1. OVERVIEW

RevPro has developed this Privacy Policy Statement to explain how we may collect, retain, process, share and transfer customer Personal Data when they visit our Sites or use our Services. This Privacy Statement does not apply to online websites or services that we do not own or control, including websites or services of other RevPro Users and Partners. This Privacy Statement is designed to help customers obtain information about our privacy practices and to help customers understand their privacy choices when customers use our Sites and Services. Please note that our Service offerings may vary by region. We have defined some terms that we use throughout the Privacy Statement. Customers can find the meaning of a capitalized term in the Definitions section. Please contact us if you have questions about our privacy practices that are not addressed in this Privacy Statement.

2. WHAT PERSONAL DATA DO WE COLLECT?

We may collect information about customers when customers visit our Sites or use our Services, including the following:

Registration and use information – When merchants register to use our Services by establishing an Account, we will collect Personal Data as necessary to offer and fulfil the Services they or their customers request. Depending on the Services marchants choose, we may require merchants to provide us with their name, postal address, telephone number, email address financial account information and identification information to establish an Account. We may require customers to provide us with additional Personal Data as customers use our Services.

Sharing of information with other gateways – when someone wants to make a payment to merchants, we will share the minimum required information on that payer with partner payment gateway as part of the requirements to process the payment or when sending settlement instructions. Depending on service required we may collect and share bank account numbers, and any other data required to meet the minimum CBN requirements on such transactions.

We may collect BVN for validation of bank accounts, to prevent fraud and/or to meet AML requirements.

Transaction and experience information – When merchants and their customers use our services or access our Sites, for example to receive or make payments, we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, merchant information, including information about any funding instruments used to complete the transaction, Device Information, Technical Usage Data, and Geo-location Information.

Participant information – When customers use our Services or access our Sites, we collect Personal Data customers provide us about the other participants associated with the transaction.

Receive a Payment: When a merchants receives a payment through our Services, we collect Personal Data such as name, postal address, telephone number, and financial account information about the participant who is making the payment and other parties involved in the transaction. The extent of Personal Data required about a participant may vary depending on the Services merchants are using to receive the payment.

Information about their public profile and their contacts – It may be easier for us to help merchants transact with their partners, clients and contacts if merchants choose to connect their contact list information with their Account or if their Account profile is publicly available. If customers establish an account connection between their device or a social media platform and their Account, we will use their contact list information (such as name, address, email address) to improve their experience when customers use the Services. When their Account profile is public, other users can find their profile to transact with them by searching by name, username, email, or mobile number on RevPro and confirm it’s customers by viewing their photo. Customers can make their Account profile private anytime in their RevPro settings.

Information that customers choose to provide us to obtain additional Services or specific online Services – If customers request or participate in an optional Site feature, or request enhanced Services or other elective functionality, we may collect additional information from customers. We will provide customers with a separate notice at the time of collection, if the use of that information differs from the uses disclosed in this Privacy Statement.

Personal Data about customers if customers use unbranded Services – certain Services are available without being required to log in to or establish an Account. We will collect Personal Data when customers are interacting with and making payments to merchants using our payment services when customers checkout with RevPro without logging into an account. For our unbranded payment services, their interaction is with the merchant, on their platform. If customers are an Account holder, or create an Account at a later date, we may collect information about unbranded transactions and associate them with their Account to improve their customers experience as an Account holder and for compliance and analytics purposes. If customers are not an Account holder, we will collect and store all information customers provide and use such information in accordance with this Privacy Statement.

Information about customers from third-party sources – We obtain information from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law.

Other information we collect related to their use of our Sites or Services – We may collect additional information from or about customers when customers communicate with us, contact our customers support teams or respond to a survey.

3. WHY DO WE RETAIN PERSONAL DATA?

We retain P