Privacy Policy
Introduction
Flutterwave and its affiliates (collectively “Flutterwave”) do not take Your trusting us with Your information for granted. The privacy of our Users is important to us and we are committed to safeguarding it responsibly and in accordance with the legal requirements of the countries in which we operate. Hence, this Privacy Notice explains the type of Your Personal Information which we collect, why we collect it, and what we do with it.
If you reside in the United Kingdom, your data controller is Flutterwave UK Limited with offices at 41 Luke Street, London, United Kingdom, EC2A 4DP. Our registration number with the Information Commissioner’s Office UK is ZA460204. If you feel that we have not addressed your questions concerning your personal data adequately, you may make a complaint with the Information Commissioner’s Office (ICO) in the United Kingdom.
For any access request, questions, or inquiries about how we use Your Personal Information, please contact us at send@flutterwavego.com
Overview
This Privacy Notice describes Your privacy rights regarding how and when we collect, use, store, share and protect Your personal information across our website or site, Application Programming Interface (APIs), Software Applications including web application and mobile application accessible at send.flutterwave.com (“Site”), email notifications and tools (jointly referred to as “Services”), regardless of how You use or access them.
Flutterwave is part of a group which is made up of a number of local operating entities in a number of markets across the globe. “Flutterwave”, “we” “us” or our” in this privacy statement means the Flutterwave entity that is responsible for processing Your Personal Information.
Definition
Account: means an account opened and maintained by You with Flutterwave to enable You use or access the Services.
Cookies: A cookie is a small data file that is transferred to Your computer or mobile device. It enables us to remember Your account log-in information, IP addresses, web traffic, number of times You visit, browser type and version, device details, date and time of visits.
Data Protection Legislation: means the UK General Data Protection Regulation 2016/679; the Data Protection Act (2018) (as may be amended) and all other application legislation relating to privacy or data protection.
Personal Information: Any information that can be used to identify a living person including Identity Data such as Your full name and government issued identification number, Contact Data such as contact and email address, Financial Data such as credit or debit card information, bank account number, etc., taxpayer identification, it may also include anonymous information that is linked to You, for example, Your internet protocol (IP), log-in information, address, location, device or transaction data and/or such other data personally identifiable to You as specified in this Privacy Notice.
User or You or Your: means an individual who accesses or uses the Services and has agreed to use the end services of Flutterwave offered through the Site.
Special Categories of Personal Information means details about Your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about Your health and genetic and biometric data.
Objective
This Privacy Notice provides all persons and organizations whose Personal Information we hold with a description of the types of Personal Information we collect, the purposes for which we collect that Personal Information, the other parties with whom we may share Personal Information with, and the measures we take to protect the security of the data.
We have outlined our Privacy Notice below.
Our Privacy Principles
Flutterwave focuses on the following core principles
To Empower the individual: Flutterwave wants You to be in charge of Your Personal Information and to make Your own voluntary choices about Your Personal Information;
To keep and secure Personal Information: Flutterwave does not take Your trusting us with Your information for granted. We take responsibility to ensure that appropriate security measures are put in place and Your Personal Information is protected;
To be transparent and to educate Users: For You to know what Personal Information is, how we collect Personal Information, the purpose for collecting Personal Information and how we secure Personal Information;
To abide by local privacy laws: Flutterwave is a global company committed to complying with local privacy laws. Our privacy practices may vary among the countries in which we operate to reflect local legal requirements.
To collect and store Personal Information on the “need to collect” basis: Flutterwave collects Personal Information to perform its services for You. We implement measures to prevent collecting and storing Personal Information beyond what we need.
Personal Information We May Collect About You
We may collect, record and use information about You in physical and electronic form and will hold, use and otherwise process this data in accordance with the Data Protection Legislation and as set out in this Policy.
The Personal Information we collect and use may include, amongst other things:
Identity Data: Information such as, Your full name(s), Your government-issued identity number, and Your date of birth. This data is to enable us to verify Your identity in order to offer our Services to You;
Contact Data: This is data that we use to You, such as Your residential address, email address, telephone number, details of the device You use and billing details;
Identification documents: (such as Your passport or any Government-issued identity card), a photograph (if applicable) and any other registration information You may provide to prove You are eligible to use our Services and in compliance with regulatory requirements on Know Your Customer (KYC);
Usage Data: When You access the Services, our servers automatically record information about how You use our Services including links You have clicked on, length of visit on certain pages, unique device identifier, log-in information, location and other device details.
Financial Data: Information, such as credit card, debit card, personal account number or bank account information, the date and the total amount of transaction, and other information provided by financial.
Personal Information of Third Party: We may also collect Personal Information including financial information of any individual, other than Yourself, that receives payment from You during Your use of our Services. In such case, You confirm to us that You have obtained requisite consent from such an individual to disclose his/her Personal Information to us for the use and processing of such Personal Information by us for the purpose of providing the Services to You.
Information from third parties or other sources: We may also receive Personal Information about You from third parties or other sources such as Your financial institution, to confirm the basic Personal Information about You or our identity verification partners, in line with the fulfilment of our Anti Money Laundering and Combating the Financing of Terrorism (AML/CFT) obligations.
Transactional Data: This is information containing details of the transactions You carry out when using our Services, including geographic information;
Marketing and Communications Data: This includes both a record of Your decision to subscribe or to withdraw from receiving marketing materials from us or from our third parties.
Records of Your discussions with us, if we contact You and if You contact us.
Information about Your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.
We may also collect, store, use and transfer non-Personal Information or anonymized data such as statistical or demographic data. As a principle, we do not collect any Special Categories of Personal Information. If we do collect Special Categories of Personal Information, we will ensure compliance with applicable law.
It is important that the Personal Information we hold about You is accurate and current. Please keep us informed if Your Personal Information changes during Your relationship with us.
This Privacy Notice applies to the Flutterwave Services only. We do not exercise control over the sites displayed or linked from within our various services. These other sites may place their own cookies, plug-ins or other files on Your computer, collect data or solicit Personal Information from You. Flutterwave does not control these third-party websites and we are not responsible for their privacy statements. Please consult such third parties’ privacy statements and set appropriate controls from Your setting when using any third-party services.
How we collect Your Personal Information and why we have it
The Personal Information we have about You is directly made available to us when You:
Sign up for an Account;
Use any of our Services;
Contact our customer support team;
Fill our online forms;
Enter a Flutterwave sponsored or affiliated promotion;
Contact us;
Social Media: depending on Your settings on the privacy policies for social media and messaging services such as Facebook, LinkedIn and Instagram. You might give us permission to access information from those accounts or services.
Other Sources: we may receive information about You from other sources, including publicly available databases and combine this data with information we already have about You, This helps us to update, expand and analyse our records and provide services that may be of interest to You.
Our Legal basis for processing your Person Information
We only use Your Personal Information for a specific purpose; and before we do so, we must have a legal reason. For example, when it is necessary for us to perform a contract with You for our Services, for our legitimate interest, or where You have given us Your consent, or to fulfill our legal obligations. These are all known as the “legal or lawful basis for processing’.
The legal or lawful basis we rely on for processing Your Personal Information are:
Your consent; Where You agree to us collecting Your Personal Information by using our Services.
With your consent, we may send marketing and promotional communications by email, SMS and push notifications (depending on your choice of contact). For more information please see the Marketing section of this policy.
We may send targeted marketing about our services on third-party online services such as Google, Instagram and Facebook if we believe that you are likely to be interested in using our services based on Your profile. Your consent to receive targeted adverts would have been obtained by these third parties on our behalf.
Surveys: engaging with You for the purposes of obtaining Your views on our Site or Services.
We have a contractual obligation: Without Your Personal Information, we cannot provide our Services to You or perform our contract to you or take steps prior to entering a contract with us.
Deliver our products and provide with our services such as conducting money transfers, payment services and mobile phone top-ups. This may include “know your client” checks and verifying Your identity and confirming Your financial details.
Notifying You of any changes to our Services, or our site or changes to our terms or Policy.
Enable third parties to perform technical, logistical, or other functions for us.
Investigate, respond and resolve any complaints you may have.
We have a legal obligation: To ensure we are fully compliant with all applicable Data Protection Legislation, Financial legislations such as Anti-Money Laundering and Counter Terrorist Financing Laws, we must collect and store Your Personal Information. We protect against fraud by checking Your identity with Your Personal Information.
We have a legitimate interest: We may also collect Your Personal Information where we have a legitimate interest to do so, provided that Your rights do not override such interests.
How We May Use Your Personal Information
We may use Your Personal Information we collect to:
Create and manage any accounts You may have with us, verify Your identity, provide our Services, and respond to Your inquiries;
Process Your transactions while using our Services;
To allow other customers to request or send money to You through our Services;
Protect against and prevent fraud, unauthorized transactions, claims and other liabilities;
Provide, administer and communicate with You about products, services, offers, programs and promotions of Flutterwave, financial institutions and partners;
Evaluate and improve our business, including developing new products and services;
To target advertisements, newsletter and service updates;
Notify You on changes to our Terms and Conditions or this Policy.
As necessary to establish, exercise and defend legal rights;
As may be required by applicable laws and regulations, including for compliance with Know Your Customers and risk assessment, Anti-Money Laundering, anti-corruption and sanctions screening requirements, or as requested by any judicial process, law enforcement or governmental agency having or claiming jurisdiction over Flutterwave or Flutterwave’s affiliates;
To use data analytics to improve our Services, user experiences and to optimize service delivery.
For other purposes for which we provide specific notice at the time of collection.
To comply with Data Protection Legislation and any other applicable laws.
We will only use Your Personal Information for the stated purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purpose. If You wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use Your Personal Information for an unrelated purpose, we will notify You and we will explain the legal basis which allows us to do so
Please note that we may process Your Personal Information without Your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Data Security and Retention
The security of Your Personal Information is important to Flutterwave. We are committed to protecting the information we collect. We maintain administrative, technical and physical controls designed to protect the Personal Information You provide, or we collect against loss or theft, as well as against any unauthorized access, risk of loss, disclosure, copying, misuse or modification.
Other security measures include but not limited to, secure servers, firewall, data encryption and granting access only to employees in order to fulfill their job responsibilities.
Where You use a password for Your Account, please ensure You do not share this with anyone, and the password is always kept confidential and secure. Flutterwave shall not be responsible for any loss that arises in relation to Your Account as a result of the disclosure of Your password to any third party.
We are committed to conducting our business in accordance with the principles set out in this Privacy Notice in order to ensure that the confidentiality of Your Personal Information is protected and maintained. Transmitting information online is not entirely secure. As such, we cannot guarantee that all information provided online is secure. We would take all reasonable steps to ensure that Your Personal Information is secured and well protected.
We will only retain Personal Information on our servers for as long as is reasonably necessary as long as we are providing Services to You. When You close Your Account, Your information is stored on our servers to the extent necessary to comply with regulatory obligations and for the purpose of fraud monitoring, detection and prevention.
To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of Your Personal Information, the purposes for which we process Your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Where we retain Your Personal Information, we do so in compliance with limitation periods under the applicable law.
Disclosing Your Personal Information
We may disclose or share Your Personal Information with third parties which include our affiliates, employees, officers, service providers, financial institutions, agents, suppliers, subcontractors as may be reasonably necessary for the purposes set out in this policy.
Flutterwave only shares Personal Information with external third parties in the following limited circumstances:
We have Your consent. We require opt-in consent for the sharing of any Personal Information; We share Personal Information with third parties directly authorized by You to receive Personal Information, such as when You authorize a third party application provider to access Your account. The use of Your Personal Information by an authorized third party is subject to the third party's Privacy Notice and Flutterwave shall bear no liability for any breach which may arise from such authorization by You.
We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing Personal Information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Notice and any other appropriate confidentiality and security measures.
Where We reasonably determine that the disclosure of your Personal Information is required by a competent regulatory authority, information request by law enforcement agencies, response to subpoenas, warrants, such as court orders, financial service regulators, security authorities or as otherwise required by law.
We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:
satisfy any applicable law, regulation, legal process or enforceable governmental request,
enforce applicable terms of service, including investigation of potential violations thereof,
detect, prevent, or otherwise address fraud, security or technical issues,
assess financial and insurance risks, or
protect against imminent harm to the rights, property or safety of Flutterwave, its users or the public as required or permitted by law.
If Flutterwave becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before Personal Information is transferred and becomes subject to a different Privacy Notice.
Marketing
We may process Your Personal Information in order to contact You or send You marketing content and communication about our products, services or surveys. You may exercise Your right to object to such contact from us or opt out from the marketing content. Where You do not opt out from receiving marketing content and communication about our products, services or surveys, we will consider that we consent to proceed to send such marketing content to You. Please note however that if You opt-out of marketing content, we may still send You messages relating to transactions and our Services related to our ongoing business relationship.
We may ask You for permission to send notifications to You. Our Services will still work if You do not grant us consent to send You notifications.
Your Data Protection Rights and Choices
Based on Your location and applicable laws, below are the rights You have as a user in relation to Your Personal Information:
Right to be informed.
Right to request access or copies to Your Personal Information by signing into Your Account or contacting us.
Right to request that Flutterwave erase Your Personal Information. You have the right to ask us to erase Your Personal Information. Please note that this is a limited right which applies where the data is no longer required in relation to the purpose for which the data was collected and processed by us, or the processing has no legal justification. The exceptions to this right include where the applicable law requires Flutterwave to retain a historical archive for public interest or such other related purposes, for the establishment, exercise or defense of legal claims or where we retain a core set of Your Personal Information to ensure we do not inadvertently contact You in future where You object to Your data being used for marketing purposes.
Right to lodge complaints with a data protection authority regarding the use of your Personal Information by Us.
Right to not be subject to a decision based solely on automated processing.
Right to correct or rectify any Personal Information that You provide which may be incorrect, out of date or inaccurate. You also have the right to ask us to complete information You think is incomplete.
Right to object to the processing of Your Personal Information for marketing purposes. You have a right to ask us not to contact You for marketing purposes by adjusting Your notification preference on the settings page or by opting out via the unsubscribe link in marketing emails we send You.
Right to object to processing: You have the right to object to the processing of Your Personal Information in certain circumstances. Please note that where You object to us processing Your Personal Information, we might be unable to provide the services to You.
Please note that We may require proof of your identity, to verify You and Your request, before we can give effect to your rights.
The basis of our processing Your Personal Information is Your consent. You also have the choice at any time to withdraw consent which You have provided.
You also have a choice to deactivate Your Account at any time. You may contact us should You wish to de-activate Your Account at any time via the Contact Us segment below or send us an email at send@flutterwavego.com .
If You wish to exercise any of the rights set above, please contact us using the contact information provided in the Contact Us segment below. Where we are unsure of Your identity, we might ask You for proof of Your identity for security reasons before dealing with Your request.
Cookies
Like many other websites, we use cookies to distinguish You from other users and to customize and improve our services.
Some browsers may automatically accept cookies while some can be modified to decline cookies or alert You when a website wants to place a cookie on Your computer. If You do choose to disable cookies, it may limit Your ability to use our website. For detailed information on the cookies and how we use them see our Cookie Policy.
Minor
Flutterwave’s websites and applications are not directed at persons under the age of eighteen (18) and we do not collect any Personal Information knowingly or directly from minors.
Where You have any belief that Flutterwave has mistakenly or unknowingly collected information from a minor, please contact us using the information provided under the Contact Ussection to enable investigate and restrict such data.
International Data Transfers
Our business is global with affiliates and service providers located around the world. As such, Personal Information may be stored and processed in any country where we have operations, which may be outside the United Kingdom ("UK").
By submitting Your Personal Information to us, You agree to this transfer, storing and processing. We note that Your Personal Information may be transferred to countries which may not have the same data protection laws as the country You initially provided Your Personal Information, but whenever we transfer or transmit Your Personal Information internationally, we will ensure or take reasonable steps to ensure Your Personal Information is handled securely in line with the applicable data protection laws and standard contractual clauses.
Dispute Resolutions and Filing a Complaint
If You have any complaints regarding this Privacy Notice, please contact us at send@flutterwavego.com. We will investigate and work on resolutions for complaints and disputes regarding use and disclosure of Personal Information within reasonable time in accordance with this Privacy Notice and in accordance with applicable data protection laws.
Updates to our Privacy Notice
From time to time, we may change, amend or review this Privacy Notice to reflect new services or changes in our Privacy Notice and place any updates on this page. All changes made will be posted on this page and where changes will materially affect You, we will notify You of this change by placing a notice online or via mail. If You keep using our Services, You consent to all amendments of this Privacy Notice.
Contact us:
All access requests, questions, comments, complaints and other requests regarding the Privacy Notice should be sent to send@flutterwavego.com.
We may request additional details from You regarding Your complaints and keep records of Your requests and resolution.