Privacy Notice
First Published : 5 January 2024
Introduction
Thank you for choosing Pooler as your preferred solution for receiving payments. If you haven’t yet done so, we hope you consider using Pooler and taking advantage of our many benefits.
Pooler is a product owned and managed by Woodcore Pooler Ltd (“Pooler”, “Us”, “We”) with the goal of facilitating Account to Account (A2A) through its licensed partners and providing other value added services to the merchants (“you”) in Nigeria.
For the sake of transparency and in accordance with applicable privacy laws, we have documented on this page our privacy notice. You will find the following essential information relating to your privacy in this notice;
This Privacy Notice applies to every use of our Services including the Pooler product. We may make changes at any time to this Notice. However, when we do this, we will make changes to the version control information above and we may contact you through phone, email or by notification on your dashboard to notify you of those changes.
Pooler is a product owned and managed by Woodcore Pooler Ltd (“Pooler”, “Us”, “We”) with the goal of facilitating Account to Account (A2A) through its licensed partners and providing other value added services to the merchants (“you”) in Nigeria.
For the sake of transparency and in accordance with applicable privacy laws, we have documented on this page our privacy notice. You will find the following essential information relating to your privacy in this notice;
- The type of data we collect from you
- How we collect your personal data
- Why we collect your personal data
- Who we share your data with
- How long we can retain your personal data
- Our lawful bases for processing your personal data
- How we protect your personal data Your rights as a data subject How you can exercise your rights as a data subject
- How to contact us
This Privacy Notice applies to every use of our Services including the Pooler product. We may make changes at any time to this Notice. However, when we do this, we will make changes to the version control information above and we may contact you through phone, email or by notification on your dashboard to notify you of those changes.
1. The types of personal data collected
Pooler is solely focused on servicing businesses. However, because behind those businesses are human beings, we often collect personal data at onboarding for purposes we will describe later on in this notice. Unregistered businesses often register with the personal data of their proprietors and registered businesses or corporate entities will provide personal data of their directors and shareholders.
We detail below the types of personal data we collect at different stages of your use of the Pooler product;
1.1 At the point of onboarding unto our product, we will collect the following information from you at the minimum;
1.2 At different times during the course of your use of the Pooler product especially during compliance reviews or Know Your Customer (KYC) refresh activities;
1.3 Additional Information
In addition to the above, we may also collect the following;
We detail below the types of personal data we collect at different stages of your use of the Pooler product;
1.1 At the point of onboarding unto our product, we will collect the following information from you at the minimum;
- First Name
- Last Name
- Date of Birth
- Email address
- Phone Number
- Physical Address
- Government-issued Identification
- Bank Verification Number
- Employment/Business Information
- Tax Identification Number
- Passwords you create on our platform
- Account number for reconciliation
- Transaction information
1.2 At different times during the course of your use of the Pooler product especially during compliance reviews or Know Your Customer (KYC) refresh activities;
- Proof of funds documentation e.g. tax refund document, bank statements etc.
- Source of funds documentation e.g, payment receipts, bank statements etc.
1.3 Additional Information
In addition to the above, we may also collect the following;
- Information about the devices you use to login to our products;
- Information about the location from which you access our products and services;
- Information from third-party databases such as the BVN database, Independent National Electoral Commission (INEC) database, National Identity Card database, relevant fraud databases, etc.
- Tracking data and cookies in accordance with our Cookie Policy; and Information about how you use our products and services and your communications with us.
2. How we collect your data
We may collect your data through any one or more of the following medium;
2.1 Onboarding
2.2 Correspondence with Pooler, by email or instant message or chat, or other means of communication.
2.3 Our web application or related software applications on the google play store or the ios app store when you;
2.4 Enter a competition, promotion, or survey hosted by Pooler or any of our partners;
2.5 When you decide to report a problem with our application or any of our Services, any of our websites, etc.
2.1 Onboarding
- Information provided by you when you complete our onboarding process, through our media channels or any other channel through which you can communicate with us;
- Information provided by you to our sales, marketing or onboarding agents during physical onboarding sessions;
- Information provided by you when we request further information to complete your verification process on our platform.
2.2 Correspondence with Pooler, by email or instant message or chat, or other means of communication.
2.3 Our web application or related software applications on the google play store or the ios app store when you;
2.4 Enter a competition, promotion, or survey hosted by Pooler or any of our partners;
2.5 When you decide to report a problem with our application or any of our Services, any of our websites, etc.
3. Why we collect your personal data
3.1 To comply with legal and regulatory requirements
Pooler provides its services through partner banks licensed by the Central Bank of Nigeria and under the obligation to properly identify their customers and conduct customer due diligence. For this reason, we collect your information and personal data to satisfy theirs and our due diligence and KYC requirements.
We may collect more information from you where there is any change in the legal or regulatory requirement that may warrant it.
3.2 To aid our fraud and financial crimes investigation
As a financial infrastructure company tied to financial service partners, we have to manage the risk of fraud on our platform. To ensure that we do not onboard fraudsters and we can properly identify suspicious or potentially illegal/fraudulent activity, we collect your information and try to understand your profile as a customer.
3.3 To improve the performance of our services
From time to time, we may collect performance data from your devices, dashboard or any other medium from which you are accessing our services. The purpose of this is to help us do proper quality checks and improve, where necessary. It also helps us to resolve any technical issues you may be having with Pooler.
Pooler provides its services through partner banks licensed by the Central Bank of Nigeria and under the obligation to properly identify their customers and conduct customer due diligence. For this reason, we collect your information and personal data to satisfy theirs and our due diligence and KYC requirements.
We may collect more information from you where there is any change in the legal or regulatory requirement that may warrant it.
3.2 To aid our fraud and financial crimes investigation
As a financial infrastructure company tied to financial service partners, we have to manage the risk of fraud on our platform. To ensure that we do not onboard fraudsters and we can properly identify suspicious or potentially illegal/fraudulent activity, we collect your information and try to understand your profile as a customer.
3.3 To improve the performance of our services
From time to time, we may collect performance data from your devices, dashboard or any other medium from which you are accessing our services. The purpose of this is to help us do proper quality checks and improve, where necessary. It also helps us to resolve any technical issues you may be having with Pooler.
4. Who do we share your data with?
As disclosed earlier, we are a financial infrastructure company partnering with a CBN licensed institution to provide our services. As such, accounts you open with us are domiciled at our partner banks and transfers are processed by those banks.
For the purposes highlighted above, we may share your personal data with these banks including but not limited to Kredi Microfinance Bank Ltd. We may also share your personal information with KYC verification service providers to complete our KYC obligations and law enforcement agencies where they request for it.
For the purposes highlighted above, we may share your personal data with these banks including but not limited to Kredi Microfinance Bank Ltd. We may also share your personal information with KYC verification service providers to complete our KYC obligations and law enforcement agencies where they request for it.
5. Our lawful basis for processing your data
The following are our lawful bases for processing your personal data at Pooler in accordance with the Nigerian data protection act 2023;
5.1 Compliance with a legal or regulatory requirement under anti-financial crime laws in force in Nigeria including the Money Laundering (Prevention and Prohibition Act, 2022 and the CBN Customer Due Diligence Regulations 2023.
5.2 To perform our contract with you including facilitation of collections services, reconciliation of payments receipt in conjunction with our partner bank(s) and other services envisaged under our Terms of Use and Service Level Agreements, where applicable;
5.3 With your consent, where we expressly request for it particularly in relation to the use and sharing of your personal data by and with third party service providers.
5.1 Compliance with a legal or regulatory requirement under anti-financial crime laws in force in Nigeria including the Money Laundering (Prevention and Prohibition Act, 2022 and the CBN Customer Due Diligence Regulations 2023.
5.2 To perform our contract with you including facilitation of collections services, reconciliation of payments receipt in conjunction with our partner bank(s) and other services envisaged under our Terms of Use and Service Level Agreements, where applicable;
5.3 With your consent, where we expressly request for it particularly in relation to the use and sharing of your personal data by and with third party service providers.
6. How long we can retain your personal data
We retain the personal data of customers and merchants for a period not less than five years(s) after we close the customer’s or merchant’s account. This is in accordance with the data retention requirement under the Nigerian Money Laundering (Prevention and Prohibition) Act 2022 and other applicable laws in Nigeria.
7. Third party services
Pooler provides some value added services through partners such as logistics and marketing partners. We may share your data with these third parties, with your consent, if you wish to use their services. At such time when this is done, we will provide a specific notice to you notifying you of the data we are sharing with those partners along with a check-box for you to consent to such data sharing.
We expressly disclaim that we provide those services directly and we make no warranties as to the quality of service nor protection mechanisms employed by those companies. We urge you to do your due diligence before engaging such third party service providers.When you click on certain links that take you to third-party platforms from our Platform, kindly review their privacy notice and privacy policy before proceeding to share your data with them. We will not bear any responsibility for any loss or liability that occurs from your data sharing with them.
We expressly disclaim that we provide those services directly and we make no warranties as to the quality of service nor protection mechanisms employed by those companies. We urge you to do your due diligence before engaging such third party service providers.When you click on certain links that take you to third-party platforms from our Platform, kindly review their privacy notice and privacy policy before proceeding to share your data with them. We will not bear any responsibility for any loss or liability that occurs from your data sharing with them.
8. How we protect your data
Compliance is a never-ending destination and everyday new threats emerge to compromise data security and privacy. To address these issues and potential risks, we continue to work towards a compliance arched on the following two objectives;
8.1 Governance Measures
We have and will implement further governance measures to ensure proper data governance within our company. This includes the designation of a data protection contact to manage our privacy and information security compliance.
8.2 Technical Measures
We have and will implement technical measures such as multi-factor authentication, encryption, password policy, and other measures to ensure that your data with us is kept secure depending on the Platform you are using.
We have and will implement further governance measures to ensure proper data governance within our company. This includes the designation of a data protection contact to manage our privacy and information security compliance.
8.2 Technical Measures
We have and will implement technical measures such as multi-factor authentication, encryption, password policy, and other measures to ensure that your data with us is kept secure depending on the Platform you are using.
9. Your rights as data subject
As a Pooler customer, we consider you to be a data subject under Nigerian data protection and privacy laws. These laws guarantee some of your rights as a data subject which we have outlined below;
9.1 The right to request confirmation of whether Pooler processes data relating to you and if so, to request a copy of such data;
9.2 The right to request that we erase your personal data in certain circumstances provided by law;
9.3 The right to request that we rectify or update your personal data or business information which is inaccurate, incomplete or outdated;
9.4 The right to request that we export your personal data that we hold to another company where we believe it is technically feasible to do so;
9.5 The right to request that we restrict the use of your personal data in certain circumstances provided that you understand that the exercise of this right might restrict your access to some of our services;
9.6 The right to withdraw your consent in accordance with this privacy Notice, where it has been previously given;
9.7 The right to file a complaint with the Nigerian Data Protection Commission in accordance with the Nigerian Data protection Act.
9.1 The right to request confirmation of whether Pooler processes data relating to you and if so, to request a copy of such data;
9.2 The right to request that we erase your personal data in certain circumstances provided by law;
9.3 The right to request that we rectify or update your personal data or business information which is inaccurate, incomplete or outdated;
9.4 The right to request that we export your personal data that we hold to another company where we believe it is technically feasible to do so;
9.5 The right to request that we restrict the use of your personal data in certain circumstances provided that you understand that the exercise of this right might restrict your access to some of our services;
9.6 The right to withdraw your consent in accordance with this privacy Notice, where it has been previously given;
9.7 The right to file a complaint with the Nigerian Data Protection Commission in accordance with the Nigerian Data protection Act.
10. How to exercise your rights as a data subject
You may exercise your rights in 9.1 to 9.6 above through any of the following means;
a. Email
You may contact us through our dedicated email address compliance@woodcoreapp.com. When we receive your request, we may ask that you complete a form and provide suitable identification in order to verify your identity, and we will provide you with requests as soon as possible. This is to ensure that you truly are the one requesting for your own data.
b. Toggle your device settings
If its in relation to technical information we collect, you may control our access through the privacy settings app on your devices. However, please note that this may affect the services we provide to you.
c. By unsubscribing
If you no longer want to receive marketing, advertising or related emails from us, you may opt out via the unsubscribe link included in such email.
d. Addressing a breach of your privacy
If you believe we have breached your privacy rights in any way, please reach out to us via email. We will make attempts to rectify such alleged breach, if found true, in reasonable time. However, please note that resolution of such issues will be done in accordance with our terms of use.
a. Email
You may contact us through our dedicated email address compliance@woodcoreapp.com. When we receive your request, we may ask that you complete a form and provide suitable identification in order to verify your identity, and we will provide you with requests as soon as possible. This is to ensure that you truly are the one requesting for your own data.
b. Toggle your device settings
If its in relation to technical information we collect, you may control our access through the privacy settings app on your devices. However, please note that this may affect the services we provide to you.
c. By unsubscribing
If you no longer want to receive marketing, advertising or related emails from us, you may opt out via the unsubscribe link included in such email.
d. Addressing a breach of your privacy
If you believe we have breached your privacy rights in any way, please reach out to us via email. We will make attempts to rectify such alleged breach, if found true, in reasonable time. However, please note that resolution of such issues will be done in accordance with our terms of use.
How to contact us
If you have any question or request about this privacy notice or how to exercise your rights, you can contact us through the following means;
At our office:
Block 4, Bayview Estate,
Ikate,
Lekki, Lagos state.
Through email:
To compliance@woodcoreapp.com
Compliance Team
Pooler.
At our office:
Block 4, Bayview Estate,
Ikate,
Lekki, Lagos state.
Through email:
To compliance@woodcoreapp.com
Compliance Team
Pooler.
