Privacy Policy

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Our Privacy Policy was last updated on 24th June, 2024.

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This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of your information when you access and use the Twinku App and/or Website (our “Products”) and informs you about your privacy rights and how the law protects you.

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We use your personal data to provide and improve products and the services we render to you. By using our product, you agree to the collection and use of information in accordance with this Privacy Policy.

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Interpretation and Definitions

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1. Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or  plural

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2. Definitions

For the purposes of this Privacy Policy:

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  • "Account" means a unique account created for you to access our Products or parts of our Products.
  • "Business", for the purpose of the Companies and Allied Matters Act, 2020, as may be amended refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in Nigeria.
  • "Company" (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Twinku Solutions and Technologies Limited (RC ) For the purpose of the NDPR, the Company is the Data Controller.
  • "Country" refers to Nigeria
  • "Cookies" are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses. alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • "Data Controller", for the purposes of the NDPR refers to the Company as the legal person which
  • "Device" means any device that can access the Products such as a computer, a cell phone or a digital tablet.
  • "NDPR” means the Nigeria Data Protection Regulation (2019).
  • “Personal Data" is any information that relates to an identified or identifiable individual. For the purposes of NDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
  • "Products" refers to the Company’s website and mobile application.
  • "Service Provider" means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Products, to provide or improve the Products on behalf of the Company, to perform services related to the Products or to assist the Company in analyzing how the Products are used. For the purpose of the NDPR, Service Providers are considered Data Processors.
  • "Usage Data" refers to data collected automatically, either generated by the use of the Products or from the Products infrastructure itself (for example, the duration of a page visit).
  • "Website" refers to the Company’s website accessible from www.twinku.co

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Collecting and Using Your Personal Data

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1. Types of Data Collected

&#160;&#160;&#160;&#160;&#160;&#160;1.1.  Personal Data<BR>

<p style="margin-left:4.6rem;">While using Our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:</p>

  • Email address
  • First name and last name
  • Address, State, ZIP/Postal code, City
  • Bank account number
  • Fintech account usernames and account details
  • Bank Verification Number (BVN)
  • Government Issued Identity

1.2.  Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Products that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Products by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

2. Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on our Products and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Products. The technologies We use may include:
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  • Cookies or Browser Cookies. A cookie is a small file placed on your Device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Products. Unless you have adjusted your browser setting so that it will refuse Cookies, our Products may use Cookies.
  • Web Beacons. Certain sections of our Products and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. We use both Session and Persistent Cookies for the purposes set out below:
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  • Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide you with services available through our Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.
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  • Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website
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  • Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website.
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  • Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.
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For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

3.  Use of Your Personal Data

The Company may use Personal Data for the following purposes:
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  • To provide and maintain our Products, including to monitor the usage of our Products.
  • To manage your Account: to manage your registration as a user of the Products. The Personal Data you provide can give you access to different functionalities of the Products that are available to you as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Products.
  • To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
  • To manage Your requests: To attend and manage your requests to Us.
  • For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Products, services, marketing and your experience.
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We may share Your personal information in the following situations
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  • With Service Providers: We may share your personal information with Service Providers to monitor and analyze the use of our Products, for payment processing, to contact you.
  • For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
  • With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include any subsidiaries, joint venture partners or other companies that we control or that are under common control with Us.
  • With business partners: We may share your information with our business partners to offer You certain products, services or promotions.
  • With other users: when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With your consent: We may disclose Your personal information for any other purpose with Your consent.

4.  Retention of Your Personal Data

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or We are legally obligated to retain this data for longer time periods.

5.  Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.


6. Disclosure of Your Personal Data

6.1. Business Transactions
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If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
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6.2. Law enforcement
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Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Where this is the case, we would provide sufficient information to you before any such disclosure, provided that this is permitted by applicable law.
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6.3. Other legal requirements
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The Company may disclose your Personal Data in the good faith belief that such action is necessary to;
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  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability
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6.4. Security of Your Personal Data
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The security of your Personal Data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect your Personal Data, We cannot guarantee its absolute security.
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6.5. Detailed Information on the Processing of Your Personal Data
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The Service Providers we use may have access to your Personal Data. These third-party vendors collect, store, use, process and transfer information about your activity on our Service in accordance with their Privacy Policies.
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6.6. Analytics
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We may use third-party Service providers to monitor and analyze the use of our Service.
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6.7. Email Marketing
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We may use your Personal Data 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 or by contacting us.
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6.8. Payments
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We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards and requirements necessary to help ensure the secure handling of payment information.
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7. NDPR Privacy Policy

7.1. Legal Basis for Processing Personal Data under NDPR
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We may process Personal Data under the following conditions
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  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company
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In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
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7.2. Your Rights under the NDPR
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The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within Nigeria, to:
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  • Request access to your Personal Data. The right to access, update or delete the information We have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact Us to assist you. This also enables you to receive a copy of the Personal Data We hold about you.
  • Request correction of the Personal Data that We hold about you. you have the right to have any incomplete or inaccurate information we hold about you corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.
  • Withdraw Your consent. You have the right to withdraw your consent on using your Personal Data. If You withdraw your consent, We may not be able to provide you with access to certain specific functionalities of the Products.
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7.3. Exercising of Your NDPR Data Protection Rights
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You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, We will try our best to respond to you as soon as possible
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7.4. Sale of Personal Information of Minors Under 16 Years of Age
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We do not knowingly collect personal information from minors under the age of 18 through our Products, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of customers we actually know are less than 18 years of age, unless We receive affirmative authorization (the "right to opt-in") from either the customer who is between 13 and 18 years of age, or the parent or guardian of a Customer less than 13 years of age. Customers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us.

If you have reason to believe that a child under the age of 13 (or 18) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.
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8. Deletion of Personal Data/User Account

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You have the right to delete your account at any time through our app. To delete your account, log in to the mobile app and navigate to theo"Account" menu on the bottom navigation bar, click on "Delete account" and complete the process. Upon deletion, all personal data associated with your account will be permanently removed from our servers. This includes, but is not limited to, the following types of data:

1. Personal Information: Your name, email address, phone number, and any other contact information.
2. Account Details: Username, profile information, and any preferences or settings you have configured.
3. Usage Data: Logs of your interactions with the app, including activity history, search history, and any saved content.
4. Transaction Data: Any records of purchases, subscriptions, or transactions conducted through the app.
5. Content and Communications: Messages, posts, and other content you have created or shared within the app.
6. Linked Accounts: Information from third-party accounts that you have linked to our app (e.g., social media profiles).

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Please note that once your account is deleted, this action cannot be undone, and your data cannot be recovered. If you wish to delete your account, please follow the instructions provided in the app’s settings menu.

For any assistance or further information regarding account deletion, please contact our support team at support@twinku.co.

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9.  Links to Other Websites

Our Products may contain links to other websites that are not operated by us. If You click on a third party link, You will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
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10.  Changes to this 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.

We will let You know via email and/or a prominent notice on our Products, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

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.

11.  Contact Us

If you have any questions about this Privacy Policy, You can contact us:
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