Privacy Policy

Last Updated: Oct 24, 2024

1. About this Privacy Policy

Aku Micro-Finance Bank Limited (‘we’, ‘our’, ‘us’) is an entity duly registered by the Corporate Affairs Commission and licensed by the Central Bank of Nigeria to offer Banking and Financial Services. We are committed to safeguarding the safety and privacy of users of our services. In order to ensure your continuous support and trust in the use of our services, we insist on the highest standards of practice in customer information privacy and protection.

This policy describes what information we collect about you, how we collect and use the information you share with us, and with whom we share that information when you use our services either through web or mobile device. This policy also contains information about when we share your personal information with third parties (such as our service providers and credit bureaus).

Our services are not intended for use by minors and we do not collect nor process information from users under the age of 18. Please discontinue the use of our services if you fall within this category.

This Privacy Policy is subject to change at any time. We will notify you of any changes by posting the new Privacy Policy on this page. You are therefore encouraged to review this policy periodically to be up to date on any changes that may occur.

2. Data We Collect About You

We collect your personal data in order to provide and continually improve our products and services. This depends on the services you access/use. We may collect, use, store and transfer the following different kinds of personal data about you:

Sign-up/Onboarding Information: When you register to use our services, we will collect the Personal Data necessary to on-board you; including your name, phone number, email address, account information with other banks, BVN, date of birth, gender, residential address, selfie image, other images/files(electricity bill, User Identification card, CAC Documents, etc) to enable us satisfy your eligibility for an account creation. We may require you to provide additional, necessary personal details as you use our services.
Login: We use your phone number or default biometric access to log you in.
Transactions: When you send/receive money, make purchases from merchants, pay bills, deposit & withdraw cash, we collect information about the transaction, as well as other associated information; such as: the amount sent or received, amount paid for products or services, merchant information, contact list (to select recipient phone number), information about your device and geolocation.
Participant Personal Data: When you use our services, we collect Personal Data about the other participants associated with the transaction, including your phone contacts from your contacts list, so you can easily manage account transfers and to enable instant messaging (IM). We collect Personal Data such as name and financial account information about the participant who is receiving money from (or sending money to) you.
Information from other sources: We may collect information from other sources, such as our social media platforms when you reach out to us to lodge a complaint about some our services. However, we will only ask for information relevant to the help required of us to you.
Other information we collect related to your use of our website or Services: We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.
When you apply for a job with us: We may request Personal Data about your education, employment and state of health. As part of your application, you will be asked to provide your express consent to our use of this information to assess your application and any monitoring activities which may be required of us under applicable laws as an employer.
Information you provide to us: We receive and store the information you provide to us including your identity data, contact data, delivery address and financial data.
Information on your use of our services: We automatically collect and store certain types of information regarding your use of our services including information about your searches, IP Address, device identifiers, etc.
Information from third parties and publicly available sources: We may receive information about you from third parties and other identification/verification services for KYC (Know Your Customer) and other purposes such as your financial institution and other identity verification portals.

Specific examples of the kind of Data we collect about you include the following:

- Name

- Email Address

- Phone Number

- Physical Address

- Other user contact information

- Payment information

- Other financial information

- Your Contact List

- Photos/Videos

- Audio Data

- Customer Support

- Other user content

- User ID

- Device ID

- Product Interaction on our Platform

- Crash Data

- User Performance Data

3. How we collect your data

When you register or log on to our sites, create an account, subscribe to a service, engage in any interactive features on our services, submit a form, participate in surveys, post on our message boards, upload any documentation, interact with customer support, submit an inquiry, get in touch with us via phone or email, or engage with us on social media, among other activities, we gather information that you voluntarily provide to us. Additionally, we will gather your information when you leave off or only partially complete any forms you submit on the sites. We may use this information to get in touch with you to remind you to finish any incomplete forms.

4. How We Use Your Personal Data

We use your personal data to operate, provide, develop and improve the products and services that we offer, including the following:

To manage your relationship with us.
To provide and maintain our Service, including to monitor the usage of our Service.
To manage transactions, including any in-app purchases or top-ups using real money. In compliance with Google Play's Real-Money Gambling, Games, and Contests policy;
- We only permit real-money transactions or top-up features in countries where real-money gambling is legally allowed.
- In addition, Users in regions where such activities are restricted will not have access to these features.
We also use your Device ID and User IDs for tracking purposes, push notifications, and other verification purposes to ensure that only trusted devices are able to access our platform.
To manage your registration as a user of our Service. The Personal Data you provide can give you access to different functionalities of our services that are available to you as a registered user.
To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To enable you to participate in promotions, competitions and surveys.
To improve our website, applications, products and services
To recommend/advertise products or services which may be of interest to you.
To comply with our legal and regulatory obligations, including verifying your identity where necessary.
We also use your contact information and transaction information for the purpose of printing and sharing electronic receipts via Bluetooth/Wi-Fi and other mediums. Such third-party mediums/devices are also subject to and compliant with clause 7 of this Privacy Policy.
We collect your contact list to enable you access your contacts for airtime top-up and other related transactions which you may wish to extend to members of your contact list.
To detect fraud.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

5. Basis for processing your Data

Lawful basis we rely on for processing your personal data include;

- Your consent has been given to use our Services

- Processing your personal data is required for us to deliver our services to you in accordance with our Terms and Conditions and this Privacy Policy

- Processing your information is required to enable us to remain compliant with applicable Law and Regulatory Requirements.

6. How We Share Your Personal Data

We may need to share your personal data with third parties for the following purposes:

i. With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf.

These third-party service providers may, for example, provide you with services, verify your identity, assist in processing transactions, send you advertisements for our products and services, or provide customer support. Please be assured that such third-party companies have compliant, legal measures in place to ensure the confidentiality of your Personal Data.

ii. With other financial institutions: We may share Personal Data with other financial institutions that we have partnered with to only offer Aku-related services, unless your consent extends to other uses. We may also share Personal Data to process transactions and update your financial information.

iii. With the other parties to transactions when you use the services, such as other users and their service providers. This includes other users you are sending or receiving funds from and their service providers. The information might include:

- Personal Data and account information necessary to facilitate the transaction; and

- Personal Data to help other participant(s) resolve disputes and detect and prevent fraud.

iv. Where permitted or required by law: We may share information about you with other parties for Aku's business purposes or as permitted or required by law, including:

- If we need to do so to comply with a court proceeding, other legal process or an applicable regulation;

- To law enforcement authorities or other government officials, or other third parties pursuant to a court order or other legal process or requirement applicable to Aku or an affiliated entity;

v. Where we reasonably believe that the disclosure is necessary: or appropriate to prevent an imminent physical harm or financial loss, or in connection with an investigation of suspected (or actual) illegal activity;

vi. With credit agencies and data processors: for credit reference checks and anti-fraud and compliance purposes - all in accordance to applicable data privacy regulations and laws;

vii. To investigate violations of or enforce a user agreement or other legal terms applicable to any service;

viii. To protect our property, services and legal rights;

ix. As reasonably and legally permitted, to facilitate a purchase or sale of all or part of Aku's business, or in the instance of some merger and acquisition;

x. To support our audit, compliance, and corporate governance functions.

xi. With your consent: We also will share your Personal Data and other information with your consent or direction.

7. Retention of your Personal Data

We keep your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. In other words, your personal information will only be kept for as long as it is needed to provide you with the services or if it's required by law. The nature and sensitivity of the personal data, the reasons for which we are processing it, and any applicable statutory or regulatory retention periods are all considered when determining the proper retention period for your personal data. We periodically review the personal data we have and the reasons behind its processing and retention using these standards.

In cases where real-money transactions or top-up features are involved, we retain the associated personal data in accordance with applicable data protection laws. Our retention practices are designed to ensure the security and confidentiality of your information while adhering to the legal obligations governing financial transactions.

Aku, as a regulated financial institution, will keep your personal information for ten (10) years following the termination of the relationship or for as long as necessary per regulatory requirements. Furthermore, in compliance with CBN regulation, transaction documents and data will be kept on file for a minimum of five (5) years.

Where the personal data is no longer required or beyond the required period of retention, Aku will either securely archive it while safeguarding your identity and privacy rights or delete it from its systems and records.

8. Compliance with Regional Laws

Our app complies with regional laws regarding the use of real money for gambling, contests, and in-app purchases. Certain features may be disabled or restricted based on your location, in compliance with Google Play’s Real-Money Gambling, Games, and Contests policy and local legal requirements. This ensures that all transactions and services provided within our app meet the necessary legal standards for each country.

For example, we only permit real-money transactions, top-ups, or gambling-related features in countries where such activities are legally allowed. Users in regions where real-money gambling is restricted, such as the United States, Canada, and Germany, will not have access to these features. In contrast, users in countries like Nigeria, where real-money gambling is permitted by law, will have full access to these services within the app.

We ensure that all real-money transactions and related data processing comply with the relevant regional laws and standards for data protection, ensuring that your information is handled securely and lawfully.

9. Gambling, Games, and Contests

Our app may include features that allow users to purchase in-app items, top-up their accounts, or participate in real-money games or contests.

In accordance with Google Play’s Real-Money Gambling, Games, and Contests policy, these features are only available in regions where real-money gambling is legally permitted. Users in prohibited regions will not have access to these features.

Country Restrictions: We automatically restrict the availability of any real-money gambling or top-up features in countries where such services are not allowed, including but not limited to the United States, Canada, Germany, and France. Users in countries where real-money gambling is allowed, such as Nigeria, will have access to these features in accordance with local laws.

10. Information shared with third parties

When we share your personal data with third parties, we:

- require them to agree to use your data in accordance with the terms of this Privacy Policy and in accordance with the law; and

- only permit them to process your personal data for specified purposes and in accordance with our instructions. We do not allow our third-party service providers to use your personal data for purposes other than those contained in this Policy nor for their personal use.

11. Security of your Personal Data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized manner, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. Considering that that no method of transmission over the Internet, or method of electronic storage is 100% secure, we cannot guarantee absolute security of your personal data. We have however, put in place procedures to deal with any suspected personal data breach and will notify you where we are legally required to do so.

12. Links to Other Websites

Our service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be redirected to the website of such third party. We strongly advise that you review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

13. Your Legal Rights

Under certain circumstances, you have rights under the Constitution of the Federal Republic of Nigeria (CFRN) and the Nigerian Data Protection Regulation (NDPR) in relation to your personal data, including the right to access, correct or erase your personal data, object to or restrict processing of your personal data, and unsubscribe from our emails and newsletters.

14. Changes and Updates to this Privacy policy

This Privacy Policy may be subject to modifications and amendments as the need arises. All amended versions will be posted on our website and all other platforms therefore, you are encouraged to review this policy periodically to be up to date on any changes. Updated policies take effect from the date they are posted and by continuing to use our Services, you expressly consent to any amendments of this Privacy Policy.

15. Contact Us

If you are looking for more information on how we process and protect your personal data, or you wish to exercise your legal rights in respect of your personal data, please contact us at contact@aku.africa

Our Cookie Policy

Cookies allow us to distinguish you from other users of our services. This helps us to provide you with an enhanced user experience. We use cookies to recognize your device or browser to learn more about your interests, and provide you with essential features and services and for additional purposes, including:

i. Login: This allows us to save your login information,

ii. Recognizing you when you login to use our services. This allows us to personalize your experience by providing you with customized features, recommendations and display personalized content.

iii. Keeping track of your specified preferences; This allows us to honor your selected application settings.

iv. Email Subscription: This allows us to save information you give us when you subscribe to our emails which helps us avoid duplicate subscriptions and controls the number of notifications you receive.

v. Forms: This allows us t0 to remember your user information when you fill a form on the website.

vi. Testing & Optimization; This allows us to conduct research and diagnostic exercises to determine how to improve our content, products, and services.

vii. Preventing fraudulent activity and improving security.

viii. Reporting: This allows us to measure and analyze the performance of our services.

Examples of Cookies we use:

i. Preference Cookies: We use Preference Cookies to remember your preferences and various settings

ii. Session Cookies: We use Session Cookies to operate our Service.

iii. Security Cookies: We use Security Cookies for security purposes.

iv. Third party Cookies: show you ads for things we believe you might be interested in

Third Parties

Approved third parties may also set cookies when you interact with our services. Third parties include search engines, providers of measurement and analytics services, social media networks, and advertising companies. Third parties use cookies in the process of delivering content, including ads relevant to your interests, to measure the effectiveness of their ads, and to perform services on our behalf.

Managing Cookies

You can manage/disable browser cookies via your browser settings. Please, note that disabling all cookies may affect your user experience on this website and some features and services may not work. This may require you to manually adjust some preferences every time you visit our site. Should you require additional information, please send an email to contact@aku.africa and we will reply with feedback as soon as possible.