is disclosed.

If we intend to use your data for a purpose which is different from the purpose for which your data was obtained, we will seek your consent prior to the use of your data for that other purpose.

In the event of any arrangement whereby KLUMP is merged or combined with another entity (ies), sells or transfers all, or a portion of, its business or assets (including in the event of an internal or external restructuring, reorganisation, dissolution or liquidation) to third parties, you hereby consent that your personal data held with KLUMP can be transferred or assigned to third parties who may become the controllers and/or processors of your personal data that was held by KLUMP prior to such arrangement. Klump Technology Company Ltd shall at all times ensure that you are notified when your personal data is intended to be transferred to third parties in the circumstances outlined in this clause.

No Consent shall be sought, given or accepted in any circumstance that may engender direct or indirect propagation of atrocities, hate, child rights violation, criminal acts and anti-social conducts.

You may withdraw your consent, in writing, at any time and may request access to your personal information in our possession at [email protected]. We can, however, deny you access to the information where we determine that your request is unreasonable.

You reserve the right to request the modification or amendment of your personal data in our possession.

In all cases of access or modification/amendment of personal information, we shall request sufficient identification to enable us to confirm that you are the owner of the data sought to be accessed or modified/amended.

E. Data Subjects’ Rights.

As a Data Subject, you have some rights in relation to the way we handle your personal data.

These include the following rights:

1. where the Legal Basis of our Processing is Consent, to withdraw that Consent at any time;
2. to ask for access to the personal data that we hold;
3. to prevent our use of the personal data for direct marketing purposes;
4. to object to our Processing of personal data in limited circumstances; and
5. to ask us to erase personal data without delay:
   1. if it is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
   2. if the only Legal Basis of Processing is Consent and that Consent has been withdrawn and there is no other Legal Basis on which we can process that personal data;
   3. if you object to our Processing where the Legal Basis is the pursuit of the public interest and we can show no overriding legitimate grounds or interest; and
   4. if the Processing is unlawful.
6. to ask us to rectify inaccurate data or to complete incomplete data;
7. to restrict Processing where:
   1. the accuracy of the personal data is contested by you for a specific period to enable us to verify the accuracy of the personal data;
   2. the processing is unlawful, and you oppose the erasure of the personal data and requests the restriction of its use instead;
   3. we no longer need the personal data for the purposes of the processing, but you require it for the establishment, exercise or defence of legal claims; and
   4. you have objected to the processing, pending the verification in relation to whether our legitimate grounds override your rights as the Data Subject.
8. to ask us for a copy of the safeguards under which personal data is transferred outside of Nigeria;
9. the right not to be subject to decisions based solely on automated Processing, including Profiling, except where:
   1. necessary for entering into, or performing, a contract, with KLUMP;
   2. authorised by a written law, which establishes suitable measures to safeguard your fundamental rights and freedoms, and interests; or
   3. authorised by you
10. to prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;
11. to data portability;
12. to be notified of a personal data Breach which is likely to result in high risk to their rights and freedoms;
13. to make a complaint to NDPB or any other regulatory body; and
14. in limited circumstances, receive or ask for their personal data to be transferred to a Third Party (e.g. another company which the customer/client has dealing with) in a structured, commonly used and machine-readable format.

We will use your data for the purposes of compiling statistics relating to our user base or loan portfolio and any other product or service we provide and may disclose such information to any third party for such purposes, provided that such information will always be anonymous.

Should we wish to use your information for marketing purposes, we will inform you prior to such use. You shall be entitled to prevent such usage by informing us, within 7 (seven) days of being informed of the proposed use, that you do not wish to disclose such information. You can also exercise the right at any time by contacting us at [email protected].

F. Personal Data Protection Principles.

When we process your personal data, we are guided by the following principles, which require personal data to be:

1. processed lawfully, fairly, in a transparent manner and with respect for the dignity of the human person.
2. collected only for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes.
3. adequate, relevant and limited to the minimum data that is necessary for the purposes for which the personal data was collected or further processed.
4. retained for no longer than is necessary to achieve the lawful bases for which the personal data was collected or further processed.
5. accurate, complete, not misleading, and, where necessary, kept up to date having regard to the purposes for which the personal data is collected or is further processed.
6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing, access, loss, destruction, damage, or any form of data breach.

G. Third Party Access.

We will only share personal information with other companies or individuals in the following limited circumstances:

1. We have your consent.
2. We provide such information to other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
3. We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable terms of service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of KLUMP, its users or the public as required or permitted by law.

Klump Technology Company Ltd is at all times responsible for the security and appropriate use of that data as long as it remains with KLUMP.

H. User Responsibility.

You are required to familiarise yourself with this policy and to ensure that the information you provide to us is complete, accurate and up to date.

I. Disclosure of your information.

We may disclose to credit reference bureaus some or all of the data we collect from you when you download the Apps or use the website.

We may disclose your personal information to any member of our group, which means our subsidiaries or affiliates.

We may disclose your personal information to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if Klump Technology Company Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
• if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; and/or
• in order to enforce our Terms and Conditions and other agreements or to investigate potential breaches; report defaulters to any credit bureau; or for the purpose of publishing statistics relating to the use of the Apps or website, in which case all information will be aggregated and made anonymous.

J. Where we store your personal data.

The data that we collect from you may be stored in the cloud (Amazon Web Services).

By providing your consent to this policy, you also authorise us to transfer your personal data provided to third parties with the understanding that the data may be used for the purpose stated in our contracts or terms of engagement with you.

We assure you that we will protect your personal data in our possession, and we confirm that the security measures in place are more than adequate to protect your personal data. We confirm that we take appropriate physical, management, and technical measures, such as the establishment of the access control system and monitoring system, encryption, anonymisation or pseudonymisation, employee training, to protect your personal data against unauthorised access, use, disclosure, modification, damage, loss, or other forms of illegal processing. By submitting your personal data, you also agree to the collection, transfer, storing or processing of your personal data in the manner set out above.

Where we have given you or where you have chosen a password that enables you to access certain parts of Our Service Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Service Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

K. Data Security.

We implement and maintain appropriate safeguards to protect personal data, taking into account in particular the risks to you, presented by unauthorised or unlawful processing or accidental loss, destruction of, or damage to their personal data.

Safeguarding will include the use of encryption and pseudonymisation where appropriate. It also includes protecting confidentiality (i.e., that only those who need to know and are authorised to use personal data have access to it), integrity and availability of the personal data. We regularly evaluate and test the effectiveness of those safeguards to ensure the security of our processing of personal data. You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures, we cannot guarantee absolute security. Klump Technology Company Ltd therefore, accepts no liability for any damage or loss, however caused, in connection with transmission over the internet or electronic storage.

L. Links to third party sites.

Our Service Sites may contain links to other websites owned and operated by third parties. These links are provided for your information and convenience only and are not an endorsement by Klump Technology Company Ltd of the content of such linked websites or third parties. The information that we collect from you will become available to these websites if you click the link to the websites. These linked websites are neither under our control nor our responsibility. Klump Technology Company Ltd therefore, makes no warranties or representations, express or implied about the safety of such linked websites, the proprietors or operators of those websites, and the suitability or quality of information contained on them. This Privacy Policy does not apply to these websites, thus, if you decide to access these linked third party websites and/or make use of the information contained on them, you do so entirely at your own risk. Klump Technology Company Ltd accepts no liability for any damage or loss, however caused, in connection with accessing, the use of or reliance on any information, material, products or services contained on or accessed through any such linked website. We advise that you contact those websites directly for information on their privacy policy, security, data collection and distribution policies.

M. Violation of Privacy Policy.

We have put in place procedures to deal with any suspected personal data breach and will notify you of any personal data breach and let you know the steps we have taken to remedy the breach and the security measures we have applied to render your personal data unintelligible.

All suspected breach of personal data will be remedied within 1 (one) month from the date of the report of the breach.

If you know or suspect that a personal data breach has occurred, you should immediately contact the KLUMP team at [email protected].

KLUMP will not be responsible for any personal data breach which occurs as a result of:

1. an event which is beyond the control of KLUMP;
2. an act or threat of terrorism;
3. an act of God (such as, but not limited to fires, explosions, earthquakes, drought, tidal waves and floods) which compromises KLUMP’s data protection measures;
4. war, hostilities (whether war be declared or not), invasion, act of foreign enemies, mobilisation, requisition, or embargo;
5. rebellion, revolution, insurrection, or military or usurped power, or civil war which compromises KLUMP’s data protection measures;
6. pandemics or epidemics;
7. the transfer of your personal data to a third party on your instructions; and
8. the use of your personal data by a third party designated by you.

N. Data Retention.

Klump Technology Company Ltd shall retain and use your Data only as long as is necessary to implement, administer and manage your request and contract with KLUMP, and up to a maximum of [5] years after the expiration or termination of the contract or as required to comply with legal or regulatory obligations, including under tax and security laws. At your request, at any time, your personal data which is in the custody of KLUMP may be deleted unless we are required by law to retain such information for a specific period of time so as to comply with our obligations under the relevant law.

Notwithstanding, a request for erasure will automatically be denied in whole or in part, where it would adversely affect a constitutionally guaranteed right, contradict a legal obligation, act against the public interest in the area of public health, act against the public interest in the area of scientific or historical research, or prohibit the establishment of a legal defence or exercise of other legal claims by KLUMP or any legitimate third party. Where a request for erasure is denied, KLUMP will provide to you the specific reason for denying the request as soon as possible but no later than one month after receiving the request for erasure.

O. Changes to privacy policy.

Any changes we may make to this Policy in the future will be posted on this page and where appropriate, notify you when you next start the Apps or log onto one of the Service Sites. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Apps or the Services. In any event, by continuing to use the Apps or any Services after the posting of any changes, you confirm your continuing acceptance of this Policy together with such changes, and your consent to the terms set out therein.

CONTACT US VIA:

[email protected]