PRIVACY POLICY

Table of Contents

Privacy notice and consent request .......................................................................................3

What information do we collect about you?. .........................................................................3

Information about connected individuals. .............................................................................5

Why do we need to collect and use your data?...................................................................... 5

How will we use the information about you?. ........................................................................5

Who might we share your information with?. ........................................................................5

Security. 6How long do we keep hold of your information?. ...................................................6

How can I access the information you hold about me?. ..........................................................6

Marketing ................................................................................................................................ 7

Cookies .....................................................................................................................................7

Other websites .........................................................................................................................8

What can you do if you arevunhappy with how your data is processed? ..................................8

Changes to our Privacy Policy ....................................................................................................8

How to contact us .....................................................................................................................9

Consent ......................................................................................................................................9

Sensitive personal data ...............................................................................................................9

Marketing ...................................................................................................................................9

*PLEASE READ THIS POLICY CAREFULLY BEFORE REGISTERING FOR AN ACCOUNTWITH US*

Privacy notice and consent request

SyndeoSolutions International Limited (referred to throughout this document as we/us/our/Gitr)is a company registered under Nigerian Laws, while Gistr is the Branded Trademark Name (BTN) owned by the company.This privacy notice explains how we use any personal information we collect about you.

SyndeoSolutions International Limited iscommitted to protecting and respecting your data and your privacy. We recognizethat your data is your property and that you have provided it to us forspecific purposes.

Unless otherwise required by applicable laws or best practices, or to perform ourcontract with you, we will only obtain and process your data in the way we tellyou or in the way you ask us to, and we will give it back to you at any time.

Thispolicy applies to our contract with you. You are therefore advised to read itcarefully. Terms used within it shall have the meaning(s) given in the Nigeria Data Protection Act 2023 (NDPA)and Nigeria Data Protection Regulation2019 (NDPR).

By visiting our website located at www.gitr.co (ourWebsite), or by registering for an account with us, via the Gistr App, you are deemed to have accepted and given your consent to the practices described in this policy.

GENERAL TERMS AND CONDITIONS

Access to and use of the Service is subject to these general terms and conditions (hereinafter referred to as the "General Terms and Conditions”.) The 'General Terms and Conditions section is written by us with the motive of providing maximum possible clarity for points of understanding between the website's firm and the user of the website. However, we in no way assure that this section would consist of answers and explanations for all questions regarding Terms and Conditions. In case you don't find an answer to a question or demand to have more clarity on a particular point, you shall email us.

The website and application are suitable only for individuals who are at least 16 years old.

Any order of Product offered for sale by GISTR and allowing access to the Service requires consultation and explicit prior acceptance of these General Terms and Conditions, by checking the "I agree to General Terms and Conditions " checkbox. These General Terms and Conditions are permanently available on the Portal and will prevail, as appropriate, over any other document.

GISTR reserves the right, at any time, to update these General Terms and Conditions. However, the conditions applicable to the User are those in force on the day the order is placed.

Access to the Portal and/or the Application occurs under normal Internet connection conditions. No additional connection costs will be charged to the User.

What information do we collect about you?

We collect information about you when you engage with us. This information may relate to personal information. It may also include special categories of personal data, if necessary for providing our services.

We may also collect information when you voluntarily complete client surveys or provide feedback to us.

Information relating to the usage of our website is collected using cookies. These are text files placed on your phone device to collect standard internet log information and visitor behavior information. We will use the information collected from the website to personalize your repeat visits to the site and App.

We may collect all or some of the following categories of data from you (this list is not exhaustive):

Type of Information

What do we use the information for?

Account number

Address (current and previous)

Name

Date of Birth (DoB)

Account/network log in details

To amend details

To verify identity

To carry out Anti-Money Laundering checks

To identify you on our system

To send correspondence

To process refunds










To carry out Credit Checks

To prevent, detect and investigate fraudand other criminal transactions

To make payments

To collect outstanding payments

To send out Marketing (subject to preferences)

Credit Card details 

Debit Cards details 

Bank account details

To take payment

To make refunds

To verify payments

To prevent, detect and investigate fraud and other criminal transactions

Email address

To identify a customer

To send correspondence

To deliver goods

To contact you about your account and payments

To send out Marketing (subject topreferences)

To prevent, detect and investigate fraudand other criminal transactions

To identify you on social media and Google

Gender

To verify identity

To carry out Anti-Money Laundering checks

To identify you on our system

To prevent, detect and investigate fraud and other criminal transactions

Marketing Preferences

Data usage

To record your marketing preferences

To record your usage data

Social Media use and information about your phone/App/Computer usage

To help improve your online experience

To identify preferences and trends

To send out Marketing (subject to preferences)

Telephone Numbers

Contact details

To amend details

To verify identity

To carry out Anti-Money Laundering checks

To identify you on our system

To send correspondence

To process refunds

To carry out Credit Checks

To prevent, detect and investigate fraud and other criminal transactions

To make payments

To collect outstanding payments

To send out Marketing (subject to preferences)

App Tracking

GISTR may collect and store information about your app interactions, including pages visited, features used, and device details.

This data helps us improve app functionality, enhance user experience, and provide personalized content.

By using GISTR, you consent to this data collection.

You can disable tracking in the app or device settings, but it may impact certain features

User's Contact list

When using GISTR, with your consent, we may access and store information from your phonebook or contact list.

This enables us to display your contacts within the app, making it easier for you to connect with them.

You can initiate calls to your contacts directly from the app, utilizing the contact information stored on your device.

We prioritize the privacy and security of your information and do not share it with third parties without your explicit consent.

Granting access to your phonebook is optional, and if you choose not to provide this permission, some app features may be limited.

Thank you for using our app and trusting us with your privacy.

Information about connected individuals

We may need to gather personal information about your close family members and dependents to provide our service to you effectively. In such cases, it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We will provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them. Provided that we shall not be liable for any notification gap between you and any of your close family members and dependents.

Why do we need to collect and use your data?

The primary legal basis that we intend to use for the processing of your data is for the performance of our contractual obligations with you. The information we collect about you is essential for us to carry out the services you require from us effectively. Without collecting your data we’d also be unable to fulfil our legal and regulatory obligations.

Where special category data is required, we’ll obtain your explicit consent to collect and process this information.

How will we use the information about you?

We collect information about you toprovide you with the services for which you engage us, in the following andsimilar circumstances (itemized below illustrate data usage circumstances but arenot exhaustive);·       

- Manage and improve the Website and App.·       
- Administer and operate youraccount with us.·       
- Personalize our services toyou.·       
- Update and notify you about important changes to the Website and our services.·       
- Understand your shopping behaviorto develop and improve our products and services.·       
- Manage promotions,competitions, customer surveys, and questionnaires.·       
- Check and verify your identity, and prevent or detect crime·       
- Enable us to determine and customize our individual customer's styles of App usage.

Who might we share your information with?

If you agree, we may email you about other products or services that we think may be of interest to you.

If you agree, we will pass on your personal information to our group of companies so that they may offer you their products and services.

We won’t share your information for marketing purposes with companies outside our group of companies / other companies.

To deliver our services to you effectively we may send your details to third parties such as those that we engage for professional legal services.

Where third parties are involved in processing your data, we will have a contract in place with them to ensure that the nature and purpose of the processing are clear, that they are subject to a duty of confidence in processing your data, and that they’ll only act following our written instructions.

Where it’s necessary for your data to be forwarded to a third party we’ll use appropriate security measures to protect your data in transit.

To fulfill our obligations in respect of the prevention of money laundering and other financial crimes, we may send your details to third-party authorities/agencies for identity verification purposes.

Security

We have put in place appropriate technical and organizational measures to help protect your personal information from unauthorized access, use, disclosure, alteration, or destruction consistent with applicable Data Protection Laws.

Each member of our staff has unique log-in details and authentication software requires these to access the systems. Our staff has access to personal data only to perform their legitimate functions.  

We have put in place procedures to deal with any suspected personal data breach and will notify you and any authorized regulator of a breach where we are legally required to do so.

How long do we keep hold of your information?

During the course of our relationship with you, we will retain personal data which is necessary to provide services to you. We will take all reasonable steps to keep your data up to date throughout our relationship.

We are also subject to regulatory requirements to retain your data for specified minimum periods, during which we have a legal obligation to retain your records.

We reserve the right to retain data for longer where we believe it's in our legitimate interests to do so. In any case, we will not keep your data for longer than 2 years after our relationship with you has ended.

You have the right to request deletion of your data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.

How can I access the information you hold about me?

You have the right to request a copy ofthe information that we hold about you. If you would like a copy of some or allof your personal information please email or write to us using the contactdetails noted below.

When your data is processed by automatedmeans, you have the right to ask us to move your data to another organizationfor their use.

We must ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.

Marketing

We would like to send you information about our products and services and those of other companies in our group which may be of interest to you. You are deemed to have agreed to receive marketing information, but you may opt-out at a later date.

We may contact and communicate with you we would embark on using several methods including; emails, phone calls, SMS, App messages, in-App push notifications, and any other appropriate channel.

You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us by email [support@gistr.co] or post, or by accessing www.gistr.co

Cookies

We use cookies to track visitor use of the website and to compile statistical reports on the website and activity, through Google Firebase Analytics.

For further information visit http://www.allaboutcookies.org/

You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Our website will use the cookies listed in the table below (alpha-numeric text files placed on your computer) to:

• Distinguish you from other users;
• Optimize your browsing experience;
• Make necessary improvements to our website;
• Recognise and count the number of visitors to our website and see how they move around the Website during use;
• Recognise you when you return to our website;
• Record your visit to our website, including any links you may follow.  

The following cookies are set to our website for the corresponding purposes:

COOKIE

PURPOSE

Targeting cookies

Collect info about your browsing habits to make advertising relevant to you and your interests

Functionality cookies

– sounds, display, notification- Remember the choices you make to improve your experience

Performance cookies

Collect anonymous information on the pages visited.

Necessary cookies

These cookies are essential to enable you to move around the Website and use its features, such as accessing secure areas of the Website. Without these cookies services you have asked for, like shopping baskets or billing, cannot be provided.

ASP.Net_SessionId

Enhances user experience by remembering session history.

ASPXAUTH

Records users' authentication session

_culture

Assists in recognizing the user’s nationality and language preferences, login, token, username recognition, and encoding.

Request VerificationToken

Part of a mechanism to protect against cross-site scripting attacks

ARRAffinity

Enhances user browsing experience – part of load balancing setup

cookie-policy

Tracks presentation of the cookie information advice

Our website additionally uses Google Firebase Analytics, a web analytics service provided by Google, LLC (Google). Google Analytics uses analytical, performance, or targeting cookies to help analyze how you use the Website and compile reports on your activity for us.

Any information generated by the cookie about your use of the Website (including your IP address) will be transmitted to, and stored by, Google on servers in the United States. Google will use this information to evaluate your use of the Website, compile reports on your activity for us, and provide other services relating to website activity and internet usage.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

By using the Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Except for essential cookies, all cookies will expire after your session.

Other websites

Our website may contain links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their privacy policies.

What can you do if you are unhappy with how your data is processed?

You also have a right to complain to the supervisory authority for data protection;

The Nigeria Data Protection Commission (NDPC)

Corporate Headquarters
No. 5 Donau Crescent,
Off Amazon Street,
Maitama,
Abuja, FCT, Nigeria

Changes to our privacy policy

We keep our privacy policy under regular review and we will place any updates on this web page (and/or) inform you of any changes when they occur.

This privacy policy was last updated on July 2023 and is subject to change.

How to contact us

Please contact us if you have any questions about our privacy policy or information, we hold about you: By email at support@gistr.co

Consent

We have provided you with a copy of our Privacy Notice which provides information about the nature of our data processing activities and includes details of our retention and deletion policies as well as your rights of access to the personal information that we hold on you.

Sensitive personal data

As explained in our Privacy Notice certain categories of personal data are sensitive by nature. These categories include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and data concerning health.

It is unlikely that through the services we would need to obtain sensitive data but, in the case, where we need to process special category (sensitive) data as described above we require your consent.

Please note that you may withdraw this consent at any time by notifying us at our main business address.

Marketing

From time to time, we may wish to contact you to offer additional products or services which may be of interest to you. To do this, we require your consent by agreeing to one or all of the options:

I/we consent to be contacted for marketing purposes by:

Email  Telephone  Text  message 

Please note that you may withdraw this consent at any time by notifying us at our main business address.