Background

We’re OneWallet Microfinance Bank Limited (‘we’, ‘our’, ‘us’) and operate under the name OneWallet. We’re registered with the Corporate Affairs Commission of Nigeria.

This policy describes what information we collect about you, how we collect and use the information you share with us, and with whom we share that information. You don’t have to share any information with us, but to use our services, we’ll need some information from you. This policy also contains information about when we share your personal information with third parties (such as our service providers and credit bureaus).

What information do we collect?

Information you give us on OneWallet Applications

We collect and use any information you supply when you interact with any of our touch points. When you open an account with us, you share details like your names, Bank Verification Number (BVN), identification documents, address and pictures. By using our card or any OneWallet Application to transact, you also share details of your transactions with us. Additionally, we may request explicit permission to see other information like your address book, location, photos and data from your phone camera. Other details we collect and what we do with them include;

• Details you give when you sign up for a OneWallet account, like your BVN, names, date of birth, gender, phone number, residential address, and email address are in fulfillment of regulatory requirements.

• Your profile picture.

• We collect a video of your face during a liveness check done to confirm that you're the one opening or upgrading your OneWallet account. We share this video with a third-party service provider to facilitate our liveness check.

• You may choose not to upload a video of your face on the OneWallet app, however, this will limit what you can do with your OneWallet account as the identification and verification will be incomplete.

• We will not share the video of your face that we collect during a liveness check with advertisers or anyone else other than the third-party service provider that facilitates the liveness check process.

• If at any time you choose to withdraw your consent for us to use this video for your liveness check, we will delete it. However, please note that this would affect your ability to use your account as certain services are dependent on us processing your video for the liveness check.

• Information you give us through the in-app chat so we can help you.

Information you give us when you contact us through other channels

If you contact us via other means than the in-app chat, we collect the following information so we can answer your questions or take action.

• The phone number you’re calling from and information you give us during the call.

• The email address you use and the contents of your email (and any attachments) sent to us.

• Public details from your social media profile (like Facebook, Instagram or Twitter) if you reach out to us via these platforms, and the contents of your messages or posts to us.

Information we collect when you use OneWallet channels

• The mobile network operator and the operating system that you use.

• Your IP addresses and device ID.

• Your phone contacts so you can make airtime purchases or pay contacts on OneWallet.

Information we get from third parties

As part of our Know Your Customer (KYC) process, we run checks on the identity information you supply during signup. We will try to verify the authenticity and validity of the identification document that you have provided, either directly from the issuing authorities or through authorized service providers. Also, when you request for credit or lending related products and services, we run further checks with the licensed credit bureaus for eligibility checks in line with regulations.

How do we use your information?

The Nigerian Data Protection Regulations 2019 (NDPR) requires that we have a lawful basis for processing your personal information. At least one of the following lawful basis must apply before we process your personal information: contractual or legal obligations, legitimate interest of the data controller, public interest, vital interest of the data subject or consent.

Contractual Obligation

We collect certain data from you to fulfill the contract we have with you, or to enter into a contract with you. We use this data to:

• Give you the services we agreed to in line with our terms and conditions.

• Send you messages about your account and other services you use if you get in touch, or we need to tell you about something.

• Exercise our rights under contracts we’ve entered into with you, like managing, collecting and recovering money you owe us.

• Investigate and resolve complaints and other issues.

Legal Duty

We have to ensure we aren’t breaking any laws by banking you by preventing illegal activities like money laundering, terrorism financing and fraud. To do this, we need your data to;

• Confirm your identity when you sign up or get in touch.

• Prevent illegal activities like money laundering, tax evasion and fraud.

• Keep records of information we hold about you in line with legal requirements.

• Adhere to banking laws and regulations (these mean we sometimes need to share customer details with regulators, tax authorities, law enforcement or other third parties).

Legitimate Interest of the data controller

In some instances, we need to use the data you supply us for our legitimate interests. This means we’re using your data in a way that you might expect us to, for a reason which is in your interest and doesn't override your privacy, interests or fundamental rights and freedoms.

Consent

For certain information, we’ll ask for your consent. We’ll ask for your consent to:

• Market and communicate our products and services. You can always unsubscribe from receiving these if you want to;

• Help protect you against fraud by tracking the location of your phone if you’ve authorised it;

• View your contact list for airtime purchases.

Who do we share your information with?

In some instances, we will share the information provided with some third parties that we do business with, like card producers and credit bureaus, or with law enforcement agencies when required. Sharing of confidential customer information with these related third parties would be done in a secure manner.

How long do we keep your data?

We keep your information as long as you are a OneWallet customer and for any additional period as required under applicable law or regulations. These retention requirements supersede any right to erasure requests under applicable data protection laws. We cannot therefore erase your data in relation to your OneWallet Account until after this time period, however we can assure you that your data will be held safely and securely whilst under our supervision.

When do we delete your data?

We are basically storing and processing your personal data only as long as it is necessary to perform our obligations under the agreement with you or as long as the law requires us to store it. That means, if the data is not required anymore for statutory or contractual obligations, your data will be deleted.

If you choose to delete your OneWallet account, we will delete any data you have previously given us, including the video of your face uploaded during the liveness check. However this is subject to the retention regulations that apply to such data as stipulated by the regulators.

What are your rights?

You have the right to access and request the information that we have on you in our records. You may also ask us to delete your information on our record, restrict the way in which we use your personal information, ask that we update the personal information we hold about you or correct such personal information which you think is incorrect or incomplete, and we will grant this request as long as we’re legally allowed to. You also have the right to object to us using your information for our marketing purposes or any additional services we may be offering you. Lastly, you may also withdraw any consent you’ve previously given us.

How to make a complaint

At OneWallet, we’re extremely committed to respecting and protecting your personal information. If you have any worries, reservations or complaints about your personal information, please contact our Data Protection Officer by:

• Sending a message via the app.

• Emailing us at help@onewalletweb.com

We will do our best to fix the problem.

Changes to this document

This document will be reviewed on a yearly basis, or more frequently if occasioned by changes or amendment to applicable data protection regulations. If we make any changes, we’ll add a note to this page and if there are significant changes we’ll let you know by email. This policy was last updated on 15 May 2024.