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At C24 Capital, we are committed to protecting the privacy and confidentiality of personal information and activities of our users, agents, partners and other identifiable individuals. This policy is set to inform users regarding our guidelines with the collection, use, and disclosure of personal information as they use our service, through any of the channels, including the C24 Capital web & mobile applications and the USSD (Unstructured Supplementary Service Data).

2. Other websites

Please note that other websites that may be linked to this Website/App are not governed by this Privacy Policy. We encourage visitors to review the Privacy Policy on each of these other websites before disclosing any personal information.

3. Policy Details

If you choose to make use of our service, then you agree to the collection and use of information in relation with this policy. The personal information that we may collect are used for providing and improving the services we render. We will not use or share your information with anyone except as described in this Privacy Policy. Details of this policy are listed as follows:

• Information Collection and Use
• Log data
• Service Providers
• Access
• Data Integrity
• Children’s Privacy
• Security

i. Information Collection and Use

C24 Capital may from time to time process certain Personal Information from our agents and third parties such as vendors, business partners, customers, service providers (e.g. Banks, Switches – NIBSS, Interswitch, Credit Bureau etc.), suppliers, including information recorded and unique per identified category and information supplied from various channels. For a better experience while using our service, we may require you to provide us with certain personally identifiable information, including but not limited to your name, phone number, basic personal information and documents. The information that we collect will be used to contact / identify you. C24 Capital may share Personal Information with its vendors, business partners, customers, service providers (e.g. Banks, Switches – NIBSS, Interswitch, Credit Bureau etc.), suppliers for the purpose of customer support. Suppliers are required to keep confidential Personal Information received from C24 Capital and shall not use it for any purpose other than as originally intended or subsequently authorized or permitted.

ii. Log Data

We want to inform you that whenever you visit our service, we collect information that your browser sends to us that is called Log Data. This Log Data may include information such as your computer’s Internet Protocol ("IP") address, browser version, pages of our service that you visit, the time and date of your visit, the time spent on those pages, your location while using our service and other statistics.

iii. Service Providers

We may employ third-party companies and individuals due to the following reasons:

• To facilitate our service
• To provide the service on our behalf
• To perform service-related services
• To assist us in analyzing how our service is used

We want to inform our service users that these third parties have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

iv. Access

Users of the C24 Capital USSD, web and mobile applications have reasonable access to their Personal Information for purposes of amendment / correction and deletion in situations where information supplied by the user is incorrect or user perceives a need for change.

v. Data Integrity

C24 Capital will secure and process Personal Information in a way that is harmonious with the purpose for which it has been collected. We take steps to ensure information collected is accurate, reliable, current and relevant to its intended use.

vi. Security

We value your trust in providing us your Personal Information, thus we strive to use commercially acceptable means of protecting it in order to avoid loss, misuse, unauthorized disclosure taking into due consideration the risks involved in the handling and the nature of the Personal Information. Some of the means we use are:

• educating and training relevant staff to ensure they are aware of our privacy obligations when handling personal information as well as training around social engineering, phishing, spear phishing, and password risks
• technological security measures, including fire walls, encryption and anti-virus software
• real-time monitoring of data leakage controls
• administrative and technical controls to restrict access to personal information on a ‘need to know’ basis
• layered and comprehensive cyber security defences
• physical security measures, such as staff security passes to access our premises
• external technical assessments, security audits and vendor due diligence
• endpoint security: Anti-virus, portable storage device lockdown, restricted administrative privileges
• security incident reporting and management.
• Although we endeavour to use appropriate security measures in protecting personal information, we cannot guarantee the security of data transmitted to us or by us because the transmission of data over the internet (including by e-mail) is never completely secure.

vii. Children’s Privacy

Our Services do not address anyone under the age of 13. We do not knowingly collect personal identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to take the necessary actions.

4. Legal Grounds

We are required by law to set out in this Privacy Policy the legal grounds on which we rely in order to process your personal information.

We generally use your personal information for the purposes outlined above because: (a) it is necessary for our legitimate interests and does not unduly affect your interests or fundamental rights and freedoms; (b) it is necessary for legal and/or regulatory obligations or requests that we are subject to, such as keeping records in accordance with applicable regulations or providing information to a public body or law enforcement agency; (c) it is necessary to perform contractual obligations that we owe towards you, or to take pre-contractual steps at the request of you; (d) in some cases, we have obtained your prior consent.

To the extent that we process any sensitive personal information relating to you for any of the purposes outlined above, we will do so because either: (1) you have given us your explicit consent to process that information; (2) the processing is necessary for reasons of substantial public interest on the basis of applicable law (for example where we are required by law or regulatory requirements to process that information in order to ensure we meet our KYC and ‘anti money laundering’ obligations); or (3) the processing is necessary for the establishment, exercise or defence of legal claims.

The legal grounds for processing sensitive personal information outlined above are contained in the EU’s General Data Protection Regulation.

5. Duration for Keeping Personal Information

We will hold your personal information on C24 Capital’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.

6. Users’ Rights

As a user, you have a right to:

• object to the processing of your personal information
• ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete
• request a copy of personal information we hold about you
• ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information
• withdraw consent to our processing of your personal information (to the extent such processing is based on consent).

7. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Thus, we advise you to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately, after they are posted on this page.

8. Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us.