BAMBOO SYSTEMS TECHNOLOGY LIMITED

PRIVACY NOTICE     

LAST REVISED:  15th January 2025

1. Introduction. 

Personal Information is as important to us as it is to you.

At Bamboo Systems Technology Limited (“Bamboo” or “we” or “We”), we are committed to protecting your information.  This Privacy Policy describes how we collect, share, use, and protect your personal information in connection with our Services.The Privacy Policy and our Terms of Service together make up an agreement between you, as a user of our Services and us. By accessing our Services, you accept and agree to this agreement, and agree to the collection, use, and disclosure of your personal data as provided in this Privacy Policy.

We value the privacy of all persons who access our website and all related sites, applications, services and tools (collectively, our “Services”). This Privacy Policy applies to information we collect in connection with our Services.

Should you disagree to abide by our Terms of Service or if you revoke your consent to the processing of your personal data, your account will be disabled, and you will no longer be able to access or interact with the Services.

2. How do we collect information?

Generally, we collect personal information you provide to us. For example:

• Personal identification information, such as name, date of birth, place of birth, nationality, gender, email, address, demographic information, and phone number.

• Supplemental identification information, such as government-issued identity documents, live photo images captured, passport, driver’s license, taxpayer identification number or national insurance number, source of income and employment information including its status and history.

• Financial information, including but not limited to income/wealth verification documents or bank account statements.

• Information on your behavior on our website, including pages viewed, links clicked keystrokes, and actions taken including copy/paste functions or failure to verify the account or lack of transactions (dormant position) and User Application activities carried out within the App. Transaction information, including information related to the use of the Services, types of Services requested, dates and times of such requests, payment methods, and other similar information.

• User Generated Content, content that you submit to the Service or via links to social media networks, forums, blogs, message boards, chat rooms or similar functionality, including audio recordings, software code, videos, photos, images, text, information (including, without limitation, personal information), user comments, and any other content (collectively, “User Content”).

• Location data information about your computer and about your visits to and use of the Service including your Internet Protocol (IP) address, geographical location, browser type and version, devise characteristics, operating system, language preferences, referral source, and information on action taken on the Site, such as; length of visit, page views and website navigation paths.

• Device and Usage Data, Information from and about the devices you use to access the Services, including attributes such as the operating system, hardware version, device settings, file and software names, types, battery and signal strength, device identifiers, device locations, specific geographic locations (such as GPS, Bluetooth, WiFi signals), connection information such as the name of your mobile operator or ISP, browser type, language, time zone, mobile phone number and IP address.

• Communications data, information contained in or relating to any communication with us or our third-party service providers for customer support or other communications, including, without limitation, records and copies of correspondence and responses to surveys for research purposes;

• Metadata, the Service may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts and address book information;

• Additional information required by Bamboo (in its sole discretion) to verify a User's identity, which may include capturing the image of your face in real time for facial matching and/or recognition.

• Any personal information you may provide us through social media channels or promotions held by us or our partners;

• Statistical Data, in connection with your visit or use of the Service, we may automatically collect information about our users, such as the numbers and frequency of users and their characteristics and information about similar groups of users, certain age groups or users that live in a particular geographical area. This data is only used in the aggregate as a statistical measure and not in a manner that would identify you personally. Aggregate information generally is collected through the use of cookies and beacons; and

• any other personal information that you choose to send to us.

3. How We Use Your Information?

          We use the personal information we collect to:  

• provide, operate, maintain, improve, and promote the Service, and any other information, products or services that you request from us;

• To enable you to access and use the Service, including uploading, downloading, collaborating and sharing content, photos, images, videos and information, with other users or third parties;  

• process, verify, and complete transactions, and send you related information, including purchase confirmations and invoices, to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing, collection and enforcement, and to build a user database;

• send transactional messages, including responding to your comments, questions, and requests; providing customer service and support; sending you technical notices, updates, security alerts, and support and administrative messages sending statements;

• send invoices and payment reminders to you, and collect payments from you; and, when we have location information, we use it to tailor our Service for you and others;

• send promotional communications, such as providing you with information about services, features, newsletters, offers, promotions, contests, events and sending updates;

• monitor and analyze trends, usage, and activities in connection with the Service and for marketing, advertising, administrative, analytical, research, optimization, and other purposes. For example, we may use statistical analyses of usage data in order to measure interest in the various areas of the Service, for development purposes and to inform advertisers and partners in aggregate and anonymous terms about consumers who click on their advertising or other messages. IP addresses are also used for systems administration and troubleshooting purposes;

• investigate and prevent fraudulent transactions, unauthorized access to the Service, and other illegal activities;

• personalize the Service’s content, features or advertisements;

• deal with enquiries and complaints made by or about you relating to the Service;

• To verify compliance with the terms and conditions governing the use of the Service; and

• To comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies.

• If you submit personal information, including User Content, for publication on the Service, we will publish and otherwise use that information in accordance with the license you grant to us, and by submitting such information to us, you hereby grant us a worldwide, revocable, sublicensable and royalty-free license to use such personal information for our business purposes. You shall be solely responsible for your own User Content and the consequences of submitting and publishing your User Content on the Service. You further agree that you will not submit to the Service any User Content or other material that is contrary to this Privacy Policy or contrary to applicable local, national, and international laws and regulations.

4. How We Share the Information You Provide?

          We disclose your information in some of the following ways:

Vendors, Consultants, and Other Third-Parties that Assist with Our Business: We may disclose your data to third-party vendors or agents (“vendors”) who perform services for us or on our behalf and require access to such information to do that work. We ensure that these vendors are bound by contracts that include data protection and confidentiality obligations to safeguard your information.

Our Employees, Agents, Consultants, Contractors, or Other authorized personnel: These individuals, including those of our contractors, service providers, subsidiaries, and affiliates, may have access to user information as necessary in the normal course of our business. We implement strict access controls and data protection practices to ensure that this information is handled securely.

Business Transfers: We may disclose or transfer your 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. We require that any transferee adheres to data protection standards similar to those provided in our policy to ensure your information is protected.

Affiliates: We may disclose your information to our affiliates, including our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us. Our affiliates are required to comply with data protection legislation and similar data protection standards when processing your information.

Law Enforcement Agencies, Regulatory or Governmental Bodies: We may disclose your information to respond to legal processes, comply with legal obligations, protect or defend our rights, interests or prevent or investigate wrongdoing in connection with the services. We ensure that disclosures are made in compliance with applicable laws and regulations.

Social Media Networks: We may include applications or widgets from social media networks that allow interaction or content sharing by their users. These widgets, such as a Facebook “Share” or “Like” button, are visible to you on the web page you visit. Integration between the Service and social media networks such as Facebook, Twitter, and others may allow these networks to collect information about you, even when you do not explicitly activate their application or widget. Please review the privacy policies of these social media networks to understand their data collection practices and the choices they offer you.

Consent: We may share your information in other ways if you have asked us to do so or have given your consent.

5. How We Protect Your Information

Safeguarding your personal information is our main concern. We maintain physical, electronic and procedural safeguards that comply with applicable federal laws to secure your information from unauthorized access and use, accidental or unlawful alteration and destruction; and other unlawful or unauthorized forms of processing. We engage in the continuous training of our employees in the proper management of personal information. When we use other companies to provide services, we require them to protect the confidentiality of personal information they receive.

At Bamboo, we take data privacy very seriously and we provide our customers with all necessary data security to protect such personal information from unauthorized access. We require any third parties who carry out any work on our behalf to comply with appropriate compliance standards to protect your information. We are pleased to announce that we comply with global best practices and requirements of the Nigeria Data Protection Act 2023 as may be amended from time to time and any other applicable data protection rules and regulations.

While we take reasonable measures to protect your personal information, you are responsible for maintaining the confidentiality of your account information and any activity that occurs under your account. It is important to:

• Choose Strong Passwords: Use strong and unique passwords for your account, and change them regularly.

• Protect Your Credentials: Keep your login details confidential and do not share them with anyone.

• Monitor Your Account: Regularly review your account activity for any unauthorized actions.

• Log Out: Log out of your account when using shared or public devices to prevent unauthorized access.

If you believe your account has been compromised or notice any suspicious activity, please contact us immediately at [email protected] to secure your account.

We understand that mistakes can happen, but Bamboo shall not be held liable for any damages, losses, or claims arising from the reckless, negligent, or intentional misuse of the Services. This includes, but is not limited to, unauthorized disclosure of personal information, failure to follow security protocols, or engaging in any activities that violate the terms and conditions set forth in this Privacy Policy or any applicable laws. You assume full responsibility for any harm or consequences resulting from such actions.

6. How We Are Allowed to Process your Personal Information

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law. This includes instances such as when we have your consent, need to comply with laws, provide you with services to enter into or fulfill our contractual obligations, protect your rights, or fulfill our legitimate business interests.

Processing of Personal Information shall be lawful if at least one of the following applies:

• You have consented to the processing of your personal data for one or more specific purposes;

• Your information is needed to fulfil a contract that you are a part of or at your request prior to entering into a contract with you;

• It is necessary to protect your Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• Send information about special offers and discounts on our products and services;
• Develop and display personalized and relevant advertising content;
• Analyze how our services are used so we can improve them;
• Support our marketing activities;
• Diagnose problems and/or prevent fraudulent activities; and
• Understand how our products and services are being used so we can improve service experience;

• where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved; and 

• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.     

7.  Individual Rights as a User of our Services

As a User of our Services, you have the following rights:

• Right to request for and access any Personal Information collected and stored by Bamboo - Individuals have the right to access information Bamboo holds, access their personal data  and other supplementary information and obtain information about how we process it.

• Right to be informed regarding your Personal Information - To emphasize the need for transparency over the usage of personal data, we ensure fair processing of information typically through this privacy policy.

• Right to object to automated decision making and processing - Individuals have the right to query a decision/profiling that we make/do about a product or  service that they have applied for and that was made solely by automated means.

• Right to request rectification and modification of Personal Information which Bamboo keeps - The right to rectification  Individuals are entitled to have their personal data rectified if it is inaccurate or incomplete. If this personal data in question has been disclosed to third parties, they must be informed of the rectification where possible. Bamboo must also inform the individuals about the third parties to whom the data has been disclosed where appropriate.

• Right to request the deletion of your data - Individuals have the right to request the deletion or removal of personal data where there is no compelling legal or regulatory requirement for its continued processing. Bamboo will make sure that this right is protected.

• Right to request the movement of your data from Bamboo to a third party - this is the right to the portability of data - We will ensure that personal data is moved, copied or transferred easily from one IT environment to another in a safe and secure way, without hindrance to usability.

• Right to revoke consent; Individuals have a right to ‘block’ or withdraw their consent to our processing of your information, which you can do at any time. When processing is restricted, we are permitted to store the personal data, but not further process it.

• Right to object to direct marketing, and to request that Bamboo restricts the processing of your information - Individuals have the right to object to our processing of their information in some  circumstances.

• Right to submit a complaint to the Nigeria Data Protection Commission (“NDPC”).

8. Cookies

A cookie is a small file that is placed on your computer’s hard drive. Its functions include storing your login and session statuses, recording your user preferences and analyzing web traffic.

Cookies enable websites and applications to store your user preferences in order to enhance your overall website experience by better understanding your preferences, likes and dislikes. They also allow websites to identify when users are logged on their site and when they return to their site, test new content and analyze web traffic with data analytics.

Besides the data you elect to disclose and share with us, we cannot access your computer or any other information about you with cookies.

9. Retaining your Personal Information

Bamboo keeps your information for as long as you maintain an account with Bamboo and except as otherwise permitted or required by applicable law or regulation, only for as long as necessary to fulfill the purposes the Company collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In all cases, in addition to the purposes, we consider the amount, nature and sensitivity of the personal data, as well as the potential risk of harm from unauthorized use or disclosure of your personal data, in determining how long to retain personal data.  

You may request the deletion of your account at any time. Following such requests, Bamboo deletes the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, Bamboo retains location, device, and usage data for these purposes for a minimum of 6 years; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, the Company may be unable to delete a user’s account, such as if there’s an outstanding credit on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, the Company will delete the account as described above.

If you decide that you no longer wish us to keep or use information or you want the information to be revised or updated, please feel free to contact us at [email protected]. We will remove or amend the information as appropriate in accordance with our Privacy Notice and applicable legislative and regulatory requirements.

Under some circumstances the Company may anonymize Users' personal information so that it can no longer be associated with a particular User. The Company reserves the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to the relevant User or its consent.

10. Third Party Links

Our Service contains links to third-party websites or services. Please note that we are not responsible for their content or privacy practices. We encourage all our Users to be cautious when leaving our Service and read the privacy policies of any site that collects your personal information.When you use our Services or its content, certain third parties  may use automatic information collection technology to collect information about you or your device. These  third parties may include but are not limited to : 

• Advertisers, ad networks and ad servers; 
• Analytics companies; 
• Your mobile device manufacturer; 
• Your mobile service provider.

These third parties may use tracking technology to collect information about you when you use the  Service. The information they collect may be associated with your personal information or they may collect  information including personal information, about your online activities over time and across different  websites, apps and other online services websites. They may use this information to provide you with interest  based interest based (behavioral) advertising or other targeted content.  

We do not control these third party tracking technology or how they may be used. If you have any  questions about an advertisement or other targeted content, you should contact the responsible provider directly.

11. Users from Other Jurisdictions

The Service is controlled and operated by us from Nigeria. If you are not a resident of Nigeria or you are located outside Nigeria, you are not authorized to use the Service. If you choose to use the      Service or provide information to us, please note that we may transfer the information, including personal information, outside of Nigeria and process it there.

We do not represent or warrant that the Service, or any portion thereof, are appropriate or available for use in any particular jurisdiction.

Those who choose to access the Service do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations, and are subject to United States  export controls in connection with your use of the Service and are responsible for any violations of such  controls, including, without limitation, any United States embargoes or other federal rules and regulations  restricting exports.

We may limit the availability of the Service, in whole or in part, to any person, geographic area or jurisdiction that we choose, at any time and in our sole discretion.

Personal information that you publish on the Service or submit for publication on our Website may be available, via the Internet, around the world. We cannot prevent the use or misuse of such information by others.

12.  Transfer of Personal Data

As part of our service provision, we may rely on third-party servers, databases co-located with hosting providers, resident in foreign jurisdictions, which constitutes the transfer of your personal data to computers or servers in foreign countries.

These countries may have different data protection laws than your jurisdiction, and in some cases, they may not provide the same level of data protection.

As required under the applicable law, third parties are required to use appropriate safeguards to protect personal information, and they can only access the personal information that is necessary for performing their specific tasks.

We take steps designed to ensure that the data we collect under this Privacy Policy is processed and protected according to the provisions of this Policy and applicable law wherever the data is located.

Where personal data is to be transferred to a country outside Nigeria, Bamboo shall put adequate measures in place to ensure the security of such Personal Information. Any transfer of Personal Information out of Nigeria will be in accordance with the provisions of relevant data protection regulations. Bamboo, shall among other things, use contractual terms to ensure protection of the data or ensure the country has adequate data protection laws (i.e. listed in the National Information Technology Development Agency’s [“NITDA”] White List of Countries, or the General Data Protection Regulation’s “GDPR” Adequacy List).

Should you wish to transfer personal data to a country deemed to have inadequate data protection laws, Bamboo will take all necessary steps to ensure that informed consent is obtained from you, and you are aware of the risks entailed with such transfer. In any instance, Bamboo will ensure Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred abroad, and details of the basis of such transfers shall be provided to you upon request.

13. Changes to Privacy Policy

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification, or as otherwise required by law. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information. Your continued use of our Services after any updates to this Policy constitutes your agreement and acceptance of this Policy as updated.

14.  Children’s Privacy

The Services are intended for general audiences and not for individuals under the age of 18. If we become aware that we have collected “personal information” (as defined by the Child Rights Act, Act No. 26, 2003)   from children under the age of 13 without legally valid parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

15. Our Contact Information.

If you have any questions, feedback or to report a violation regarding the Privacy Policy, you may email us at [email protected] or you may send a letter to Plot 1, Block 22, Nathan Terrace, Lekki Phase 1, Lagos, Nigeria.

16. List of Our Affiliates and Related Properties.

Below is a representative list of some of our affiliated properties and related properties that currently may have access to personal information collected from Users on our Services as set forth in this Privacy Policy.  We may update this list from time-to-time, so please check back periodically to keep up to date. 

Affiliates: Bamboo Systems Ghana Limited, Bamboo Global Inc, Invest Bamboo (Pty) Limited, and Bamboo Securities LLC.  

Related Properties: n/a