Privacy Policy

First draft: February 16, 2021

Last updated: August 2, 2021

Introduction

Welcome to Links Microfinance Bank Limited

At Links Microfinance Bank Limited, we treat your privacy with the highest importance and confidentiality. Our Privacy Policy details the procedures we take to preserve and safeguard your privacy when you visit our website or communicate with our personnel. Our Privacy Policy covers Data Collection, Your Personal Data and how it is Used, Purpose of Data Collection, Right of Data Subject, who can access your Personal Data, Security and Confidentiality, how we transfer your Personal Data outside Nigeria and Third-party link. Other include Cookies Policy and Subject Access Request Response Procedure.

Links Microfinance Bank Limited (“us”, “we”, or “our”) operates https://sofrisofri.com/  (hereinafter referred to as “Service”).

Our Privacy Policy governs your visit to https://sofrisofri.com/ and explains how we collect, safeguard, and disclose information that results from your use of our Service. We use your data to provide and improve Service. By using Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy constitute your agreement with us (“Agreement”).

INTERPRETATION AND DEFINITIONS

Interpretation

The words in 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 in the plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Links Microfinance Bank Limited, 66/68, Alexander Avenue, Ikoyi, Lagos. 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.

Country refers to: Nigeria.

Device means any device that can access the Service such as a computer, a cell phone, or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual. These include a name, gender, a photo, an email address, bank details, medical information, computer internet protocol address, and any other information specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Service refers to the Website.

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 Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.

Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

Usage Data refers to data collected automatically, either generated using the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website refers to Links Microfinance Bank Limited, accessible from  https://sofrisofri.com/

You mean the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

COLLECTING AND USING YOUR PERSONAL DATA

Types of Data Collected

Personal Data

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:

1. Email address
2. First name and last name
3. Phone number
4. Address, State, Province, ZIP/Postal code, City
5. Usage Data
6. Human Resource Data includes information on your employment history, professional and educational information submitted upon applying for employment with us.

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 Service 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 Service 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.

TRACKING TECHNOLOGIES AND COOKIES

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service. The technologies We use may include:

• 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 Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.
• Web Beacons. Certain sections of our Service 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. Learn more about cookies: Cookies: What Do They Do?.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us.

Purpose: These Cookies are essential to provide You with services available through the 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.

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.

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.

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.

Consent

You accept this Privacy Policy and hereby give us consent to save, process, and use your Personal Data to the extent as allowed by law when you provide us with details of your Personal Data, by clicking on the “accept” button or by continuing the use of our website. We may request for further consent if your Personal Data is required to be transferred to a third party for marketing purposes or when it is to be further processed in a manner that would require your further consent.

You may withdraw your consent at any time before, during, and after we process your Personal Data. Personal Data is information that can be directly used to identify you and includes any offline or online data that makes a person identifiable such as names, addresses, phone numbers, passport ID, usernames, digital footprints, photographs, financial data, assets, and liabilities, etc (hereinafter collectively referred to as “Personal Data”).

USE OF YOUR PERSONAL DATA

The Company may use Personal Data for the following purposes:

1. To provide and maintain our Service, including to monitor the usage of our Service.
2. To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
3. 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 Service.
4. 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.
5. To provide You with news, special offers and general information about other goods, services, and events which we offer that are like those that you have already purchased or enquired about unless You have opted not to receive such information.
6. To manage Your requests: To attend and manage Your requests to Us.
7. 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 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.
8. 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 Service, products, services, marketing, and your experience.

We may share Your personal information in the following situations:

1. With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
2. 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.
3. 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 Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
4. With business partners: We may share Your information with Our business partners to offer You certain products, services, or promotions.
5. 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. If You interact with other users or register through a Third-Party Social Media Service, your contacts on the Third-Party Social Media Service may see Your name, profile, pictures, and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
6. With Your consent: We may disclose Your personal information for any other purpose with Your consent.

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, 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.

We limit a One-month period to respond to your access request to your Personal Data in our possession. However, if the one-month timeline cannot be met or where we determine that the request made by you is excessive in nature, we will take steps to inform you and suggest alternative courses of action such as the extension of the time of which to provide the information requested or request for cost for requests of an excessive nature. We subject ourselves to copy the regulatory authority in all such correspondence.

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, province, country, or other governmental jurisdiction where the data protection laws may differ from 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.

DISCLOSURE OF YOUR PERSONAL DATA

Business Transactions

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.

Law enforcement

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).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• 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.

YOUR RIGHTS AS A DATA SUBJECT

The law gives you certain rights in respect to your Personal Data the Company holds about you. Below is a highlight of some of those rights. At any point while we are in possession of or processing your Personal Data, you, the Data Subject has the following rights:

• Right of Access – You have the right to request a copy of the information that we hold about you.
• Right to Rectify – You have the right to correct the Personal Data we hold about you that is inaccurate.
• Right to be Forgotten – In certain circumstances you may ask for the data we hold about you to be erased from our record.
• Right to Restrict Processing – Where certain conditions apply, you have a right to restrict processing of your Personal Data.
• Right to Portability – You have the right to have your Personal Data transferred to another organization.
• Right to Object – You have the right to object to the Processing of Personal Data.
• Lodge Complaint – You have a right to lodge a complaint about the handling of your Personal Data with the National Information Technology Development Agency (NITDA) at info@nitda.gov.ng
• NITDA’s website (https://nitda.gov.ng/) has a wealth of useful information in respect of your rights over your Personal Data. If you wish to exercise your rights, you may contact our Data Protection Officer at (compliance@linksmfb.com) or you may write to us at (info@sofrisofri.com ) or hello@sofrisofri.com

SECURITY OF YOUR PERSONAL DATA

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.

CHILDREN’S PRIVACY

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18 except if the data is provided by the parents or guardians. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please Contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, we take steps to remove that information from Our servers.

LINKS TO OTHER WEBSITES

Our Service 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.

BREACH/ PRIVACY VIOLATION

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data, we shall within 72 (Seventy-Two) hours of having knowledge of such breach report the details of the breach to NITDA. Furthermore, where we ascertain that such breach is detrimental to your rights and freedoms in relation to your Personal Data, we shall within 7 (Seven) days of having knowledge of the occurrence of such breach take steps to inform you of the breach incident, the risk to your rights and freedoms resulting from such breach and any course of action to remedy said breach.

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 Service, 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.

CONTACT US

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

By email: info@sofrisofri.com  or hello@sofrisofri.com

By visiting this page on our website https://sofrisofri.com/

By phone number: +23415151115, +23415151116