Yana Privacy Policy

Preamble
Yana and all Yana products and services are all provided and protected under Pennee Technologies, Inc. A company incorporated in the state of Delaware, USA with operations in Nigeria. This Privacy Policy explains how your personal information is collected, used and discussed by Pennee Technologies, Inc. and all its subsidiaries.
Introduction
This Privacy Policy applies to our website, web applications and mobile applications (collectively, our “Services”) and to all forms of systems, operations and processes within our environment that involve the collection, storage, use, transmission and disposal of Personal and Business Information. By accessing or using our Services, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy and our Terms of Service. This Privacy Policy is strictly restricted to only our Services and therefore does not apply to services that are not owned or controlled by us, including third-party websites. We are committed to handling all Personal Information provided to us in compliance with both applicable and model data protection and privacy laws.
Definition and Interpretation
To ensure that you understand the terms used within this Privacy Policy, these terms are referenced and defined below:
1. Cookie: means a small amount of data generated by a website and saved by your web browser application. It is used to identify your browser, provide analytics and remember information about you.
2. Company: means Pennee Technologies, Inc. and all its subsidiary and products including Yana and all its affiliated products and services.
3. Country: means Nigeria.
4. Device: means any device connected to the internet which a person (natural or legal) used to access our website, mobile application and services. It could be a phone, tablet, computer, or any other device capable of connecting to the internet and accessing our services.
5. Personal information: means any information that belongs to any identifiable living individual. Such information includes (such as name, telephone numbers, address, PIN, email address, Bank Verification number etc.) of individuals that makes them easily identifiable.
6. Business information: means any information that belongs to any entity that identifies as a business and recognized by the Nigerian state. Such information includes (such as name, CAC number, TIN etc) of businesses that makes them easily identifiable as a corporate entity.
Consent
By using our Services in any manner, you confirm to us that you have read and accept this Privacy Policy and consent to the data practices described in this Privacy Policy. If you do intend to accept this Privacy Policy or do not meet or comply with the provisions set forth herein, then you may not use our Services.
The Information We Collect
1. Personal Information
  As part of our operations, we collect and process certain types of information (such as name, telephone numbers, address, PIN, email address, Bank Verification number etc.) of individuals that makes them easily identifiable. These individuals include current, past and prospective registered users, prospective users, newsletter applicants, any and all other persons that in one way or the other interact with our platform (“Users”) and other individuals whom we communicate or deal with, jointly and/or severally. To use our Services, you will be required and hereby undertake to voluntarily provide us with certain Personal Information. Personal Information refers to information relating to an identified person or information that can be used to identify you, (e.g., name, email address, telephone number). It may also include anonymous information that may be linked to you specifically, (e.g., IP address).
  We use your Personal Information to:
  1. provide you with the required Services
  2. respond to your questions or requests
  3. improve features, website content and analyze data to develop products and services
  4. address inappropriate use of our Services
  5. prevent, detect and manage risk against misinformation, wrong use and illegal activities using internal and third-party screening tools
  6. send you marketing content, newsletters and service updates curated by us, however, we will provide you with an option to unsubscribe if you do not want to hear from us
  7. verify your identity and the information you provide in line with our statutory obligations using internal and third-party tools
  8. maintain up-to-date records
  9. resolve disputes that may arise, including investigations by law enforcement or regulatory bodies
  10. any other purpose that we disclose to you while providing our Services to you.
  We may retrieve additional Personal Information about you from third parties and other identification/verification services. With your consent, we may also collect additional Personal Information in other ways including emails, surveys, and other forms of communication. Once you begin using our Services, we will keep records of and collect information regarding your activities as it relates to our Services. We will not share or disclose your Personal Information with a third party without your consent except as may be required for the purpose of providing you.
  We may retrieve additional Personal Information about you from third parties and other identification/verification services. With your consent, we may also collect additional Personal Information in other ways including emails, surveys, and other forms of communication. Once you begin using our Services, we will keep records of and collect information regarding your activities as it relates to our Services. We will not share or disclose your Personal Information with a third party without your consent except as may be required for the purpose of providing you with our services or under applicable legislation.
2. Business Information
  As part of our operations, we collect and process certain types of information (such as name, telephone numbers, address, email address, CAC information, Tax information, etc.) of businesses and corporate bodies that makes them easily identifiable. These businesses include current, past and prospective registered businesses, prospective businesses, newsletter applicants, any and all other entities that in one way or the other interact with our platform (“Businesses”) and other entities whom we communicate or deal with, jointly and/or severally. To use our Services, you will be required and hereby undertake to voluntarily provide us with certain Business Information. Business Information refers to information relating to an identified entity or information that can be used to identify it, (e.g., name, logo, CAC). It may also include general information that may be linked to the business specifically, (e.g., address).
  We use your Business Information to:
  1. provide the business with the required Services
  2. respond to the business or persons affiliated with the business, questions or requests
  3. improve features, website content and analyze data to develop products and services
  4. address inappropriate use of our Services
  5. prevent, detect and manage risk against misinformation, wrong use and illegal activities using internal and third-party screening tools
  6. send you marketing content, newsletters and service updates curated by us. However, we will provide you with an option to unsubscribe if you do not want to hear from us.
  7. verify the business identity and the information they provide in line with our statutory obligations using internal and third-party resources.
  8. maintain up-to-date records.
  9. resolve disputes that may arise, including investigations by law enforcement or regulatory bodies
  10. any other purpose that we disclose to you while providing our Services to you.
  We may retrieve additional Business Information about you from third parties and other identification/verification services. With your consent, we may also collect additional Business Information in other ways including emails, surveys, and other forms of communication. Once you begin using our Services, we will keep records of and collect information regarding your activities as it relates to our Services. We will not share or disclose your Business Information with a third party without your consent except as may be required for the purpose of providing you.
3. Information that we collect from website visitors not Users
  As a visitor to our website, we do not collect your Personal Information or Business Information. However, so we can monitor and improve our website and Services, we may collect non-personally identifiable information. We will not share or disclose this information with third parties except as a necessary part of providing our Services. We may, where applicable, use the information to target advertisements to you.
4. Purpose Limitation
  We collect Personal Information and Business Information only for identified purposes and for which consent has been obtained. Such Personal Information and Business Information cannot be reused for another purpose that is incompatible with the original purpose, except consent is obtained for such purpose.
5. Data Minimization
  We limit Personal Information and Business Information collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed. We will evaluate whether and to what extent the processing of Personal Information is necessary and where the purpose allows, anonymized data will be used.
6. Cookies
  We use cookies to identify you as a User or Business and make your experience easier, customize our Services, content and advertising and where applicable help you ensure that your account security is not compromised. We also use cookies to mitigate risk and prevent fraud, promote trust and safety on our website. Cookies allow our servers to remember IP addresses, date and time of visits, monitor web traffic and prevent illegal activities. Our cookies do not store private or sensitive information. They simply hold a unique random reference to you so that once you visit our website, we can recognize who you are and provide certain content to you. If your browser or browser add-on permits, you have the choice to disable cookies on our website, however this may impact your experience with using our website.
How Do We Protect Your Information
We shall establish adequate controls in order to protect the integrity and confidentiality of your Personal Information and Business Information, both in digital and physical format and to prevent your Personal Information and Business Information from being accidentally or deliberately compromised. We are committed to managing your Personal Information and Business Information in line with global industry best practices. We protect your Personal Information and Business Information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration, we also use industry recommended security protocols to safeguard your Personal Information and Business Information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to our building and files and only granting access to your Personal Information and Business Information to only employees who require it to fulfill their job responsibilities. No Personal Information and Business Information processing will be undertaken by an employee who has not been authorized to carry such out as part of their legitimate duties.
How We Share The Personal Information You Provide
We do not sell or trade Personal Information and Business Information with third parties. However, to enable us to render our Services to you on our website, we may share your information with trusted third parties, such third parties include sanctions screening and identity verification services as well as any third parties that you have directly authorized to receive your Personal Information and Business Information. We may disclose your Personal Information and Business Information in compliance with applicable law or a legal obligation to which we are bound. Please note that third-party sites you engage with through our Services will have their privacy policies, and we are therefore not responsible for their actions, including their information protection practices. The use of your information by such third parties will be subject to their applicable privacy policy, which you should carefully review.
Transfer Of Personal Information
1. Third Party Processor within Nigeria
  We may engage the services of third parties to process your Personal Information and Business Information. The processing by such third parties shall be governed by a written contract with us to ensure adequate protection and security measures are put in place by the third party for the protection of Personal Information and Business Information in accordance with the terms of this Privacy Policy.
2. Transfer of Personal Information to Foreign Country
  In providing you with the Services, we may rely on third-party servers located in foreign jurisdictions from time to time, which as a result, may require the transfer or maintenance of your Personal Information or Business Information on computers or servers in foreign jurisdictions. Where such Personal Information and Business Information is to be transferred to a country outside Nigeria, we shall put adequate measures in place to ensure the security of such Personal Information. We shall, among other things, confirm whether the country is on the National Information Technology Development Agency (“NITDA”) Whitelist of Countries with adequate data protection laws. The transfer and subsequent processing of such Personal Information and Business Information will be in accordance with the provisions of the Nigeria Data Protection Regulation ("NDPR”) which we comply with. We will therefore only transfer and permit the processing of Personal Information and Business Information outside of Nigeria where:
  1. the transfer and processing is necessary for the performance of a contract between us or implementation of pre-contractual measures taken at your request;
  2. the transfer and processing is necessary to conclude a contract between us and a third party in your interest;
  3. the transfer and processing is necessary for reason of public interest;
  4. the transfer and processing is for the establishment, exercise or defense of legal claims;
  5. the transfer and processing is necessary to protect your vital interests or that of other persons, where you are physically or legally incapable of giving consent.
  We will take all necessary steps to ensure that your Personal Information and Business Information is transmitted and processed in a safe and secure manner. Details of the protection given when your Personal Information and Business Information is transferred outside Nigeria shall be provided to you upon request.
Data Retention
We will retain your Personal Information and Business Information for as long as is needed to provide our Services to you, comply with our legal and statutory obligations or verify your information with the required verification authorities. Therefore, even after discontinuance of our Services, we will retain certain Personal Information, Business Information and transaction data to comply with our legal and regulatory obligations. All Personal Information and Business Information shall be destroyed by us where we have satisfied the legal retention timeframe. For all Personal Information and Business Information and records obtained, used and stored by us, we shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity and requirement to retain.
The length of storage of your Personal Information and Business Information shall, amongst other things, be determined by:
1. the contract terms agreed between us or as long as it is needed for the purpose for which it was obtained; or
2. whether the transaction or relationship has statutory implication or a required retention period; or
3. whether there is an express request for deletion of the Personal Information and Business Information by you, provided that such request will only be treated where you are not under any investigation which may require us to retain such Personal Information and Business Information or there is no subsisting contractual arrangement with you that would require the processing of the Personal Information and Business Information; or
4. whether we have another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.
Choices And Rights
Once your Personal Information and Business Information is held by us, you are entitled to reach out to us to exercise the following rights:
1. the right to request rectification and modification of your Personal Information and Business Information which we keep,
2. the right to request the movement of your data from us to a third party called the right to the portability of data; and
3. the right to object to, and to request that we restrict the processing of your Personal Information and Business Information. We shall inform you of the effect of such restrictions and how it will affect our Services to you.
Your request will be reviewed by us and carried out except as restricted by law or our statutory obligations. You may review and update your Personal Information and Business Information directly or by contacting us via email at swift@yana.finance.
Age Restriction
Our Services are directed to people from the ages of 18 and above. If as a parent or guardian, you become aware that your child or ward has provided us with any information without your consent, please contact us via email at swift@yana.finance.
Updates, Modifications And Amendments
We reserve the right to update, modify, change or revise this Privacy Policy from time to time. The changes will not be retroactive, and the most current version of this Privacy Policy which will always be on this page and will continue to govern our relationship with you. We advise that you check this page often, referring to the date of the last modification on the page. We will also try to notify you of any material changes which could be done via email associated with your account or service notification. By continuing to use our Services after the changes become effective, you agree to be bound by the revised Privacy Policy.