Access Power Systems Limited and its affiliates ("APNG", "APS", "The Company") operates AccessPowerNG website, AccessPowerNG Android Mobile App and AccessPowerNG Apple iOS Mobile App (henceforth refered to as “The Platform(s)”). This Privacy Policy informs you of the policies regarding the collection, use and disclosure of Personal Information when you use our The Platform(s). We will not share your information with anyone except as described in this Privacy Policy. Our use of your personal information is for providing and improving the services on The Platform. By using The Platform(s), you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this policy, terms used in herein have the same meanings as in our Terms of Use. This policy applies to all of our services on The Platform(s). By accessing or using our services, or affirming your assent to this Privacy Policy, you signify that you have read, understood and agree to our policy on the (i) collection, (ii) storage, (iii) use and (iv) disclosure of your personal information as described in this Privacy Policy. In the event that you are acting on behalf of a Company, your accent to this policy affirms that you are an authorized representative of the Company with the legal authority to bind your Company to this Privacy Policy and that you agree to this Privacy Policy on the Company’s behalf.

Table of Contents

1. Data Collection and Use
2. Permissions We Request
3. Logged Data
4. Location Data
5. What information do we collect?
6. Usage of Collected Data
7. Data From Other Sources
8. Cookies
9. Information Disclosure
10. Changes to Personal Data
11. Site Data
12. Third Party Tracking
13. Data Storage & Security
14. Communications
15. Compliance with Laws
16. Your Legal rights
17. Changes to This Privacy Policy
18. Contact Us

Data Collection and Use

While using The Platform(s), we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information, but are not limited to,

• your email address
• name
• phone number
• postal address

Permissions We Request

We ask for permissions to send and for you to receive notifications that we send. The notifications contain the status of transactions you perform on The Platform(s). To stop un-subscribe or re-subscribe to receive the notifications, please use your mobile device or computer specific notification's management feature.

Logged Data

When using The Platform(s), we automatically collect certain data about your Mobile device or Internet browser, including, but not limited to,

• type of device (computer or mobile)
• platform accessed (mobile app or website)
• device identifier
• ip address
• device OS
• other data (time spent, pages/links opened

1. Google Analytics, which we use to collect, monitor, analyse and aggregate data we collect to better understand your usage of The Platform(s). This is to help us continually improve our services on The Platform(s). You can view Googles privacy policy
2. Paystack, is a Payment gateway that enables us provide payment for services we provide on The Platform(s). You can access their Privacy Policy

Location Data

We currently don't ask for nor use your location information.

What We Collect

When using The Platforms, we collect data and information, which include but not limited to:

1. When using The Platform(s) we collect
   • your DISCO meter no or customer no
   • amount of units to vend
   • GSM No to send token to
   • email address to send token to
2. When making payments for services we offer on The Platform(s), we use Paystack, which collects, among others,
   • Bank/EMV Card information
   • Bank/EMV Card PIN
   • Your Bank
   • Transaction Information
3. While using The Platform(s), we collect
   • your usage
   • actions performed
   • communications you send to use
   • total time spent on each operation/action
4. We also collect device specific data including but not limited to
   • device id
   • device version
   • device model
   • ip address

Usage of Collected Data

• To fulfil our obligations to you for using The Platform(s)
• To provide value for services we offer on The Platform(s)
• To monitor performance of The Platform(s)
• To better understand your usage of The Platform(s)
• To aid in our internal operations for data analysis, research, etc
• To comply with the Nigeria Data Protection Act

Data From Other Sources

• From your meter's DISCO we collect
• your personal details
• meter account balance
• meter category
• meter vending history
• Paystack Payment Gateway
• Payment information
• Payment success/failure status

Cookies

Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will "remember" information about your use. Cookies are sent to your browser from a website and stored on your computer’s hard drive.
We use cookies for the following purposes

1. To enhance your user experience on our Platform.
2. To recognise new or past customers.
3. To store your password if you are registered on our Platform.
4. To monitor and improve the effectiveness of our Platform and to better understand your visits on our Platforms.
5. To serve you with interest-based or targeted advertising.
6. To observe your behaviours or browsing activities over time across multiple Platforms or other platforms.
7. To better understand the interest of our customers and visitors to our Platform.
8. To diagnose or fix technical issues, to plan for and enhance our Platform

1. Change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it;
2. Disable existing cookies;
3. Set your browser to automatically reject cookies;

Information Disclosure

1. With any of our affiliated companies and Platform providers;
2. With financial Platform providers, including the financial institutions identified in your cardholder bank agreement that provide banking Platforms in connection with your account;
3. With non-financial companies, such as email Platform providers that perform marketing Platforms on our behalf, and fraud prevention Platform providers that use the information to provide Platforms to us;
4. With a non-affiliated third-party to access and transmit your personal and financial information from a relevant financial institution. You grant the third- party the right, power, and authority to access and transmit this information according to terms of their privacy policy;
5. With selected third parties including business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you;
6. With third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or alternatively, acquire all or parts of their businesses;
7. In response to a request for information, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process;
8. With relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud.
9. Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and
10. 10.We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

Changes to Personal Data

Profile and Data Sharing Settings. You may update your profile information, such as your username and profile photo, and may change some of your data sharing preferences on your Settings Page.

Access to your Device Information. You may control the app’s access to your device information through your "Settings" app on your device. For instance, you can withdraw permission for the app to access your address book, location, photo stream and camera.

How to control your communications preferences: You can stop receiving promotional email communications from us by clicking on the "unsubscribe link" provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).

Modifying or deleting your information: If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our website or publicly displayed content, you can contact us directly at Customer Care. We may not be able to modify or delete your information in all circumstances

Site Data

In an ongoing effort to better understand our users and the Platform, we might analyse site data to operate, maintain, manage, and improve the Platform. This site data does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose site data and aggregate user statistics to describe the Platform to current and prospective business partners and to other third parties for other lawful purposes.

Third Party Tracking

We may share, or we may permit third party online advertising networks, social media companies and other third-party services, to collect, information about your use of The Platform(s) over time so that they may play or display advertisement that may be relevant to your interests on The Platform(s) as well as on other websites or apps, or on other devices you may use. This information is used to display targeted adverts through our The Platform(s) or on other websites or apps, including Facebook. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. As noted above, depending on your browser or mobile device, you may be able to set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting "limit ad tracking" (iOS) or "opt-out of interest-based ads" (Android). If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at Customer Care

Data Storage & Security

Data storage and transfer: Your information collected through our Services may be stored and processed in Nigeria or any other country in which Payable or its affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from Nigeria law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you acknowledge such transfer of information to Nigeria or any other country in which the Payable or its parent, subsidiaries, affiliates, or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

Keeping your information safe: We care about the security of your information and use commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through our Services. However, no security system is impenetrable and we cannot guarantee the security of our systems or the systems of the third parties with which we may share your information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Communications

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Compliance with Laws

We will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Platform.

Your Legal Rights

You have the right to:

1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios.
6. If you want us to establish the data’s accuracy.
7. Where our use of the data is unlawful but you do not want us to erase it.
8. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
9. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
10. 10.Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
11. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or Platforms to you. We will advise you if this is the case at the time you withdraw your consent

Changes To Our Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

How to Contact Us

If you have any questions about this Privacy Policy or The Platform(s), please contact us at Customer Care