Privacy policy

Introduction

This Policy describes how Brails Financials Inc. on behalf of itself, subsidiaries, and affiliates (hereinafter called “Brails” or “we" or “our”) will ensure the data privacy of its users.This Policy applies to the personal data collected by Brails when you use our website, mobile application, social media platforms, tools and any other platform belonging to Brails (collectively, the "Services") or otherwise interact with us as described below.We may update our Policy from time to time at our sole discretion. Thus, you are advised to review this page periodically for any changes. These changes are effective immediately after they are posted on this page. Where updates are made to the Policy, we will notify you of same by updating the date at the top of this Policy, and in some cases, provide you with additional notice (by adding a statement to the homepages of our website or mobile application; or by sending you an email notification).

Consent

This Policy describes how Brails Financials Inc. on behalf of itself, subsidiaries, and affiliates (hereinafter called “Brails” or “we” or “our”) will ensure the data privacy of its users.This Policy applies to the personal data collected by Brails when you use our website, mobile application, social media platforms, tools and any other platform belonging to Brails (collectively, the "Services") or otherwise interact with us as described below.We may update our Policy from time to time at our sole discretion. Thus, you are advised to review this page periodically for any changes. These changes are effective immediately after they are posted on this page. Where updates are made to the Policy, we will notify you of same by updating the date at the top of this Policy, and in some cases, provide you with additional notice ( by adding a statement to the homepages of our website or mobile application; or by sending you an email notification).

Collection of Personal Data

For a better experience, while using our Services, we may require you to provide us with certain personally identifiable information, including but not limited to your name, address, phone number, email address, date of birth, bank account information, BVN, username, password, and next of kin details.When you create a Brails account, we may collect information about you from third party service providers to verify your identity and for fraud prevention. We will notify you when we receive information about you from them and the purposes for which we intend to use that information. The information that we request will be retained by us and used as described in this Policy.The mobile application does use third party services that may collect information used to identify you.Link to privacy policy of third party service providers used by the app Google Play Services.

• Google Play ServicesFirebase AnalyticsCookies

Cookies

For a better experience, while using our Services, we may require you to provide us with certain personally identifiable information, including but not limited to your name, address, phone number, email address, date of birth, bank account information, BVN, username, password, and next of kin details.When you create a Brails account, we may collect information about you from third party service providers to verify your identity and for fraud prevention. We will notify you when we receive information about you from them and the purposes for which we intend to use that information. The information that we request will be retained by us and used as described in this Policy.The mobile application does use third party services that may collect information used to identify you.Link to privacy policy of third party service providers used by the app Google Play Services.

Use of Personal Data

For a better experience, while using our Services, we may require you to provide us with certain personally identifiable information, including but not limited to your name, address, phone number, email address, date of birth, bank account information, BVN, username, password, and next of kin details.When you create a Brails account, we may collect information about you from third party service providers to verify your identity and for fraud prevention. We will notify you when we receive information about you from them and the purposes for which we intend to use that information. The information that we request will be retained by us and used as described in this Policy.The mobile application does use third party services that may collect information used to identify you.Link to privacy policy of third party service providers used by the app Google Play Services.

Third Service Provider

We may employ third-party companies and individuals due to the following reasons:

• To facilitate our Services;
• To provide some services on our behalf; and
• To assist us in analyzing how our Service is used.

We want to inform users of our Services that these third parties have access to your personal information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose. Brails does not sell its user lists to third parties.

Security

Brails takes reasonable measures to help protect all personal datafrom loss, theft and unauthorized access. To prevent unauthorized access to your information, we have implemented strong controls and security safeguards at the technical and operational levels. Additionally, Brails implements policies designed to protect the confidentiality and security of your personal data, including a privacy protection policy. Brails limits access to your personal data to employees that have a business reason to know such personal data and implement security practices and procedures designed to protect the confidentiality and security of such personal data and prohibit unlawful disclosure of such personal data in accordance with its policies.Where you have chosen a password that allows you to access certain parts of the website and mobile application, you are responsible for keeping this password confidential. We advise younot to share your password with anyone. We have also taken measures to comply with provision of security facilities for the protection of your personal data through the set-up of firewalls, limited access to specified authorized individuals, encryption and continuous capacity building for relevant personnel. We therefore have digital and physical security measures to limit and eliminate possibilities of data privacy breach incidents. We value your trust in providing us your personal data, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

Link to other sites

Our Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the privacy policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Children’s Privacy

Our Services do not address anyone under the age of 16. We do not knowingly collect personally identifiable information from children under 16. in the event we discover that a child under 16 has provided us with personal information, we immediately deletethis from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions

Privacy Rights

This Policy describes your privacy rights regarding our collection, use, storage, sharing and protection of your personal data. It applies to our website, mobile application and all other related applications, services, tools, and physical contact with us regardless of how you access or use them.You have the following rights:`

• right to request for access to and rectification or erasure of your personal data
• right to restrict processing or object to processing of your personal data;
• right to data portability;
• right to withdraw consent at any time,without affecting the lawfulness of processing based on consent before its withdrawal; and
• right to lodge a complaint with the relevant authority.

In the event that you wish to: (i) access your personal data processed by us in accordance with this Policy; (ii) ask any questions at all regarding our use of your personal data; (iii) rectify your personal data processed by us in accordance with thisPolicy; (iv) restrict or object to the processing of your personal data; (v) withdraw your consent to our processing of your personal data; or (vi) request for data portability, please reach outto us at hello@onbrails.comWe respect your privacy and give you an opportunity to opt-out ofreceiving announcements of certain information. You may opt-outof receiving any or all communications from Brails by contacting us at hello@onbrails.comWe will retain your personal data for the duration of our Services to you and afterwards for as long as is necessary and relevant for purposes permitted by applicable laws and regulations.

Lawful Basis For Processing Personal Data

We only process personal data where we have a lawful basis for doing so, such as the following.

• user consent - this is where you have given us explicit permission to process personal data for a given purpose. For example, if you create a profile on our mobile application, we may additionally ask you to consent.
• to comply with our legal and regulatory obligations.
• right to data portability;
• to perform a contract with you or to take steps at your request before entering a contract.
• to use your personal data as is necessary for our legitimate interests or the legitimate interests of others.
• to protect your interest, the interest of another data subject or for the performance of a task carried out in the public interest or in exercise of official public mandate.

Data Breach

In the event we become aware that the security of our Services have been compromised or user's personal information have been disclosed to unrelated third parties as a result of an external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected users if we believe that there is a reasonable risk of harm to the user as a result of the breach.

Contact Us

If you have any questions or suggestions about our Policy, do not hesitate to contact us at hello@onbrails.com