Introduction

1.1 ATN Wayya Limited is a Financial Services Company duly incorporated under the Laws of the Federal Republic of Nigeria and providing financial services including but not limited to agency banking services.

1.2 References in this Policy to “we”, “us” or “ATN Wayya” are references to ATN Wayya Limited.

1.3 Reference in this Policy to “personal data” means any information that identifies, or could reasonably be used to identify, a living individual, either on its own or together with other information.

What Information we collect about you

The personal data that we collect and process may include:

  • Basic information such as name, date of birth, employer, title, relationship affiliations with a person or organization;
  • Contact information such as physical address, email address, fax and phone number(s);
  • Background information such as provided by you or collected by us as part of our recruitment processes;
  • Financial information including BVN, bank account details, accounting and tax details and payment records as statutorily required of us under the extant laws, KYC procedure or other confidential information belonging to our sub-agents, vendors or affiliates;
  • Details relating to your visits to our offices; and/or
  • Any other information relating to you which you may provide to us.

How we protect your personal information

We are committed to protecting your personal information and implementing appropriate technical and organizational security measures to protect it against any unauthorized or unlawful processing and against any accidental loss, destruction or damage. Our information security practices are contained in our Information Security policy.

How we use your personal data

Whether we obtain your personal data directly from you or from a third party, we will only use your personal data in connection with contractual or statutory obligations unless where you have specifically consented to such use or where such use serves our legitimate interest (balanced out against yours). Uses to which we pay put your personal data include:

  • Providing our professional services including but not limited to agency banking or other financial related services to you;
  • Managing our business relationship with you or your organization, whether in connection with the delivery or procurement of goods and services or as your employer or former employer, including processing payments, accounts keeping, statutory remittances, billing and collection and related services;
  • Acting in compliance with our statutory obligations such as records keeping, statutory remittances and KYC requirements;
  • Supervision of access to our offices, systems and online platforms;
  • Complying with court orders and other legal directives/requirements;
  • Processing that is necessary for purposes of the reasonable interest of ATN Wayya or third parties provided that such interests do not override your interests or your fundamental rights and freedoms, and
  • For any other purpose relating to the foregoing or for any purpose for which you provided the personal data to ATN Wayya.

We will therefore only process your personal information if:

  1. You have given your consent (where necessary) to such use or the organization you work for has obtained your consent (where necessary to share your information with us); or
  2. If we have a contractual or statutory obligation to process your personal information
  3. If we (or a third party) have a legitimate interest which is not overridden by your interest or your rights and freedoms.

How Your Personal Data Is Obtained

As a Financial Service Company, we frequently obtain personal data as part of our professional activities. We may collect your personal data:

  • in the course of our recruitment processes;
  • when you seek our professional services or when you agree to register as a sub-agent/business affiliate under our platform;
  • when you or your organization provides services as our vendor;
  • when you email us or contact us via our social media platforms or subscribe to any of our products and services
  • When you physically visit any of our premises

Sharing Your Personal Data

Irrespective of how we obtain your personal data, it may be shared among all our affiliates/agents/sub-agents and persons to whom we owe statutory disclosure obligations as concerns your personal data. We always ensure at least a standard level of data protection is always in place. Where we share your personal data with third parties, we will do this in accordance with applicable data protection laws and will take appropriate safeguards to ensure its protection.

Marketing

We would like to send you information about our products, services and special offers which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or call. We will only ask whether you would like us to send you marketing messages when you tick the relevant boxes. If you have previously agreed to being contacted in this way, you can unsubscribe at any time by contacting us at our contact email address or by using the unsubscribe link in the emails.

Retaining Your Personal Data

We will delete your personal data when it is no longer reasonably required for the Authorized Uses or you withdraw your consent (whichever is applicable), provided that we are not legally required or otherwise authorized to continue to hold such data. We may retain your personal data for an additional period to the extent that deletion would require us to overwrite our automated disaster recovery backup systems or to the extent we deem it necessary to assert or defend legal claims or in pursuance of any regulatory, accounting or reporting requirement

Your Rights As A Data Subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete
  • Right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records
  • Right of portability – you have the right to have the data we hold about you transferred to another organization
  • Right to object – you have the right to object to certain types of processing such as direct marketing
  • Right to object to automated processing, including profiling – you also have the right not to be subjected to the legal effects of automated processing or profiling
  • Right to judicial review – in the event that we refuse your request under rights of access, we will provide you with a reason for the refusal. You also have a right to make a complaint to the NITDA

What Constitutes Consent Of A Data Subject?

Consent of a data subject to this Privacy Policy is construed accordingly:

  1. Visitors: When you visit our website or online platforms and volunteer your personal information or when you physically visit any of our premises
  2. Client: When you engage us to provide financial services to you and/or sign a contract document with us in that regard, subsequent to the disclosure of personal information
  3. Vendor/Supplier: when you approach us or when we engage you to supply goods/services to us.
  4. Job Applicant: when you send your application/CV in the response to our advertised job offers or a cold email

Can I Find Out The Personal Data That ATN Wayya Holds About Me?

ATN Wayya at your request can confirm what information we hold about you and how it is processed. If ATN Wayya does hold personal data about you, you can request the following information:

  1. Contact details of the Data Protection Officer, where applicable
  2. The purpose of the processing as well as the legal basis for processing
  3. If the processing is based on the legitimate interest of ATN Wayya or a third party, information about those interests
  4. The categories of personal data collected, stored and processed;
  5. Recipient(s) or categories of recipients that the data is/will be disclosed to
  6. If we intend to transfer the personal data to a third party or international organisation, information about how we ensure this is done securely. The Attorney General of the Federation will approve sending personal data to some countries if they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information
  7. How long the data will be stored
  8. Details of your rights to correct, erase, restrict or object to such processing
  9. Information about your right to withdraw consent at any time
  10. How to lodge a complaint with the supervisory authority (NITDA);
  11. Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data
  12. The source of personal data if it was not collected directly from you
  13. Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing

What Forms Of ID Will I Need To Provide In Order To Access This?

ATN Wayya accepts the following forms of ID (but not limited to) when information on your personal data is requested:

  • Passport
  • Driver’s license
  • Permanent Voters Card.
  • National Identity Card

Dispute Resolution Or Filing A Complaint

If you have any complaints regarding our compliance with this Privacy Policy, please contact our Data Protection Officer. We will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of personal information within thirty (30) days in accordance with this Privacy Policy and in accordance with applicable law and regulation.

Compliance With The Regulators

This Privacy Policy is in line with the provisions of Nigeria Data Protection Regulation, 2019 (Regulation). This Regulation describes how data controllers including ATN Wayya must collect, handle and store personal information and applies regardless of whether data is stored electronically, on paper or on other materials.

Policies Updates

From time to time, we may change, amend or review this Privacy Policy from time to time to reflect new services or changes in our Privacy Policy and place any updates on this page. All changes made will be posted on this page and where changes will materially affect you, we will notify you of this change by placing a notice online or via mail. If you keep using our Services, you consent to all amendments of this Privacy Policy.

Contact Us

If you have any questions or suggestions regarding our Privacy Policy, please contact our Data Protection Officer.
Address: muhammad.sani@wayya.com.ng
Contact Name: Muhammad Sani
Phone Number: +234 816 664 6701