2. DEFINITIONS

• 2.1. 'Account'

  means an account on Easeplan website.

• 2.2. 'Device Information'

  means data that can be automatically collected from any device used to access the Sites or Services. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device’s IP address; information about your device’s web browser and the internet connection being used to access the Site or Services; Geolocation Information; and information about apps downloaded to your device;

• 2.3. 'Geolocation Information'

  means information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. Some of our Services may ask you for permission to share your current location. Some of the Sites and Services require this information to provide a specific product or online Service. If you do not agree to our collection of the geolocation information, our Sites or Services may not function properly when you try to use them.

3. PERSONAL DATA WE COLLECT

In the course of your visits to our Sites or utilization of our Services, we may gather information pertaining to you, which may encompass the following:

4. WE RETAIN PERSONAL DATA

We retain Personal Data to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Policy.

5. WE PROCESS PERSONAL DATA

We may Process your information for the following reasons:

1. To operate the Site and provide the Services, including to:
   • send or request money, add value (stars/likes) to an account, or pay a bill;
   • authenticate your access to an Account;
   • communicate with you about your Account, the Sites, the Services, or Easeplan; and
   • compare information for accuracy and verification purposes.
2. To manage our business needs, such as monitoring, analyzing, and improving the Services and the Site's performance and functionality. For example, we analyze User behavior and perform research about the way you use our Services.
3. To manage risk and protect the Site, the Services, and you from fraud by verifying your identity. Easeplan's risk and fraud tools use Personal Data, Device Information, Technical Usage Data, and Geolocation Information from our Site and websites that offer Easeplan Services to help detect and prevent fraud and abuse of the Services.
4. To market to you about Easeplan products and Services. We may also Process your Personal Data to uniquely tailor the marketing content and certain Services or Site experiences to better match your interests on Easeplan.
5. To provide you with location-specific options, functionality, or offers if you elect to share your Geolocation Information through the Services. We will use this information to enhance the security of the Sites and Services and provide you with location-based Services, such as advertising, search results, and other personalized content.
6. To comply with our obligations and to enforce the terms of our Site and Services, including to comply with all applicable laws and regulations.
7. To respond to your requests, for example, to contact you about a question you submitted to our customer service team.

6. SHARING PERSONAL DATA

We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Policy.

1. With other members of the Easeplan corporate family: We may share your Personal Data with members of the Easeplan family of entities to, among other things, provide the Services you have requested or authorized; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; and to help us manage the availability and connectivity of Easeplan products, Services, and communications.
2. With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers such as Paystack may, for example, provide you with Services such as assisting in processing transactions.
3. With the other parties to transactions when you use the Services, such as other Users, Vendors, Collaborators, and their service providers: We may share information about you and your account with the other parties involved in processing your transactions. This includes other Users, vendors, and their service providers. The information includes:
   • Personal Data and Account information necessary to facilitate the transaction;
   • information to help other Users resolve disputes and detect and prevent fraud; and
   • aggregated data and performance analytics to help Vendors better understand Users and to help Vendors enhance Users' experiences.
4. With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for Easeplan business purposes or as permitted or required by law, including:
   • if we need to do so to comply with a law, legal process, or regulations;
   • law enforcement, regulators, government officials, or other third parties (in Nigeria or elsewhere) in relation to a subpoena, court order, or other legal process or requirement under Nigerian law or regulation, or the laws and regulations of other jurisdictions that are applicable to Easeplan; when we need to do so to comply with such law; or when we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss; or to report suspected illegal activity or to investigate violations;
   • to protect the vital interests of a person;
   • to protect our property, Services, and legal rights;
   • to facilitate a purchase or sale of all or part of Easeplan's business;
   • in connection with services rendered or for purchases made using a Service;
   • to help assess and manage risk and prevent fraud against us, our Users, and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals and vendors;
   • to companies that we plan to merge with or be acquired by; and
   • to support our audit, compliance, and corporate governance functions.
5. In addition, Easeplan may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services. This data will not personally identify you or provide information about your use of the Sites or Services. We do not share your Personal Data with third parties for their marketing purposes without your consent.

7. WE USE COOKIES

A cookie is a small data file that certain web sites write to your hard drive when you visit them.

1. Personalization Cookies: These cookies allow us to recognize and count the number of users of our Sites, as well as to see how users move around our Sites when they are using it. This helps us to improve the way our Sites work, for example, by ensuring that users are finding what they are looking for easily. The information collected through these cookies may include IP addresses, browser types, referring pages, pages visited, and the time spent on particular pages.
2. Security Cookies: These cookies are used to authenticate users and prevent fraudulent use of user accounts. For example, they help us to identify and prevent login attempts from unauthorized sources.
3. Functionality Cookies: These cookies are used to recognize you when you return to our Sites. This enables us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
4. Advertising and Targeting Cookies: These cookies record your visit to our Sites, the pages you have visited, and the links you have followed. We use this information to make our Sites and the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose.

8. YOUR PRIVACY CHOICES

You have choices when it comes to the privacy practices and communications described in this Privacy Policy:

1. Personal Data: You may decline to provide Personal Data when it is requested by Easeplan, but certain Services or all of the Services may be unavailable to you.
2. Object to Processing of your Personal Data: In accordance with Section 36 of the Nigeria Data Protection Act, you have the right to object to the processing of your personal data by sending a request in that regard via this email: easeplan.team@gmail.com.

9. YOUR RIGHTS

Subject to limitation set out in Data Protection Laws, you have certain rights in relation to your personal data. You have the right to request access to your data, erasure, rectification, and data portability. Please contact us via easeplan.team@gmail.com if you want to exercise these rights.

1. If you wish to complete a request for access to all personal data Easeplan holds about you, remember that you may be required to prove your identity.
2. If you have an Account, you will generally be able to review and edit Personal Data in the Account by accessing the account and updating the information directly.

10. WE PROTECT YOUR PERSONAL DATA

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration.

While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.

11. CHILDREN CANNOT USE OUR SERVICES

The Sites and Services are not directed to children. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child, we will promptly delete it, unless we are legally obligated to retain such data.

If you believe that we have mistakenly or unintentionally collected information from a child, please contact us via easeplan.team@gmail.com.