Disclaimer and Privacy Policy

Privacy Notice- Azero Digital Limited

Last Updated: October 2022

Azero Digital Limited and its affiliates (“AO Digital” “we” “us” “our”) are committed to attaining the highest possible standards in the value of our services and ensure the protection of our customer’s (“user” ”you” “your”) data when it is made available to us in their use of our services.

This Privacy Notice (“Notice”) describes how we collect, use and process your personal information when you access our website and mobile application (“platform”) or otherwise use our services. It outlines the nature of data we collect and the processes as well as measures we have in place for their protection.

Our Terms of Use is incorporated under this Notice and every term not defined under this Notice will have the meaning ascribed to them in our Terms of use.

By accessing and using our service you signify that you have read, understood and agreed to our collection, storage, use and disclosure of your personal information in the manner described under this Notice.

We recommend that you read this Notice carefully, to understand your rights and duties towards the protection of your data.

1. Version Control

We may make changes to this Notice from time to time to reflect the dynamics of our business practices and changes in the law. When this happens we will notify you by updating the last revised date of this Notice. All changes are effective from the date the Notice is updated.

We are committed to the protection of your data, however, it is your responsibility to stay updated on the changes we make to this Notice. If you object to any changes, you may close your account. By using our services after such modification, you consent to all changes.

1. Types of Data we collect

The category of information we collect are those which are necessary to providing our services to you and to improve the nature of our service delivery, and these are:

1. Personal data

These are unique identifiers such as your full name and email address,[1]  as well as any other additional information you may provide or additional information we may request you to provide.

1. Device Information

We may also collect information about your device such as the hardware model, operating system and version, your browser type and version, the presence of any device, browser add-ons, unique device identifiers, and mobile network information.

1. Transaction data

We collect information about automated trading enabled by our investment speculation tool, as well as the date and time of such trading for record keeping purposes

1. Financial information

We will require information about your API Keys and wallet addresses to enable our plug-ins

1. Log Data

Our servers may automatically collect information about your visit to our website or mobile application, the sites you visit before visiting our website, how you use our services, the date and time you assessed our services and language preference.

1. Location information

We may receive information from you that helps us to approximate your location, such as using an IP address received from your browser to determine an approximate location. We may also collect location information from devices in accordance with the permissions allowed by your device.

1. How we collect your data

We collect your data when you (i) visit our website (ii) sign up to use our services (iii) read our emails (iv) communicate with us through our customer support channels or otherwise engage with us.

These data become available to us when you respond to our request to make them available to us in your use of our services and we also assess them through a variety of tracking technologies including cookies, web beacons, flash objects and similar technologies (collectively “tracking technologies’ ‘). These tracking technologies help us in collecting log data, location information as well as device information. More particularly, we use tracking technologies (i) to improve your user experience, by remembering your information, so you do not have to re-enter them at every visit (ii) to identify you across multiple devices for our business and regulatory purposes (iii) monitor the effectiveness of our services (iv) monitor aggregate metrics such as total number of visitors, traffic, usage and demographic patterns on our services (v) diagnose or fix technological errors (vi) otherwise plan for and enhance our services.

We understand that you may prefer not to accept tracking technologies and if you are averse to this, depending on your browser you may: (i) Set your browser to automatically reject cookies or (ii) Disable existing cookies.

We would also notify you once you visit our platform that we make use of cookies or other tracking technologies and will provide you with the option to allow or reject cookies. Please note that by disabling cookies or other tracking technologies you may negatively impact your user experience on our platforms, as some features may not work properly.

We may make use of one or more third-party analytics services to evaluate your use of our services by compiling reports on your activities on our platform such as your IP address, ISP, amount of time spent on certain pages, and analysing performance metrics. These third party partners may also use cookies and other tracking technologies and as stated above you may be able to set your browser to delete or notify you of cookies and other tracking technologies. You also consent to the use of cookies by our third party providers by accepting this Notice.

Additionally, we also collect information from third parties such as identity verification services, public institutions as well as regulatory and enforcement agencies.

1. Why we collect and use your data

Primarily, we collect your data for our legitimate business interests and for legal and regulatory reasons, but more specifically, we collect and use your data:

1. To provide our services to you, perform obligations under our agreements and to carry our related business functions;

2. To verify you, your identity, the integrity of the data you provide and prevent fraud;

3. To determine your eligibility to use our services;

4. To comply with legal obligations and regulations applicable to our services including but not limited to “know your customer” obligations based on applicable AML/CFT requirements;

5. To develop, improve, enhance, modify add to and further develop our services;

6. To provide customer support to you or  to our platforms including responding to your inquiries related to our services or our platforms;

7. To send you technical notices , updates, security alerts and support administrative messages;

8. To investigate any misuse of our services or our platforms including criminal activities or other unauthorised access to our services;

9. To protect you, our platforms and AO Digital from fraud, malicious activity and other privacy and security-related concerns;

10. To conduct record keeping and otherwise manage our business;

11. To Conduct aggregate analysis and develop business intelligence that enables us to operate, protect, make informed decisions and report on the performance of our business

12. For any other lawful purpose, with your consent.

1. Your control over your personal data

With respect to your personal data, you have the following data privacy rights;

1. Right to know the categories of personal data we collect and to request a copy of such data

2. Right to update or rectify your personal data where they are incomplete, inaccurate or outdated

3. Right to request the deletion of your personal information subject to certain circumstances allowed under the law

4. Right to withdraw your consent from this Notice by putting a stop to your use of our services

5. Right to data portability

6. Right to request for a restriction in our collection and use of your data.

You may restrict our access to your data through implementing the permission restrictions on your device. Also, to stop receiving promotional email communications from us, you may click on the “unsubscribe link” provided in such communication. We are not responsible for your inability to stay updated on new features in our services when you unsubscribe from our mailing list.

Please be informed that your rights as set out under this Notice is subject to any restriction that may be imposed by the law.

To enforce any of these rights, you may send us an email at info@aodigital.org.[2]   We may take additional steps to verify the identity of the person making the request before acting on such request. We will endeavour to respond within a period of 48 hours and we will notify you if we need additional time.

All disputes arising out of the enforcement of these rights will be resolved in accordance with our Client Service Agreement, which is available on our website.

1. Storage of Personal data

All data collected in accordance with this Notice is kept throughout the duration of our business relationship with you and for a further period of 5 years after the termination of the business relationship, in accordance with the Nigeria Data Protection Regulation (NDPR) 2019.

We retain your information to fulfil our legal or regulatory obligations and for our business purposes. We may retain your data for longer periods than required by law if it is in our legitimate business interests and it is not prohibited by law.

All data is stored in encrypted formats in AO Digital’s database[3] .

1. Data Protection

AO Digital takes commercially reasonable, physical, administrative and technological safeguards in preserving the integrity of your data and to protect your information from loss, theft, misuse, and unauthorised access, disclosure, alteration and destruction.

We implement policies designed to protect the confidentiality and security of your nonpublic personal information, and unless otherwise specified in this Notice, we limit access to your information to employees that have a business reason to know such information.[4]

When we have reasons as covered under this Notice, to grant third party access to your data, we will ensure that they are subject to a confidentiality agreement that prevents unauthorised disclosures and ensure that they have security measures in place to guarantee the security of your data. [5]

However, no security system is impenetrable and we cannot guarantee the security of our systems or the systems of the third parties with which we may share your personal data nor can we guarantee that the personal data you supply will not be intercepted while being transmitted over the internet. We advise that you take security precautions in your use of our services.

1. Third party access[6]

The nature of our services requires that we use the services of third party vendors. However, AO Digital takes your privacy seriously and we do not sell or rent your information to marketers or other third parties. We do share your information:

1. With the third party platform you are using to have access to our services for the purpose of offering our services to you and providing customer services to you. You understand that such third party platform, may have access to all your data;

2. For our everyday business purposes such as providing investment speculation to you and maintaining your accounts;

3. With other companies that provide services to us, such as identity verification service providers, IT providers and other vendors;

4. To independent external auditors or other service providers, to support our audit, compliance and corporate governance functions;

5. In compliance with a legal obligation or in response to a request from law enforcement agencies;

6. To describe our services to current and prospective business partners and to other third parties for lawful purposes;

7. For the protection of the rights of AO Digital and for the security of our users;

8. With your consent or direction.

1. Transfer of Personal data

Personal data collected through our services may be stored and processed in Nigeria or any other country in which AO Digital or its affiliates and service providers maintain facilities. If you are located in other regions with laws governing data collection and use that may differ from Nigerian law, please note that we may transfer personal data to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you acknowledge such transfer of information to Nigeria or any other country in which AO Digital or its affiliates and service providers maintain facilities and the use and disclosure of your data as described in this Notice.

1. Third-party links

Our platform may contain links to third-party websites. Please be informed that such third parties may maintain separate privacy notices and you are advised to read such notices as they may differ significantly from that of AO Digital. We also do not accept any responsibility or liability for their policies and privacy practices.

​

1. How to Contact us

If you have any questions or inquiries concerning this Notice or our services, please contact us at info@aodigital.org