Privacy Policy | Shekel Mobility

Privacy Notice

Effective from 2023

Introduction

This data privacy notice describes your privacy rights regarding how Shekel MobilityLimited, (“Shekel Mobility”, “our”, “we”, “us”) collects, processes, uses, stores, and discloses your personal data when you use our website and all related sites, applications, and services (“Platform”). For the purpose of this Policy, “Personal Data” refers to any information relating to an identified or identifiable natural person.
We provide credit facilities and financial services to automobile dealers registered on our platform. We also offer a global marketplace that connects dealers, agents, and direct sellers to facilitate the easy trading of cars. As part of our services, we are committed to protecting our customers' personal data, ensuring it is handled responsibly and in compliance with data protection standards throughout our business relationships
By registering to use our services or register with our Platform, you signify that you have read, understood and agreed to our collection, storage, use and disclosure of your personal information as described in this Notice and our Terms of Use.

Scope

This Notice applies to all information we collect, use, store, share, collect from users including but not limited to, name, date of birth, contact details, and financial information when you visit our website, or use our Services through our Platform.

Version Control

We may in our sole and absolute discretion, change or revise this Notice, and any other policy or agreements which are referenced or incorporated under it. Such changes or revision shall be effective immediately upon posting it on our website or mobile application. We will notify you of such changes or revision by indicating the “Last Modified Date”. Your continued use of our Services after such change or revision shall constitute your acceptance of the Notice. If you do not agree to the Notice as at the Last Revised Date, do not use or continue to use our Services.

How we collect personal information.

When you register with or subscribe to Shekel Mobility Limited, submit an inquiry to us on social media and volunteer information to us; we may collect personal information from you, which may include your full name, date of birth, identification number, email address, mobile phone number, financial information, KYC information, pictures, incorporation documents and other information that identifies you (collectively, "Personal Information").
By providing your Personal Information and any other kind of information or data to us, you expressly agree to our collection, use, storage, and disclosure of such information for the Purpose as described in this Privacy Policy.

The Information we collect.

For the purpose of this notice, the nature of information we collect are

Personal Information; Personal information is the unique information or aggregated data, which when processed with other information can identify you as a human being. The nature of personal information we collect are those which are necessary for the purpose of providing our services (KYC and ascertain credit worthiness) to you and they include name, telephone number, email address, physical address, financial information( credit card number, expiry date and CVV security number) and other relevant information. We may use third party tools for the verification, We may also retain information for a period of time after use. This timeline is guided by our data retention policy, data protection laws, and industry regulations and guidelines applicable to us.
Inventory and Accounting management data: After onboarding and while connecting on the Platform, we collect certain data from you. This information is collected and processed on an absolute necessity basis as required by law and industry standards to which we are mandated to comply. The data we collect includes transaction records, vehicle listings, financial transactions, and relevant accounting details necessary for business operations.
Location Information: we may receive information from you that helps approximate your location, such as using an IP address received from your browser to determine an approximate location. We may also collect location information from devices in accordance with the consent process provided by your device;
In summary we may request for Financial Data,Technical Data e.g internet protocol (IP) address;Profile Data ;Usage Data, Social Media, Third Parties e.t.c
Information collected through the use of our Services: we collect information about how you use our Service, your actions on and your communications with us through our website or mobile application (“Platform”).

How we collect your information

We automatically collect public and non-public information about you when you visit our website, or use our mobile application, or communicate with us through our customer support channels or when you apply or sign up to use any of our Services through a third party platform or read our emails, or through third party service providers and other sources, or through online research on social media and websites which may not be publicly available;
We typically collect this information through variety of tracking technologies including cookies, flash objects, web beacons, file information and similar technologies (“tracking technologies”);
We may use the data collected through tracking technologies to:
1. Provide custom, personalised content and information, including targeted content and advertising;
2. Identify you across multiple devices;
3. Monitor aggregate metrics such as total number of visitors, traffic, usage and demographic patterns on our Services;
4. Diagnose or fix technology problems and otherwise to plan for and enhance our Services;
We may use one or more third party analytics services to evaluate your use of our Services, by compiling reports on your activities on our website or mobile application and analysing performance metrics. By assessing and using our Services, you consent to the processing of your data by these analytics providers in the manner and for the purposes set out in this Notice.

Legal Basis/Purposes of Collection/Processing and Use of Information.

We use your personal information to improve customer service and respond more efficiently to customer service complaints and requests;
We use the information collected to conduct Due Diligence processes to ensure the reliability and credibility of all parties involved in transactions conducted through our Platform which includes verifying the identity and legitimacy of customers.
The information collected is used to facilitate connection between us and you which involves sharing relevant information between parties to ensure successful completion of transactions.
The information collected is used to determine financial history, risk assessment and creditworthiness.
We may also process your personal data to comply with our legal obligations. These could include financial reporting, tax compliance, or responding to lawful requests from regulatory bodies or government authorities.
In certain emergency situations, we process your personal data where it is necessary to protect your life or the life of another person. This may involve sharing medical or contact information with emergency services or authorities to ensure your safety or the safety of others.
We process personal data when necessary for the performance of a task carried out in the public interest or under the official authority vested in Shekel Mobility. This may involve compliance with public health regulations, governmental orders, or other official directives that require data processing for the greater good.
We may process your personal data based on our legitimate interests or those of a third party, provided that these interests do not override your rights and freedoms. Legitimate interests may include activities such as fraud prevention, service improvement, direct marketing, or other business operations that benefit both Shekel Mobility and our users.
We use the information we collect or receive to operate, improve and protect our Platform, the Services we provide and to develop new Services;
More specifically, we collect and use your information to:
1. Develop, improve, enhance, modify, add to and further develop our platform;
2. Perform KYC and Customer Due Diligence on the information provided;
3. Verify you, your identity, that the data you provide is credible;
4. To provide the services, perform obligations under our agreements and carry out related business functions;
5. Comply with legal obligations and regulations applicable to our Services;
6. Conduct recordkeeping and otherwise manage the business;
7. Protect you, our website, mobile applications and Services from malicious activity and other privacy and security risks;
8. Provide customer support to you, including to help respond to your inquiries related to our Services or our website and mobile application;
9. Remember information so that you will not have to re-enter it during your visit or the next time you visit our website or mobile application;
10. Send you technical notices, updates, security alerts, support and administrative messages;
11. Provide and monitor the effectiveness of our Services;
12. Investigate any misuse of our Services or our website or mobile application, including criminal activity or other unauthorised access to our Services;
13. Deal with disputes and complaints;
14. For any other purpose with your consent;
We may use raw or aggregated and anonymised data for the purposes provided in this Notice. When a new user creates an account with us, we programmatically compare that user’s data against others in our database to help detect potential cases of identity theft.

Protection of your information.

We take commercially reasonable measures to help in the protection of your information from loss, theft, misuse and unauthorised access, disclosures, alteration and destruction.
We also implement policies which are designed to protect the confidentiality and security of your nonpublic personal information;
Unless otherwise specified in this Notice, we limit access to your information to employees that have a business reason to know such information and further implement security practices and procedures designed to protect the confidentiality and security of such information and prohibit unlawful disclosure of such information in accordance with our policies.

Control over your information.

You may update your profile information, such as your business name, email address, nature of the business, and phone number and may change some of your data sharing preferences on your settings page;
Notwithstanding the foregoing, there may be circumstances in which we are unable to accept a request to edit or update your profile or personal information which includes but not limited to;
1. Where such request can be denied under applicable law
2. Where we need to comply with civil, criminal or regulatory inquiry, investigation or subpoena, summons by enforcement agents.
3. Where we need to retain information to exercise or defend legal claims.
Our site uses cookies to keep track of your visits to our website. A cookie is a small file that can be stored by your browser on your computer’s hard drive. We may use cookies to deliver contents specific to your interest and save your password so that you don’t have to re-enter it every time you visit our site. It helps to redefine the service we provide to your preferences. However, if you would prefer not to accept cookies, most browsers will allow you to change your browser settings to notify you when you receive a cookie, which lets you choose whether to accept it or not, disable existing cookies, or to set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Services many not work properly;
You can stop receiving promotional email communications from us, by clicking on the “unsubscribe” link provided in such emails. We make every effort to promptly process all unsubscribe requests. You may not opt out of service related communications such as changes to features of our Services, technical and security notices;
If you have any questions about reviewing, modifying or deleting your information, please contact us directly at [email protected] we may not be able to modify or delete your information in all circumstances.

Third-parties’ access to personal data and purpose of access

We may share or allow third parties to access personal data collected through our services for the purpose of providing and improving the services we offer. This access is strictly controlled and granted only to entities that require the data to perform a legitimate function on our behalf. Below are the types of third parties 8 with whom we may share personal data, and the purposes for which they may access it:
1. These third-party service providers are required to handle your data securely and comply with applicable data protection laws. The purposes for which these third parties may access your personal data include:
  1. Payment Processing: For processing payments, including credit card transactions and other financial services.
  2. Customer Support: For providing customer service, including responding to inquiries, handling complaints, and offering technical support.
  3. Analytics: For collecting and analyzing usage data to help improve our platform and services, such as monitoring user behavior, measuring website performance, and generating reports.
2. KYC (Know Your Customer) and Creditworthiness Verification Providers-To comply with regulatory requirements and assess the creditworthiness of users applying for credit facilities, we may share certain personal data with KYC providers and credit scoring agencies.
3. Advertising and Marketing Partners- We may share aggregated or anonymized data with third-party advertising and marketing partners to provide targeted advertising and promotional content. These partners use your data to:
4. Legal and Compliance Requirements-In certain situations, we may need to share your personal data with third parties in order to comply with legal obligations, protect our business interests, or ensure the safety of our users. This may include:
Whenever we share personal data with third parties, we ensure that they are contractually bound to protect your data and handle it only for the specified purposes. We enter into Data Processing Agreements (DPAs) with third-party providers to ensure compliance with data protection laws, and we put in place appropriate safeguards, including:
1. Ensuring that third parties use industry-standard security measures.
2. Limiting access to personal data only to those individuals who need it to perform their functions.
3. Requiring that third parties comply with our data retention and deletion policies.

International Data Transfer

As part of our global operations and the provision of our services, we may transfer your personal data to countries outside of Nigeria. These transfers are conducted in strict compliance with the Nigeria Data Protection Act (NDPA) 2023, and other relevant regulations designed to ensure that your personal data remains secure, private, and protected during international transfers.
1. We may transfer your personal data to other countries or jurisdictions if required to provide you with our services, including but not limited to:
  1. Processing and Storing Data: We may store and process your personal data on servers located outside Nigeria.
  2. Third-Party Service Providers: We may engage third-party service providers, partners, or affiliates located in different countries for purposes such as payment processing, marketing, IT support, or analytics.
  3. Global Marketplace: As we offer a global marketplace connecting automobile dealers, agents, and sellers across different regions, some of your data may be shared or accessed by parties outside Nigeria.
2. Personal data can only be transferred to another country if the recipient country ensures an adequate level of protection for the data, or if specific legal conditions are met. We comply with these legal conditions and ensure that:
  1. The country receiving the data must offer data protection laws that are substantially similar to the NDPA 2023 and meet the standards set by the Nigeria Data Protection Commission (NDPC). This can include countries with established data protection laws or membership in international data protection conventions.
  2. In cases where the recipient country does not have an adequate level of protection, we may implement Standard Contractual Clauses or other legal mechanisms to ensure that your data is protected according to the same standards as under the NDPA 2023.
  3. In some cases, we may use internal policies that govern how data is handled across borders within a corporate group, to ensure compliance with data protection laws.
  4. In situations where no adequacy decision, SCCs, or BCRs apply, we may seek your explicit consent to transfer your personal data to another country. You will have the option to withdraw consent at any time.
Measures We Take to Protect Your Data During International Transfers
1. We take the protection of your personal data seriously and implement appropriate technical and organizational measures to safeguard your data during international transfers. These measures include:
  1. Encryption: All personal data is encrypted during transmission and storage using industry-standard encryption technologies.
  2. Access Controls: We restrict access to your data to authorized personnel only, and implement strong authentication methods to ensure that only authorized individuals can access your data.
  3. Third-Party Contracts: We require that our third-party service providers and partners sign data protection agreements that include specific provisions ensuring that they handle your data in compliance with the NDPA and applicable international data protection laws.
  4. Data Minimization: We only share the minimum necessary data for the purposes of providing our services, and limit the scope of data that is transferred internationally.
  5. Regular Audits: We conduct regular audits of our data protection and security practices to ensure compliance with data protection laws and our internal policies.
International Data Transfer Countries and Region
1. We may transfer your personal data to the following countries or regions, where our third-party service providers or business partners are located, and where our data storage facilities are based:
  1. European Economic Area (EEA): We may transfer personal data to countries within the EEA, which adhere to the General Data Protection Regulation (GDPR) standards.
  2. United States: In some cases, personal data may be transferred to the United States for processing by our third-party service providers. We ensure that these transfers are made in compliance with applicable privacy laws such as the EU-U.S. Data Privacy Framework, or through the use of Standard Contractual Clauses (SCCs).
  3. Other Countries: We may also transfer personal data to other countries as needed to provide our services. Where such transfers occur, we ensure that adequate data protection measures are in place.
Your Rights Regarding International Data Transfers
1. You have the right to be informed about the transfer of your personal data and to ensure that your data is processed in accordance with the standards of protection . If you wish to know more about the specific countries to which your data may be transferred, or if you would like to exercise any of your rights, including your right to withdraw consent, please contact us using the details provided in the "Contact Us" section below.
2. You also have the right to:
  1. Request Copies of Transfer Safeguards: If your personal data is being transferred to another country, you can request a copy of the safeguards we have in place to protect your data during the transfer.
  2. Withdraw Consent: If your personal data is being transferred based on your consent, you have the right to withdraw your consent at any time, and we will cease such transfers.
  3. Object to Transfers: You may have the right to object to the transfer of your personal data, depending on the specific circumstances.

Data Retention and Protection.

Your information collected through our Services may be stored and processed in the country in which we maintain facilities or you utilise our Services;
Please note that we may transfer information, including personal information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction and you acknowledge such transfer or information to the any other country in which we maintain facilities and the use and disclosure of information about you as described in this Notice;
We retain your information to fulfil our legal or regulatory obligations and for our business purposes. We may retain your information for longer periods than required by law if it is in our legitimate business interests and it is not prohibited by law;
If you stop using our Services and close your account with us, we reserve our ability to retain and access the data as provided in this Notice. We will continue to use and disclose such data in accordance with this Notice;
All data or information are stored in encrypted formats in our database.

Surveys

We may request that you complete a survey on the Services we provide to you, in order for us to better understand your perception of our Services and to further improve on them. If you choose to participate in any of such surveys, we may collect demographic information about you, such as your age, marital status, ethnicity, profession or other sensitive information. We may also collect information about the way you utilize our Services and your experiences while using it. By participating in such a survey you consent to our collection and use of the information you provide in accordance with this Notice.

Links to third party website

Our Services, website or Platform, may contain links and integration to third party websites or applications of our partners or contractors. While we take appropriate care when publishing links to any third party service, if you follow a link to any website, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use and share information. We are not responsible for the privacy practices or the content on the websites or mobile applications of third party sites.

Mobile Application Notice

When using our mobile application, we may collect personal data through your use of the app, including information such as your location, device information, and usage data. This data is used to improve our app and provide a better user experience.
Our mobile application may use cookies, beacons, and other tracking technologies to analyze usage patterns and enhance performance. You can manage your cookie preferences and disable certain tracking features through your device’s settings.
You have the right to request access to, correction of, or deletion of your personal data collected through the app. You can submit these requests by contacting us at [email protected]

Right to Lodge a Complaint with Supervisory Authority

We are committed to ensuring that your personal data is handled securely. If you believe that your data protection rights have been violated or if you are dissatisfied with how your personal data has been processed, you have the right to lodge a complaint with the relevant supervisory authority.
You may lodge a complaint if you believe that:
1. Your personal data has been processed without your consent, or in a manner inconsistent with the purposes for which it was collected.
2. Your rights, such as access, correction, or deletion, have not been adequately addressed.
3. There has been a data security breach affecting your personal data.
4. You are dissatisfied with our response to a request regarding your personal data.
Before escalating to the supervisory authority, we encourage you to first contact us with any concerns or questions regarding the processing of your personal data. Our team will make every effort to address your concerns promptly.
To get in touch with us, please use the following contact methods:
1. Email: [email protected]
2. Phone: +234 909 233 8000
3. Postal Address: 14, Oroleye Crescent Opebi Lagos Nigeria.
We will respond to your inquiry or complaint within 3 (three) working days
If you are not satisfied with our response, or if you believe your data protection rights have been violated, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC), the data protection authority responsible for enforcing the NDPA. Below is the guide to lodge to the supervisory agency;
1. Prepare Your Complaint: Include your personal information (name, contact details), a description of the issue, and any relevant supporting documentation.
2. Submit the Complaint: submit to email, postal address and phone number
Investigation and Outcome: NDPA will investigate your complaint and, if necessary, will take enforcement actions, including penalties or corrective measures against us. You will be informed of the outcome.
We are committed to working with NDPC to resolve any issues that may arise and to improve our data protection practices

Governing Law

This Notice is made pursuant to the Nigeria Data Protection Act 2023 and Nigeria Data Protection Regulations as well as all other laws, regulations or international conventions which Applatch in providing its Services and within the country of its operations is subject to. Where any provision of this Notice is deemed inconsistent with such law, regulation or convention, such provision shall be subject to the overriding law, regulation or convention.

How to contact us

If you have any questions about how we process your personal data, or if you wish to exercise your rights (on the website and mobile app), you can contact our Data Protection Officer through our designated privacy email address [email protected]