Paystack Payments Limited, (“Paystack”, “Company”, “we”, “us” or “our”) offers an online payment platform that makes it easy for Merchants to accept electronic payments from Customers. Paystack values the privacy of Merchants who use our website and all related sites, applications, services and tools (collectively, our “Services”).This Privacy Policy describes how we collect, use, store, share, and protect personal data from Merchants who engage with our Services.

The Services are primarily intended for and provided to businesses and other organisations (“Merchants”), and not individual consumers. Thus, we generally process personal data at the direction of and on behalf of Merchants. When we do, we do so as a service provider or a “data processor” to those Merchants, but we do not control and are not responsible for the privacy practices of those Merchants. If you are a Customer of a Paystack Merchant, you should read that Merchant’s privacy policy and direct any privacy inquiries to that Merchant.

This Privacy Policy does not apply to services that are not owned or controlled by Paystack, including third-party websites and the services of other Paystack Merchants. This Privacy Policy applies to all forms of systems, operations and processes within the Paystack environment that involve the processing of personal data. Paystack is a Stripe company; for more information about Stripe’s privacy practices, see the Stripe Privacy Policy https://stripe.com/en-gb/privacy.

By using or accessing our Services, you agree to the collection, use, and disclosure of your personal data as described in this Privacy Policy. Your use of our Services is also subject to Paystack’s Terms. Should you disagree to abide by such Terms, or if you revoke your consent to the processing of your personal data, your account will be disabled and you will no longer be able to access or interact with the Paystack platform.

1. The Information We Collect

1.1 Personal Data You Provide Directly

We collect personal data you provide to us. For example:

• Registration information. To gain full access to our website and services, you must register for a Paystack account. When you register for an account, we collect business data and personal data, which you voluntarily provide to us in order to complete the KYC (Know Your Customer) process (e.g. email address, bank details, name, telephone number). With your consent, we may also collect additional personal data such as survey responses.
• Payment information. If you make a financial transaction, we collect credit card numbers, financial account information, and other payment details.
• Communications. If you contact us directly, for example with an inquiry or a support request, we may receive additional personal data about you, including your email address and the content of your communications.

1.2 Personal Data We Collect Automatically

• Device Information. We receive information about the device and software you use to access our Services, including internet protocol (IP) address, web browser type, operating system version, and device identifiers.
• Usage Information. To help us understand how you use our Services, including the Demo portion of our website, and to help us improve them, we automatically receive information about your interactions with our Services. This information includes records of your transactions and information about your other activities related to our services.such as date and time of your sessions, the pages you view, links to/from any page, and time spent in a session. Some of the data we gather through the use of cookies and similar technologies as discussed below.
• Location Information. When you use our Services, we may collect or infer your general location information. For example, your IP address may indicate your general geographic region.

1.3 Personal Data That We Receive from Others or Infer

• Partners. We may retrieve additional personal data about you from third parties and other identification/verification services such as your financial institution and payment processor. We may combine that data with other information we have about you.
• Publicly available sources. Public sources of information such as open government databases.
• Inferences. We may infer additional Personal Data based on the Personal Data described above. For example, for Visitors, we may infer your interests based on the web pages you view.

When you are asked to provide personal data, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional.

2. How We Use Personal Data

We use the personal data we collect to:

1. Provide you with the required services
2. Respond to your questions or requests
3. Improve features, website content and analyse data to develop products and services
4. Address inappropriate use of our website
5. Prevent, detect and manage risk against fraud and illegal activities using internal and third party screening tools
6. Send you marketing content, newsletters and service updates curated by Paystack, 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 Paystack’s statutory obligations using internal and third party tools
8. Maintain up-to-date records of Merchants
9. Resolve disputes that may arise, including investigations by law enforcement or regulatory bodies
10. Any other purpose that we disclose to you in the course of providing Paystack services to you

3. How We Share The Personal Data You Provide

Paystack does not sell, trade or rent personal data to anyone. Further, we will not share or disclose your personal data with a third party without your consent except as necessary to provide the Services or as described in this Privacy Policy.

• Service providers. We share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we’ve hired to provide customer service support, to assist in protecting and securing our systems and services, or to perform sanctions screening and identity verification services may need access to personal data to provide those functions. The processing by such third parties shall be governed by a written contract with Paystack to ensure adequate protection and security measures are put in place for the protection of personal data in accordance with the terms of this Privacy Policy.
• Financial services & payment processing. When you provide payment data, we will share payment and transactional data with banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, or other related financial services.
• Affiliates. We enable access to personal data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access is needed to provide our services and operate our business.
• Corporate transactions. We may disclose personal data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
• Legal and law enforcement. We may access, disclose, and preserve personal data in accordance with applicable law and when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
• Security, safety, and protecting rights. We will disclose personal data if we believe it is necessary to:
  • protect our merchants and others, for example to prevent fraud, or to help prevent the loss of life or serious injury of anyone;
  • operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or
  • protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies.

Third party analytics and advertising companies also collect personal data through our website and apps including, marketing and communications data, demographic data, content and files, geolocation data, usage data, and inferences associated with identifiers and device information (such as cookie IDs, device IDs, and IP address) as described in the Cookies section of this statement. These third party vendors may combine this data across multiple sites to improve analytics for their own purpose and others. For example, we use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners.

Please note that some of our services include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, or allow us to share personal data with them, that data is governed by their privacy statements.

Finally, we may share de-identified information in accordance with applicable law.

4. Cookies

We and our partners use cookies and similar technologies on our website to help collect information and operate the site. We use cookies to: remember visitors to our website; make your user experience easier; customise our services, content and advertising; help you ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our website. Cookies are small text files placed by a website and stored by your browser on your device.

Our cookies hold a unique random reference to you so that once you visit the site we can recognise who you are and provide certain content to you.

Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this may impact your experience using our website.

5. How We Protect Your Information

Paystack has established adequate technical and organisational controls to protect the integrity and confidentiality of your Personal Information, both in digital and physical format, whilst preventing Personal Information from being accidentally or deliberately compromised.

Paystack is committed to managing your Personal Information in line with best practices. We protect your Personal Information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration, we also use industry recommended security protocols to safeguard your Personal 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 Personal Information to only employees who require it to fulfil their job responsibilities.

In compliance with the Payment Card Industry Data Security Standard (PCI DSS Requirements”), we implement access control measures, security protocols and standards including the use of encryption and firewall technologies to ensure your card information is safe and secure in our servers, additionally, we implement periodical security updates to ensure that our security infrastructures are in compliance with reasonable industry standards.

Paystack also maintains a data breach procedure in order to deal with incidents concerning Personal Information or practices leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Information transmitted, stored or otherwise processed. You may contact our DPO upon becoming aware of any breach of Personal Information or if your access credentials have been compromised, to enable us to take the necessary steps towards ensuring the security of your Personal Information or account. We will report any breaches that will compromise your rights and freedoms to the Relevant Authority within 72 hours of discovery.

6. Storage Limitation

We will retain your information for the following periods:

• As long as reasonably necessary for the purpose of providing our services to you
• For the duration your account is active and we have your consent
• For the period needed to comply with our legal and statutory obligations
• As needed to verify your information with a financial institution

Paystack is statutorily obliged to retain the data you provide in order to process transactions, ensure settlements, make refunds, identify fraud and to comply with applicable laws and regulatory guidelines.

Under the Central Bank of Nigeria’s Regulations and Guidelines we are mandated to retain transactional records (customer and beneficiary names, addresses, identification number, amount, currency etc.) for at least seven years following the completion of the transaction.

Therefore, even after closing your Paystack account, we will retain certain personal data and transaction data to comply with these obligations. All personal data shall be destroyed by Paystack where possible, or anonymised in other instances.

The length of storage of personal data shall, amongst other things, be determined by:

• The contract terms agreed between Paystack and the Merchant or as long as it is needed for the purpose for which it was obtained; or
• Whether the transaction or relationship has statutory implication or a required retention period; or
• Whether there is an express request for deletion of Personal Data by the Merchant, provided that such request will only be treated where the Data Subject is not under any investigation which may require Paystack to retain such Personal Data or there is no subsisting contractual arrangement with the Data Subject that would require the processing of the Personal Data; or
• Whether Paystack has another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.

7. Transfer of Personal Data

As part of our service provision, we may rely on third-party servers, databases co-located with hosting providers, resident in foreign jurisdictions, which constitutes the transfer of your personal data to computers or servers in foreign countries. We take steps designed to ensure that the data we collect under this Privacy Policy is processed and protected according to the provisions of this Policy and applicable law wherever the data is located.

Where personal data is to be transferred to a country outside Nigeria, Paystack shall put adequate measures in place to ensure the security of such Personal Information. Any transfer of Personal Information out of Nigeria will be in accordance with the provisions of relevant data protection regulations. In particular, Paystack shall, among other things, use contractual terms to ensure protection of the data or ensure the country has adequate data protection laws (i.e. listed in the National Information Technology Development Agency’s [“NITDA”] White List of Countries, or the General Data Protection Regulation’s [“GDPR”] Adequacy List).

Should you wish to transfer personal data to a country deemed to have inadequate data protection laws, Paystack will take all necessary steps to ensure that informed consent is obtained from you, and you are aware of the risks entailed with such transfer. In any instance, Paystack will ensure Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred abroad, and details of the basis of such transfers shall be provided to you upon request.

8. Grounds for Processing of Personal Information

Processing of Personal Information by Paystack shall be lawful if at least one of the following applies:

• The Data Subject (Merchant or Merchant representative) has given consent to the processing of his/her Personal Information for one or more specific purposes;
• The processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation to which Paystack is subject;
• Processing is necessary in order to protect the vital interests of the Data Subject or of another natural person; and
• Processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in Paystack.

9. Choices and Rights

Merchants with Personal Information held by Paystack are entitled to the following rights:

• Right to request for and access any Personal Information collected and stored by Paystack;
• Right to be informed regarding their Personal Information;
• Right to object to automated decision making and processing;
• Right to request rectification and modification of Personal Information which Paystack keeps;
• Right to request the deletion of their data;
• Right to request the movement of data from Paystack to a third party – this is the right to the portability of data;
• Right to revoke consent;
• Right to object to direct marketing, and to request that Paystack restricts the processing of their information; and
• Right to submit a complaint to the National Information Technology Development Agency (NITDA).

Your request will be reviewed and answered by Paystack’s Data Protection Officer within a 30-day period. You may review your account settings and update your Personal Information directly or by contacting us.

10. Policy Violations

Any violation of this Privacy Policy should be brought to the attention of the Data Protection Officer (details below) for appropriate sanctioning and treatment.

You certify that the information provided to register as a Merchant is correct to the best of your knowledge. Furthermore, when providing the personal data of any other person, you confirm that you are only providing accurate and up-to-date data in accordance with their instructions, and are able to provide evidence of their consent to the data processing described in this Policy as and when required by Paystack. Please note that any attempt to mislead may result in prosecution and the deliberate provision of inaccurate data results in a privacy violation.

11. Changes to This Privacy Policy

We may need to update, modify or amend our Privacy Policy as our technology evolves and as required by law. If we materially change the ways in which we use or share personal data previously collected from you through our Services, we will provide notice or obtain consent regarding such changes as may be required by law. The Privacy Policy will apply from the effective date provided on our website.

12. Contact Paystack’s Data Protection Officer (DPO)

If you have any questions relating to this Privacy Policy, complaints or would like to find out more about exercising your data privacy rights, please reach out to our DPO via email at dpo@paystack.com.

For any further queries, our Data Protection Officer, may be reached at the following address:

126 Joel Ogunnaike Street,
Ikeja GRA, Ikeja,
Lagos, Nigeria.