B. Information We Collect
C. Our Use and Disclosure of Information
D. Information Security
E. Accessing and Changing Your Information
F. Money Laundering Prevention
G. European Data Conscent
G. Contacting Us
Notification of Changes
Pages on the OnlineNaira website may include links to third party websites. OnlineNaira is not responsible for their operations, including but not limited to their information practices. Their privacy statements govern those sites. Users submitting information to or through these third party websites should review the privacy statement of these sites before providing them with personally identifiable information.
To open a OnlineNaira account, you must provide your name, company name (if any), address, phone number, home page (if any), and e-mail address. In order to make payments through OnlineNaira, you must provide credit card, debit card or bank account information. We may also ask you to choose different security questions to answer. This required information may be necessary for us to process transactions, issue a new password if you forget or lose your password, protect you against credit card fraud and checking account fraud, and to contact you should the need arise in administering your account.
In order to comply with the Bank Secrecy Act, we will also require your SSN or TIN if you send or receive certain high-value transactions or high overall payment volumes through OnlineNaira. If you choose to register or apply for certain optional features or products offered through the OnlineNaira websites, you will be required to provide additional information to establish that you qualify for such features or products.
When you use OnlineNaira to send money to someone else or request money from someone else, we ask you to provide information related to each transaction, including the amount of the transaction and the e-mail address of the third party. We retain this information for each of your transactions through OnlineNaira. We also collect the Internet address (IP address) of the computer or device you use to access your OnlineNaira account, in order to help detect possible instances of unauthorized transactions.
Information About You From Third Parties
In order to protect all our customers against potential fraud, we verify with third parties the information you provide. In the course of such verification, we receive personally identifiable information about you from such services. In particular, if you register a credit card or debit card with OnlineNaira, we may use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to OnlineNaira, and that the card has not been reported as lost or stolen.
If you send or receive high overall payment volumes through OnlineNaira, in some circumstances we may conduct a background check on your business by obtaining information about you and your business from a credit bureau or a business information service. If you incur a debt to OnlineNaira, we will generally conduct a credit check on you by obtaining additional information about you from a credit bureau, to the extent permitted by law. OnlineNaira, at its sole discretion, also reserves the right periodically to retrieve and review a business or consumer credit report for any account, and reserves the right to close an account based on information obtained during this credit review process.
If we cannot verify the information that you provide, or if you request a withdrawal by check to an address other than your verified credit card billing address, we may ask you to send us additional information (such as your drivers' license, credit card statement, and/or a recent utility bill or other information linking you to the applicable address), or to answer additional questions online to help verify your information.
Website Traffic Information
Because of the way that Internet communication standards work, when you arrive at or leave the OnlineNaira website, we automatically receive the Internet address of the site that you came from or are going to. We also collect information on which pages of our website you visit while you are on the OnlineNaira site, the type of browser you use and the times you access our website. We may use this information only to try to understand our customers' preferences better and to manage the load on our servers, so as to improve our service and your experience with OnlineNaira. We do not track the websites that you visit before or after you leave the OnlineNaira site.
Our Use of "Cookies"
"Cookies" are small files of data that reside on your computer and allow us to recognize you as a OnlineNaira customer if you return to the OnlineNaira site using the same computer and browser. We send a "session cookie" to your computer if and when you log in to your account by entering your e-mail address and password. These cookies allow us to recognize you if you visit multiple pages in our site during the same session, so that you don't need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.
Customer Service Correspondence
Questionnaires, Surveys and Profile Data
From time to time, we may offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users' interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.
Non-member Recipients and Requests
When a member either sends a payment to, or requests a payment from, an individual who is not a registered member of OnlineNaira, we will retain the information that the member submits to us, including, for example, the other party's email address and/or name, for the benefit of the member who is attempting to contact the non-member, so that the member can see a complete record of his or her transactions, including uncompleted transactions. Although this information is stored indefinitely, we will not market to the non-member in any way at any time. Additionally, these non-members have the same rights to access and correct information about themselves (assuming that their email addresses were correct enough to reach them) as anyone else who uses OnlineNaira.
We collect, store and process your personal information on servers located in the United States. We use the information we collect about you in order to provide our services and process your transactions, to provide customer service, to determine your eligibility to receive offers for special features or products, and to improve our products and services. At your option (as indicated in your user settings), we use the information you provide to access specific third party services on your behalf and perform the actions that you request us to perform.
We give access to individually identifiable information about our users only to those employees who require it to fulfill customer service requests.
Disclosure to Other Customers
If you are a registered user, your name, e-mail address, member status, and other information may be displayed to other OnlineNaira customers whom you have paid or who are attempting to pay you through OnlineNaira. Your credit card number, bank account and other financial information will never be revealed to anyone whom you have paid or who has paid you through OnlineNaira, except if we are required to do so pursuant to a subpoena or other legal process.
If you are buying goods or services and paying through OnlineNaira, the seller of the goods or services may request that you provide a mailing address that OnlineNaira has confirmed as matching the billing address in the system. You do not have to provide this information. If you do not provide the information, however, the seller may choose not to accept your payment and not to complete the transaction.
Disclosure to Third Parties Other Than Customers
OnlineNaira will not sell or rent any of your personally identifiable information to third parties. OnlineNaira will not share any of your personally identifiable information with third parties except in the limited circumstances described below, or with your express permission (and to other customers as described above). These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared. We share information with companies that help us process the transactions you request and protect our customers' transactions from fraud, such as sharing your credit card number with a service that screens for lost and stolen card numbers. See "Information About You From Third Parties" in Section B above. Additionally, if you go into a negative balance and owe us money, we may share information with processing companies including collection agencies.
We disclose the information we collect, as described in Section B above, to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements. These companies may be subject to confidentiality agreements with us and other legal restrictions that prohibit using the information except to market the specified OnlineNaira-related products or services, unless you have affirmatively agreed or given your prior permission for other uses.
We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.
If a user signs up for a co-branded version of OnlineNaira through links on our co-branded partner's website, OnlineNaira will share with the co-branded partner that user's name, e-mail address and physical address in order to provide enhanced integration between OnlineNaira's services and the services of our co-branded partner. If a user does not want his or her information shared with OnlineNaira's co-branded partner, he or she should not use this aspect of the site.
We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
We share aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in British Columbia. However, this aggregated information is not tied to personally identifiable information.
We share your information with our parent, subsidiaries and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.
Our Contacts with Customers
We communicate with users on a regular basis via e-mail to provide requested services, and we also communicate by phone to resolve customer complaints or investigate suspicious transactions. We use your e-mail address to confirm your opening of a OnlineNaira account, to send you notice of payments that you send or receive through OnlineNaira (including referral payments described below), to send information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional.
We also may use your e-mail address to send you other types of communications that you can control, including tips, newsletters, customer surveys and notice of special third-party promotions. You can choose whether to receive some, all or none of these communications when you complete the registration process, or at any time thereafter, by logging in to your account on the OnlineNaira website and changing your user preferences. You can also change your choices at any time through the same procedure.
In connection with independent audits of our financial statements and operations, auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.
Internet Address Information
We use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use.
Your Use of Information and Our Services
In order to facilitate the transactions between OnlineNaira members, our service allows you limited access other users' contact information. As a seller you may have access to the User ID, email address and other contact information of the purchaser, and as a purchaser you may have access to the User ID, email address and other contact information of the seller.
In all cases, you must provide users with the opportunity to remove themselves from your database and review any information you have collected about them. In addition, under no circumstances, except as defined in this Section, can you disclose personally identifiable information about another OnlineNaira user to any third party without our consent and the consent of such other user after adequate disclosure. Note that law enforcement personnel and other rights holders are given different rights with respect to information they access.
OnlineNaira does not tolerate unsolicited commercial e-mail or "spam". Therefore, without limiting the foregoing, you may not add a OnlineNaira user to your mail list (e-mail or physical mail) without their express consent after adequate disclosure, even if said user has previously made a purchase from you. Our anti-spam policy is strictly enforced.
We handles your customer information with high standards of information security. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.
The security of your account also relies on your protection of your password. You should not share your password with anyone. We representatives will never ask you for your password, so any e-mail or other communication requesting your password should be treated as unauthorized and suspicious. If you do share your password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account at OnlineNaira and changing your user settings, and also contact us right away as described in Section F below.
You can review the personal information you provided us and make any desired changes to such information, or to the settings for your account, at any time by logging in to your account on the OnlineNaira website and changing your user preferences. You can also close your account through the OnlineNaira website. If you close your account, we will mark your account in our database as "CLOSED" but will keep your account information in our database. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required by law.
What am I asked to do?
You may find that you are asked to confirm your identity and other personal details. OnlineNaira has established special verification systems involving your Bank Account, Drivers Licence or International Passport to prove your identity or Bank Verification Number if you are Nigerian. To safeguard the integrity of our payment system, your OnlineNaira account may also be subject to periodic transaction limits depending on your user status.
You could be asked to confirm your identity whether you are applying to be a new customer or have been a customer for some time. While our identity verification systems are designed to minimise any inconvenience for you, the verification process is usually instant, but may take several days to complete.
Crime and terrorism need cash. Criminals turn the "dirty" cash made from drug trafficking, smuggling, and robbery into clean money by using false identities or taking the names of innocent people - like you. Making sure that people are who they say they are is essential in the fight against crime and terrorism. This does not mean in any way that suspicion is falling on you. Any information about your identity is held confidentially and will help stop your identity being used falsely.
Who is involved?
Government and all organisations involved in financial services. All are united in their determination to stop the spread of financial crime as part of the international effort to crack down on financial crime - protecting us all against crime and terrorism.
Your co-operation is vital to the successful fight against crime and terrorism.
What the Law Requires:
If your agreement with OnlineNaira includes the use of an OnlineNaira product, you must ensure that certain disclosures are given to, and consents obtained from, end users in the European Economic Area. If you fail to comply with this policy, we may limit or suspend your use of the OnlineNaira product and/or terminate your agreement.
Properties under your control
For OnlineNaira products used on any site, app or other property that is under your control, or that of your affiliate or your client, the following duties apply for end users in the European Economic Area. You must obtain end users’ legally valid consent to:
- the collection, sharing, and use of personal data for personalization of ads or other services.
When seeking consent you must:
- retain records of consent given by end users; and
- provide end users with clear instructions for revocation of consent.
You must clearly identify each party that may collect, receive, or use end users’ personal data as a consequence of your use of a OnlineNaira product. You must also provide end users with prominent and easily accessible information about that party’s use of end users’ personal data.
Properties under a third party's control
If personal data of end users of a third-party property is shared with OnlineNaira due to your use of, or integration with, an OnlineNaira product, then you must use commercially reasonable efforts to ensure the operator of the third-party property complies with the above duties. A third-party property is a site, app or other property that is not under your, your affiliate's or your client's control and whose operator is not already using an OnlineNaira product that incorporates this policy.
If you have any questions about this privacy statement please review our FAQ page or Contact Us directly.