Privacy Policy - Onboard

This Privacy Policy is designed to inform you (“Transaction Partner”, “Merchant” or “User”) about the Personal Data we collect, how we collect this data, the uses of the data and your rights relating to the Personal Data when you use the Onboard Platform and any of its Products and Services.

Nestcoin Holdings Limited, (the “Company”, “We”, “Us”, “Our”) a private limited liability company incorporated in the British Virgin Islands, with Registration Number 2074697, is the data controller for personal information collected in connection with provision of Onboard Services. We are committed to protecting the privacy of the personal information that is provided to or collected by us while you use the Onboard Platform. We acknowledge and comply with our legal obligations in relation to applicable data protection laws.

This privacy policy explains:

• How we may collect, use, manage, and disclose information about clients, other business, and firm contacts
• How we may collect, manage, and use personal information obtained from you
• The rights you may have in respect of your own personal information.

By continuing to use the Onboard platform, you acknowledge that you have reviewed the Privacy Policy and agree to its terms. This also means that you have consented to the use of your Personal Data and have accepted the applicable disclosures.

THE DATA THAT WE MAY COLLECT:

The scope of information we may collect from Users include:

• All personal data obtained from persons using the service.
• Data provided to us while making an enquiry on the use of the service.
• Data provided to us while reporting a problem or making a complaint about the service.

THE TYPE OF DATA WE MAY COLLECT

The specific types of personal data that we may collect, use and store are as follows:

• “Identity Data”: This includes your first name, middle names, maiden name, last name, title, date of birth, photographic identification, and gender.
• “Contact Data”: This includes your home address, email address and telephone number.
• “Account Information”: This includes information such as usernames and passwords, authentication methods and roles, and similar data.
• “Financial Data”: This includes information such as payment card details, bank information and payment information.
• “Transaction Data”: This includes details about payments to and from you and other details of services you have purchased from us, or we have purchased from you.
• “Technical Data”: This includes information collected when you access the Onboard platform, your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you are using.
• Marketing and Communication Data: This includes data relating to your preferences in receiving newsletters with respect to our products and services from us as well as your communication preferences.
• Professional Data: This includes your company name, job title, email address, phone number and addresses.

WHY WE COLLECT DATA

We collect data to enable us to -

• Process requests or applications which you make, or which are made on your behalf with your consent; to provide you with our services.
• Communicate with you, to provide further information on our Services, and to assist you.
• Respond to questions or requests which you submit as well as anticipate and resolve problems with any services we offer to you.
• Process identity information and Sensitive Personal Data (as detailed in section 1) to comply with our Know Your Customer (“KYC”) obligations under applicable laws and regulations, and Anti-Money Laundering laws and regulations;
• Prevent and detect fraud and abuse in order to protect the security of our Users, Onboard Services and others.
• Provide functionality, analyse performance, fix errors, and improve the usability and effectiveness of the Onboard application, website and its Services.

HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

• Direct collection: You may give us your data by signing up on the Onboard platform; creating your profile; by correspondence and conversations (including via email and telephone); or through contracts we may enter with you.
• Automated technologies: As you interact with our website, we will automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We collect such data to be able to properly provide you with our services. Please see our cookie policy for further details.
• Third parties or publicly available sources: We may also receive your personal data from third parties to whom you have legally provided such data to. We also share Your Personal Data with third parties in order to protect the rights, properties or safety of us, the Users or as otherwise required by law. To the extent that such data is disclosed by third parties, different rules may apply to their use or disclosure of your information. We do not control how they use or share your data and we cannot make any representations or warranties as to these. We however have control over data that you have voluntarily shared to us directly or through your usage of our website. With your consent, we use your information to fulfil requests to receive information or materials from us, to carry out services for your benefit and to process applications and requests from you. We do not use your data for any other purpose than for the purposes listed out in this policy and we do not sell, lend or rent any personal data about you to any third parties.

STORAGE OF PERSONAL DATA

We take the security of the Personal Data we collect very seriously and we take reasonable measures to reduce the risk of accidental destruction, loss or unauthorised access to such information. However, please note that no system involving the transmission of information via electronic storage systems or the internet is completely secure.

The Personal Data and any other information we have about you may be stored for such a period as we may determine until you terminate your account with us or you withdraw your consent.

PURPOSE OF PROCESSING PERSONAL DATA

We will use your personal data only to the extent permitted by law. We process your personal data under any of the following lawful basis in both the Nigeria Data Protection Regulation 2019 (NDPR), and the EU General Data Protection Regulation (GDPR).

We collect and use the Personal Data that we collect for the following reasons:

• Where you consent to our use of your personal data
• Communicate with you, to provide further information on our Services, and to assist you.
• Where your personal information is necessary for the performance of the contract to use our services
• Where we need to comply with a legal obligation.
• Where we need to protect your vital interest or the vital interest of another individual
• Where it is in the interest of the general public to process your data

DATA SECURITY

We will take reasonable steps to protect personal data disclosed to us from loss, modification, misuse, unauthorised access and/or disclosure. The Onboard platform is built with strong security features that continuously protects your Personal Data. Our security features help us detect and block security threats. If we detect any security risk, we may inform you and guide you through steps to stay protected.

While we do our best to protect your personal data, we cannot guarantee the security of your data transmitted over the internet as transmission over the internet is not completely secure; therefore, note that any such transmission is at your own risk. However, we will use strict procedures and security features to try to prevent unauthorised access once we have collected your information. We are bound by international standards and best practices on information and cyber security as may be issued from time to time

DATA RETENTION

We retain your data for such a period as is necessary for the purpose for which it was collected. Storage of your data is also determined by legal, regulatory, administrative, or operational requirements. We only retain information that allows us to comply with legal and regulatory requests for certain data, meet business and audit requirements, respond to complaints and queries, or address disputes or claims that may arise. When data is no longer required for the purposes for which it was collected, we securely destroy it.

DISCLOSURE OF YOUR INFORMATION

Your personal data may be disclosed in the following ways:

• By you: On the Onboard platform, you can share information with other Users. However, you have control over how you share this information. When you upload any content on our application, or website, your content becomes accessible to other Users.
• By Us:

• We may disclose your personal information to any of our affiliates.
• We may also disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect our rights, property, or safety or those of other Users our clients or others.
• We may disclose your personal data if we are legally required to do so.
• We may disclose your personal data to meet any applicable law, regulation, legal process or any legal request such as subpoenas, court orders, requests for administrative or government bodies;
• to enforce our applicable Terms and Conditions;
• to detect, prevent or address any fraud, security or technical issues;
• to prosecute or bring any legal action against any User who has violated any law or our Terms and Conditions.

USER CONTENT

We may allow Users to post their content or information on this. These contents include audio, video, updates, articles, images or other materials Users choose to display on the. Please note that any material which You may post is made accessible to the entire public and will not be regulated by this Privacy Policy.

THIRD PARTY SITES

Our website, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details are governed by their privacy practices and we will not be liable for any breach of confidentiality or privacy of your information on such third-party websites. We encourage you to learn about the privacy practices of those third parties or contact them directly for information on their privacy policy, security, data collection and distribution policies.

PRIVACY POLICY CHANGE

We may modify this Privacy Policy from time to time without prior notice by publishing a new version of the Privacy Policy on the Onboard website. Any changes to the Privacy Policy will be reflected on the website and will become effective immediately upon publication. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personally identifiable information we collect. If changes to the Privacy Policy are material, we will do our best to notify you via email or through a notification on our website.

YOUR LEGAL RIGHTS

In addition to being able to control the data your directly provide to us, you may exercise any of the below rights with respect to your data:

1. Request information about any of your personal data which we are processing, and request access to your personal information which we process.
2. Request correction of personal information that we hold about you to make them more accurate or to reflect change in circumstances.
3. Request us to refrain from doing certain things with your data or restrict the extent of our collection or processing of your data.
4. Request partial or complete erasure of your personal information.
5. Object to our processing of your personal information where we are processing your personal information for direct marketing purposes.
6. Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
7. Request the transfer of your personal information to another party. If you wish to exercise any of the rights set out above, please contact us using the contact details provided below.

YOUR LEGAL RIGHTS

If you have any questions about this privacy policy or our privacy practices, please contact us using the details provided below:

Full name of legal entity: Nestcoin Holdings Limited

Email address: support@onboard.xyz