Effective March 2025

Introduction

At PLUG DOT NG LIMITED, we don't only respect and value the privacy of our clients, visitors and website and mobile application users but we are also committed to protecting the privacy and security of our customers' personal data/information. This Privacy Policy explains how we collect, use, and protect personal data when you visit or interact with the website or other services offered by PLUG DOT NG LIMITED which is in accordance with the Nigeria Data Protection Act (NDPA) 2023 and other relevant and applicable laws.

Kindly read through this policy as your engagement and usage with our website and services connote that you agree to the collection and use of information in accordance with this policy.

Consent

You consent to our use of your personal information when you(voluntarily) provide us with them to be able to access any of our products online or in any of our outlets. You also consent when you sign forms or documents enabling us to provide certain services to you.

How we use our information

Your everyday service providers are here on PLUGNG to make your life easy, bringing happiness and convenience closer to you.Your everyday service providers are here on PLUGNG to make your life easy, bringing happiness and convenience closer to you.Your everyday service providers are here on PLUGNG to make your life easy, bringing happiness and convenience closer to you.

Scope

This Privacy Policy applies to all individuals who use our payment services, including:

• Customers who create an Account with us.
• Customers who use our Mobile Money Operating Services to send or receive money.
• Customers who use our Payment Service Solution Services to make or receive payments.
• Merchants who use our Payment Services to receive payments.
• Customers who engage and use our Website and Mobile Applications.

Types of Personal Data We Collect

Personal Data for the purpose of this Policy includes information that we collect automatically when you visit our website or any of our channels, information collected upon registration or subscription for our products or services, information collected at Onboarding and maintenance of account, information that you provide or disclose to us voluntarily through;

• Direct Interaction: when you create an account, use our services, or communicate with us.
• Automated Technologies: when you interact with our website, mobile application, or online platforms.
• Third-Party Sources: when we receive information from third-party sources, such as identity verification services or credit reporting agencies.

We collect the following types of personal data:

• Identification Data: Name, Email Address, Phone Number, Contact Address, Photograph, Date of Birth, and Government-Issued Identification.
• Financial Data: Bank Account Information, Payment Card Information, Bank Verification Number(BVN) and Transaction History.
• Mobile Money Data: Mobile Money Account Information, Transaction History, and Balance Information.
• Payment Data: Payment Instrument Information (e.g., Credit/Debit Card, Bank Account), Payment Amount, and Payment Purpose.
• Device Data: IP Address, Device Type, Operating System, and Browser Type.
• Location Data: Location Information, such as City, State, and Country.

Purposes for Which We Use Personal Data

We use personal data for the following purposes:

• To Provide Our Services: to facilitate payments, Mobile Money transactions, and other services.
• To Verify Identity: to prevent fraud, money laundering, and terrorist financing.
• To Improve Our Services: to analyze and improve usage patterns and functionality, identify trends, enhance user experience and performance of our website and mobile applications.
• To Communicate with You: to send notifications, updates, marketing materials and respond to your inquiries
• To Comply with Laws and Regulations: to meet our obligations and comply with applicable laws and regulations, including Data Protection Laws.
• To detect and prevent financial crimes including fraud, financing for terrorism and money laundering for ensuring security and business continuity.

Basis for Processing Information

Prior consent has been obtained from data subjects for the use and processing of personal data

• To comply with our legal obligations
• To satisfy a Public Interest
• To enter and perform our contractual obligations
• For the performance of a statutory duty
• For the legitimate interest of PLUG DOT NG LIMITED and our Data subjects

Sharing of Personal Data

In ensuring and enhancing our service delivery, we may share personal data with our technical support and other service providers, partners, associates and subsidiaries of the company where necessary as well as;

• Service Providers: to facilitate payments, Mobile Money transactions, and other services.
• Identity Verification Services: to verify identity and prevent fraud.
• Credit Reporting Agencies: to assess creditworthiness and prevent fraud.
• Law Enforcement Agencies: to comply with laws and regulations.
• Regulatory Bodies: to comply with laws and regulations.
• Mobile Network Operators: to facilitate Mobile Money transactions.
• Banks and Financial Institutions: to facilitate payments and Mobile Money transactions.

Data Protection and Security

We take the security of the website, our online portals and the information you provide very seriously and also take all appropriate technical measures using recognised reasonable and effective robust security measures, procedures and tools in accordance with good industry practice to protect your personal information from unauthorized access, data loss and misuse, alteration, or destruction and interception by third parties of the information under our control, but, to the extent allowed by law. To the best of our ability, access to your personal limitation is limited to those who have a need to know and are required to always maintain the confidentiality of such information. However, PLUG DOT NG LIMITED assumes no liablity for any damages you may suffer as a result of interception, alteration or misuse of information transmitted over the internet. Whilst we use all reasonable measures to protect your security in the manner described above, we consider that it is only appropriate to advise users that data transmission over the internet and the world wide web cannot be guaranteed as fully secure, and therefore you use the website and online portals at your own risk.

Also, we acknowledge that security cannot be absolutely guaranteed against all threat actors. Hence, we also make reasonable efforts to retain personal information only for so long as the data subject asks that the information be deleted, necessary to comply with legal, regulatory, internal business or policy requirements or the information is necessary to comply with an individual’s request.

Data Retention

Personal Data will be kept secured for as long as is reasonably necessary under the circumstances you are registered or use the website or for as long as you use the service or product that you are subscribed to, comply with laws and regulations, and resolve disputes unless a longer retention period is required or permitted by law. When there is no lawful reason to process your personal information, we may either delete or anonymize such information, or if this is not possible for some reasons, for example, personal information has been stored in backup archives, then we will securely store your information and isolate it from further processing.

Rights of Data Subjects

You have the right to:

• Access: to request access to your personal data.
• Rectification: to request correction of inaccurate personal data.
• Erasure: to request deletion of personal data.
• Restriction: to request restriction of processing personal data.
• Objection: to object to processing personal data.
• Data Portability: to request transfer of personal data to another service provider.
• Withdraw Consent: to withdraw consent at any time after providing consent for the processing of data, though,this will not affect the lawfulness of any processing that occurred prior to the withdrawal

Links And/Or Third Party Websites

Our website or any of our online portals may contain links to third-party websites and other websites of interest, you should note that this policy applies only to our website and as such,once you have used these links to leave our site, you should note that we do not have any control over the other website as well as responsible for the privacy practices or the content of any external sites. PLUG DOT NG LIMITED does not endorse these sites, its sponsors or any of the policies, activities, products or services offered on these sites or by any advertiser on these sites. We encourage you to review the privacy policies of any third party websites or links before sharing any personal information with them as we will not be responsible for the protection and privacy of any information which you provide whilst visiting such sites as such sites are not governed by this privacy policy. This privacy policy applies to only information collected by our online portals.

Complaints and Disputes

If you have any complaints or disputes regarding our handling of personal data, please contact us at: [email protected]m or our 24 hours Live Chat for optimum response.

Policy and Website Updates

We may modify or update this Privacy Policy from time to time. However, we shall provide you with notice of any changes by posting them on our website or mobile application. You are responsible for periodically reviewing the most current version of any of our online portals as your continued use of our platforms will be deemed your acceptance of the Updated Privacy Policy. The company reserves the right to change or delete any information, content of the pages of our online portals at any time but with notice.

This privacy policy was last updated on the … March 2025.

Governing Law and Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria.

Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at: