PRIVACY AND COOKIE NOTICE

Contents

1. About this Notice

2. Who We Are

3. The Data We Collect About You?

4. Cookies and other Identifiers

5. How We Use Your Personal Data

6. Legal basis for the processing of Personal Data

7. How We Share Your Personal Data

8. International Transfers

9. Data Retention

10. Data Security

11. Your Legal Rights

12. Data Controllers & Contact

13. Related Practices and Information

1. About this Notice

This Privacy Notice provides information on how HelloPay collects and processes your personal data when you visit our website or mobile applications. It sets out what we do with your personal data and how we keep it secure and explains the rights that you have in relation to your personal data. .

2. Who We Are

HelloPay is licensed by the Central Bank of Nigeria as a Payment Solution Service Provider (PSSP) in Nigeria to provide payment processing services to customers. This website and/or mobile app is operated by a member of the Jumia group of companies, the ultimate holding company of which is Jumia Technologies AG.

3. The Data We Collect About You?

Personal data means any information that can be used to identify directly or indirectly a specific individual. We collect your personal data in order to provide tailored products and services and in order to analyze and continually improve our products and services. We may collect, use, store and transfer different kinds of personal data for marketing and personal data optimization purposes. HelloPay also uses Google Digital Marketing to propose targeted offers for certain products and services to our customers.

You provide us with your personal data when you register your personal details on our website and mobile platforms and transact with the same.

The personal data we collect includes:

• A. Information you provide to us: We receive and store the information you provide to us, including your identity data, contact data, biometric data, delivery address, and financial data. These types of personal data may include:
  1. contact details (such as your name, postal addresses, phone numbers, and email addresses),
  2. demographic information (such as your date of birth, age or age range, and gender),
  3. online registration information (such as your password and other authentication information),
  4. payment information (such as your credit card information and billing address),
  5. information provided as part of online questionnaires (such as responses to any customer satisfaction surveys or market research),
  6. competition entries/submissions, and
  7. in certain cases, your marketing preferences.
• B. Information we automatically collect/generate or obtain from third parties: We automatically collect and store certain types of information regarding your use of HelloPay’s website or mobile application, including information about your searches, views, downloads, and purchases. In addition, we may receive information about you from third parties, including our carriers, payment service providers, merchants/brands, and advertising service providers. These types of personal data may relate to your device (such as your PC, tablet, or other mobile device), your use of our websites and apps (as well as certain third-party websites with whom we have partnered), and/or your personal preferences, interests, or geographic location. Examples of these types of information include:
  1. name and age (or predicted age range),
  2. information about your device, operating system, browser and IP address,
  3. unique identifiers associated with your device,
  4. details of web pages that you have visited,
  5. which products you have looked at online (including information about products you have searched for or viewed, purchased or added to an online shopping basket),
  6. how long you spend on certain areas of a website or app together with the date and time of your visit/usage,
  7. personal data contained within user-generated content (such as blogs and social media postings),
  8. social media username or ID, and
  9. social media profile photo and other social media profile information (such as the number of followers).

We strive to provide you with choices regarding the Personal Data that you provide to us. Where required by law, if you wish to have your Personal Data used by HelloPay to provide you with a personalized experience/targeted advertising & content, you can indicate so through the relevant tick-box(es) located on the registration form or by answering the question(s) presented by HelloPay’s representatives. If you decide that you no longer wish to benefit from this personalization, you can opt-out or adjust your preferences at any time by closing your account or by sending an email to [email protected]. You can close your account by clicking on this link and following the instructions. Once your account is closed, all products and services that you access through your account will no longer be available.

4. Cookies and other Identifiers

A cookie is a small file of letters and numbers that we put on your computer, mobile phone or tablet if you agree. Cookies allow us to distinguish you from other users of our website and mobile applications, which helps us to provide you with an enhanced browsing experience. For more information about cookies and how we use them, please read our Cookie Notice:

5. How We Use Your Personal Data

We use your personal data to operate, provide, develop, and improve the products and services that we offer, including the following:

• A. Registering you as a new customer.
• B. Processing your payment made on or through our platform.
• C. Processing and delivering your orders.
• D. Managing your relationship with us.
• E. Enabling you to participate in promotions, competitions, and surveys.
• F. Improving our website, applications, products, and services.
• G. Recommending/advertising products or services which may be of interest to you.
• H. Enabling you to access certain products and services offered by our partners and vendors.
• I. Complying with our legal obligations, including verifying your identity where necessary.
• J. Detecting fraud.

6. Legal basis for the processing of Personal Data

We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and used your personal data. In almost every case, the legal basis will be one of the following:

• A. Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you.
• B. Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services, and operate effectively, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights.
• C. Performance of a contract with you: This would also apply where we need to take steps prior to entering into a contract with you. For example, where you have purchased a product from us and we need to use your contact details and payment information in order to process your order and send the product to you.
• D. Compliance with law: Where we are subject to a legal obligation and need to use your personal data in order to comply with that obligation.

7. How We Share Your Personal Data

A. We may need to share your personal data with third parties for the following purposes:

• i. Payment processing: In order to provide effective and efficient payment processing services to you, we may be required to provide your personal data to third parties, including but not limited to relevant card schemes, acquirers, and regulatory bodies.
• ii. Sale of products and services: Where applicable, in order to deliver products and services purchased on our marketplace from third parties, we may be required to provide your personal data to such third parties.
• iii. Working with third-party service providers: We engage third parties to perform certain functions on our behalf. Examples include fulfilling orders for products or services, delivering packages, analyzing data, providing marketing assistance, processing payments, transmitting content, assessing and managing credit risk, and providing customer service.
• iv. Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, customer information may be transferred together with other business assets.
• v. Detecting fraud and abuse: We release account and other personal data to other companies and organizations for fraud protection and credit risk reduction, and to comply with applicable law.

B. When we share your personal data with third parties, we:

• i. require them to agree to use your data in accordance with the terms of this Privacy Notice, our Privacy Policy and in accordance with applicable law;
• ii. only permit them to process your personal data for specified purposes and in accordance with our instructions. We do not allow our third-party service providers to use your personal data for their own purposes.

8. International Transfers

We may transfer your personal data to locations in another country if this is permissible pursuant to applicable laws in your location. There are inherent risks in such transfers.

In the event of international transfers of your personal data, we shall put in place measures necessary to protect your data and ensure the same level of protection available in the country of data origin. We shall continue to respect your legal rights pursuant to the terms of this Privacy Notice and applicable laws in your location.

9. Data Retention

We will take every reasonable step to ensure that your personal data is processed for the minimum period necessary for the purposes set out in this Privacy Notice. Your Personal Data may be retained in a form that allows for identification only for as long as:

• A. We maintain an ongoing relationship with you. This will enable us to improve your experience with us and to ensure that you receive communications from us.
• B. Your Personal Data is necessary in connection with the purposes set out in this Privacy Notice and we have a valid legal basis.
• C. The duration of: (i) any applicable limitation period (i.e., any period during which a person could bring a legal claim against us).

We will actively review the personal data we hold and delete it securely, or in some cases anonymize it, when there is no longer a legal, business, or consumer need for it to be retained.

10. Data Security

We have put in place security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed.

In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

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

11. Your Legal Rights

A. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

B. Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

• access, correct, or erase your personal data,
• object to or restrict processing of your personal data,
• ask that we transfer your personal data to a third party, and
• unsubscribe from our emails and newsletters.

C. In the event that you have provided us with your personal data and you wish to permanently delete your data from our website and other applications, you can choose the option of having such personal data deleted. You can apply for such data deletion by clicking on this link and following the instructions. Once your personal data is permanently deleted, such data deletion is done subject to applicable laws and regulations.

D. We can refuse to accede to your request where it is unreasonable or where you have failed to provide additional information necessary to confirm your identity.

12. Data Controllers & Contact

If you have any questions or concerns about HelloPay’s Privacy Notice or you are looking for more information on how we process your personal data, or wish to exercise your legal rights in respect of your personal data, please contact the Data Privacy Officer by email at [email protected].

We will investigate any complaint about the way we manage Personal Data and ensure that we respond to all substantiated complaints within prescribed timelines.

13. Related Practices and Information

Cookie Notice

HELLOPAY COOKIE NOTICE

1. About this Notice

This Cookie Notice provides information on how HelloPay uses cookies when you visit our website or mobile applications. Any Personal Data provided to or collected by HelloPay via cookies and other tracking technologies is controlled by HelloPay. Kindly familiarize yourself with our cookie practices.

2. Cookies and how we use them

A cookie is a small file of letters and numbers that websites send to the browser which are stored in the User terminal, which might be our computer, phones or applications, your personal computer, a mobile phone, a tablet, or any other device.

Cookies allow us to distinguish you from other users of our website and mobile applications, which helps us to provide you with an enhanced browsing experience. For example, we use cookies for the following purposes:

• Recognizing and counting the number of visitors and to see how visitors move around our sites, mobile apps [and app] when they are using it (this helps us to improve the way our website works, for example by ensuring that users can find what they are looking for).
• Identifying your preferences and subscriptions e.g. language settings, saved items, items stored in your basket and Prime membership; and
• Sending you newsletters and commercial/advertising messages tailored to your interests.

Our approved third parties may also set cookies when you use our marketplace. Third parties include search engines, providers of measurement and analytics services, social media networks, and advertising companies.

3. Cookie Preferences

We use technology such as “cookies” to collect information and store your online preferences. By managing your cookie preference, you enable or disable a specific set of cookies based on predefined categorization:

• Strictly Necessary Cookies: This cookie enables website functionality and is automatically enabled when you use the Site. This is essential to the operation of the Site to help you have an effective and efficient payment experience. You cannot disable this category of cookie.
• Analytics Cookies: It is important for Us to understand how you use the Site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping Us to improve Our Site and your experience of it.
• Functional Cookies: Functionality Cookies allow the Site to remember the choice you made and provide you with enhanced personal features. The information these cookies collect is anonymized and does not track your browsing activity on the Site.
• Targeting Cookies: It is important for Us to know when and how often you visit the Site, and which parts of it you have used (including which pages you have visited, and which links you have visited). As with Analytics Cookies, this information helps us to better understand you and, in turn, to make Our Site and advertising more relevant to your interests. Some information gathered by Targeting Cookies may also be shared with third parties.
• Third Party Cookies: Third party Cookies are not placed by Us; instead, they are placed by third parties that provide services to Us and/or to you. Third party Cookies may be used by advertising services to serve up tailored advertising to you on Our Site, or by third parties providing analytics services to Us (these Cookies will work in the same way as Analytics Cookies described above).
• Persistent Cookies: Any of the above types of Cookies may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit Our Site.
• Session Cookies: Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit Our Site until you close your browser. Session Cookies are deleted when you close your browser.

For more details of the personal data that We collect and use, the measures we have in place to protect personal data, your legal rights, and our legal obligations, please refer to our Privacy notice.

4. Consent

Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies (unless those Cookies are strictly necessary); however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow and/or deny different categories of Cookie that We use.

In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

The links below provide instructions on how to control Cookies in all mainstream browsers:

• Google Chrome
• Microsoft Internet Explorer
• Microsoft Edge
• Safari (macOS)
• Safari (iOS)
• Mozilla Firefox
• Android (Please refer to your device’s documentation for manufacturers’ own browsers)

5. Changes to this Cookie Policy

We may alter this Cookie Policy at any time. If We do so, details of the changes will be highlighted at the top of this page. Any such changes will become binding on you on your first use of Our Site after the changes have been made. You are therefore advised to check this page from time to time.

In the event of any conflict between the current version of this Cookie Policy and any previous version(s), the provisions current and in effect shall prevail unless it is expressly stated otherwise.

6. Further Information

If you are looking for more information on how we process your personal data, or you wish to exercise your legal rights in respect of your personal data, please send us an email to [email protected].