Introduction
DeeX[1] (“We”, “Our”, “DeeX[2] ”) is a technology company providing a range of services including facilitation of access to cryptoassets and other virtual financial services (“Services”) through our website, software application, point-of-sale channels and other medium (“Platform”).
We strive to maintain transparency of our Services to our customers (“Customers”, “You”, “Your”) on what kinds of data we collect, how we collect the data, what we do with the data we collect and the rights of our customers as our data subjects. We have covered these in simple terms under this Privacy Notice.
If you have any questions or want us to clarify any part of this privacy notice, you may send us an email with privacy@deexoptions.com and we will certainly respond to your query.
Version Control
We may make changes to this Privacy Notice from time to time to reflect the changes to our Platform, Services or our business. Such changes or revision shall be effective immediately upon posting it on our Platform.
We will provide you notice of such changes, by indicating the Last Revised Date on our Platform. Your continued use of our Services after such revision, shall constitute your acceptance of the Notice.
If you do not agree to the Notice as at the Last Revised Date, you may speak to our privacy contact via privacy@deexoptions.com .
Authorisation
By accessing or using our Services, or otherwise assenting to this Privacy Notice, you signify that you have read, understood and agreed to our collection, storage, use and disclosure of your personal information as described in this Privacy Notice and our Terms of Use.
What kind of information do we collect from you?
When you use or apply to use any of our services hosted on any of our platforms, we may collect some personal data and other information from you to aid the provision of our services. We have categorized them below;
1. Personal data
1. Personal data
We may collect any one or more of the following information at the point of onboarding or during the course of the provision of our services to you;
i. Full name
ii. Address
iii. Email Address
iv. Mobile phone number
v. Sim card
vi. Bank Verification Number (BVN)
vii. National ID Number/Passport number or Business Registration Number
viii. Username
ix. Date of birth and agex. Source of income/employment status
xi. Information relating to finance and credit, information about your bank account number or other banking information.
xii. Personal description and photograph.
xiii. Password and any other information required during the registration process.
xiv. Transaction information.
xv. Bank accounts
xvi. Your contact with us such as when you call us or interact with us through the app, email, social media etc.
2. Technical datai. Full name
ii. Address
iii. Email Address
iv. Mobile phone number
v. Sim card
vi. Bank Verification Number (BVN)
vii. National ID Number/Passport number or Business Registration Number
viii. Username
ix. Date of birth and agex. Source of income/employment status
xi. Information relating to finance and credit, information about your bank account number or other banking information.
xii. Personal description and photograph.
xiii. Password and any other information required during the registration process.
xiv. Transaction information.
xv. Bank accounts
xvi. Your contact with us such as when you call us or interact with us through the app, email, social media etc.
Aside from your personal data, we may collect any one or more of the foilowing technical data to help us comply with applicable laws, provide our Services to you, resolve your complaint etc.;
i. GPS and location information to help confirm and verify your exact location while using our services.
ii. Information from third party databases such as the BVN database, Independent National Electoral Commission (INEC) database, National Identity Card database, relevant fraud databases etc.
iii. Tracking data and cookies in accordance with our Cookie policy.
iv. information of a technical nature, to include the type of mobile device used by you, unique device identifiers (such as the Device’s IMEI or serial number), SIM card information, mobile network information, the user’s device operating system, the browser which is being utilized by the user, the location of the Device and its time zone setting (Device information).
v. information relating to the your use of DeeX’s Platform or any visits by the user to any of our websites. This includes but is not limited to location data, traffic data, weblogs and other data (Log information)
3. Pseudonymous datai. GPS and location information to help confirm and verify your exact location while using our services.
ii. Information from third party databases such as the BVN database, Independent National Electoral Commission (INEC) database, National Identity Card database, relevant fraud databases etc.
iii. Tracking data and cookies in accordance with our Cookie policy.
iv. information of a technical nature, to include the type of mobile device used by you, unique device identifiers (such as the Device’s IMEI or serial number), SIM card information, mobile network information, the user’s device operating system, the browser which is being utilized by the user, the location of the Device and its time zone setting (Device information).
v. information relating to the your use of DeeX’s Platform or any visits by the user to any of our websites. This includes but is not limited to location data, traffic data, weblogs and other data (Log information)
The blockchain is not anonymous. Records of transactions on it are publicly available on blockchain explorers. However, your wallet addresses are pseudonymous. We may collect your wallet address to make necessary deposits, payment reconciliations, or other DeeX services you are subscribed to. Rest assured that we will take necessary measures to keep it safe where you provide it to us.
What information is the app Collecting using True Depth API?
The app uses True Depth API to position Holograms in selfie mode only.
1. For what Purpose is the Information Collected?
1. For what Purpose is the Information Collected?
The selfie is required for compliance, to authenticate and verify the identity of the user for fraud reduction.
2. Will this data be shared with third parties? Where will this information be Stored?The data is not stored or set to any other devices, so it's not shared with 3rd parties. None of this information collected by the TrueDepth API ever leaves the user's device, and it is not permanently stored on the Device.
3. Where in the private Policy is the app's collection, use, disclosure, or sharing and retention of face data explained? Identify the specific sections in your privacy section where this information is located?We don't share users personal data within our app.
How do we collect your personal data?
DeeX will collect information through;
a. 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;
b. Correspondence with DeeX, by email or instant message or chat, or other means of communication.
b. Correspondence with DeeX, by email or instant message or chat, or other means of communication.
1. Our web application or related software applications on the google play store or the ios app store when you;
i. Download or register on our app;
ii. Share data when subscribing to any of DeeX’s Services e.g email marketing, market price reports, etc.
iii. Share data through our application’s social media capabilities;
iv. enter a competition, promotion, or survey hosted by DeeX or any of our partners;
v. when you decide to report a problem with our application or any of our Services, any of our websites. etc.
i. Download or register on our app;
ii. Share data when subscribing to any of DeeX’s Services e.g email marketing, market price reports, etc.
iii. Share data through our application’s social media capabilities;
iv. enter a competition, promotion, or survey hosted by DeeX or any of our partners;
v. when you decide to report a problem with our application or any of our Services, any of our websites. etc.
Why we collect your data and how we use the data we collect?
Some of the reasons why we collect the data we collect are summarised below;
1. Performance of our service
If you need to know more specifically why we collect a specific type of data from you, you may reach out to us via privacy@deexoptions.com with a request and we will explain it clearly to you.
1. Performance of our service
We collect your data to enable the ease of provision of our services to you. For instance, your data is used to help us do any of the following;
i. To facilitate your access to DeeX products and Services for as long as you maintain an account;
ii. To take a decision on whether to onboard you to our Platform;
iii. To respond to any of your queries or concerns;
iv. To validate your device to enable you access the services;
v. To understand your device usage to facilitate our anti-fraud checks;
vi. To bill you and address appropriately such bill for using our services;
vii. To ensure quality control and maintain optimal system operations;
viii. We may also combine categories of information with any other category of information that we see fit. When we do this, we will treat the combined information as personal data in accordance with this notice and our internal privacy policy.
2. Compliance with the lawi. To facilitate your access to DeeX products and Services for as long as you maintain an account;
ii. To take a decision on whether to onboard you to our Platform;
iii. To respond to any of your queries or concerns;
iv. To validate your device to enable you access the services;
v. To understand your device usage to facilitate our anti-fraud checks;
vi. To bill you and address appropriately such bill for using our services;
vii. To ensure quality control and maintain optimal system operations;
viii. We may also combine categories of information with any other category of information that we see fit. When we do this, we will treat the combined information as personal data in accordance with this notice and our internal privacy policy.
We are a company operating out of Nigeria. For this reason, we are bound to comply with a range of laws applicable to our services. This includes the Money Laundering (Prevention and Prohibition) Act, Cybercrimes Prevention Act etc. which mandates us to carry out some processing of your data including the following;
i. collect identification information from you and store it for a certain period.
ii. verify your identity information through publicly available and/or restricted government databases in order to comply with applicable regulatory requirements.
iii. Share your information with approved third party or law enforcement agencies, where appropriate.
i. collect identification information from you and store it for a certain period.
ii. verify your identity information through publicly available and/or restricted government databases in order to comply with applicable regulatory requirements.
iii. Share your information with approved third party or law enforcement agencies, where appropriate.
If you need to know more specifically why we collect a specific type of data from you, you may reach out to us via privacy@deexoptions.com with a request and we will explain it clearly to you.
What are the lawful basis for our processing of your data?
Under the Nigerian Data Protection Regulations 2019 (NDPR), we are required to process your data under one or more basis of the law. At DeeX, our lawful bases for processing of your personal data includes any one or more of the following;
1. Compliance with our duty under the law
4. In furtherance of public interest.
5. By your consent
1. Compliance with our duty under the law
For example, we carry out KYC(Know Your Customer) and we run checks on the ID information you supply during sign up to comply with a range of anti-financial crimes laws in Nigeria.
2. Performance of our contract with youWe may also process your information on the basis that we need to fulfil our agreement with you for the provision of Services or to take steps towards fulfilling your request prior to entering the agreement.We may need to process your information to give you information about your account and other financial services we agreed to provide in line with our terms of use.
3. Legitimate business interest.4. In furtherance of public interest.
5. By your consent
Where any of the above do not apply, we wlll seek your informed consent before we carry out any processing activity on your personal data.
For how long can we retain your data?
At DeeX, we only retain personal data for as long as it is necessary to do so in line with the Data Protection Laws. This means that we retain data:
1. For as long as you continue to use our services
2 .For any period required under applicable laws.
3. For purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
4. For the purposes of any legal proceedings. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of a matter in court arising out of our relationship with you.
5. We may hold anonymized information that is no longer associated with you indefinitely.
2 .For any period required under applicable laws.
3. For purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
4. For the purposes of any legal proceedings. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of a matter in court arising out of our relationship with you.
5. We may hold anonymized information that is no longer associated with you indefinitely.
What are your rights as a data subject?
Under Nigerian data protection laws, you, as a customer of DeeX, are our data subject. You are guaranteed certain rights under these laws in relation to your data. They include;
1. The right to request confirmation of whether DeeX processes data relating to you and if so, to request a copy of such data;
2.The right to request that we erase your Personal Data in certain circumstances provided by law;
3.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;
4.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;
5. The right to withdraw your consent in accordance with this Privacy Notice,where it has been previously given;
6. The right to request that we rectify or update your Personal Data or Business Information which is inaccurate, incomplete or outdated;
2.The right to request that we erase your Personal Data in certain circumstances provided by law;
3.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;
4.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;
5. The right to withdraw your consent in accordance with this Privacy Notice,where it has been previously given;
6. The right to request that we rectify or update your Personal Data or Business Information which is inaccurate, incomplete or outdated;
How can you exercise your right?
To exercise your rights, you may go through any of the following options;
1. Data Subject Access Request portal
1. Data Subject Access Request portal
We are working on creating a direct DSAR portal to collect and organise all requests for easy response. When we finalise the portal, we will edit this to reflect the portal page. You may use any of the other options under this heading tentatively.
2. Email CorrespondenceYou may contact us through our dedicated email privacy@deex.co. [1] 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 reuesting for your own data.
3. SettingsWhere it is in relation to our software application on your device, you may control our access through the privacy settings app on your devices.
4. MarketingIf 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. We will try to comply with your request as soon as practicable;Where any of your rights as provided for under this Privacy Notice is breached, resolution shall be in accordance with the provision of our Terms of Use, provided that you can only apply for a remedy within a period of 2 years within which the breach occurred.
Changes to policy
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Data Security
In compliance with the relevant laws in force in Nigeria, we have and will implement security measures targeted towards the following;
1. Governance measures
1. Governance measures
We have and will implement further governance measures to esure proper data governance within our company. This includes the designation of a data protection contact to manage our privacy and information security
2. Technical measuresWe have and will implement technical measures such as multi-factor authentication, encryption, passwords policy and other measures to ensure that your data with us is kept secure depending on the Platform you are using.
3. Your own responsibilityWhile we have a responsibility to protect your data and we implement measures above to achieve that, please understant that there is no absolutely secure method of transmission over the internet or method of electronic storage.
You are solely responsible for the security of your login information including username, passwords, hashes, private key or other information that may be used to access your account. We will not bear responsibility where it is leaked or disclosed by reason of your negligence.
You are solely responsible for the security of your login information including username, passwords, hashes, private key or other information that may be used to access your account. We will not bear responsibility where it is leaked or disclosed by reason of your negligence.
Data Transfer
We host our data in cloud servers outside of Nigeria. In some cases, we also transfer to carry our certain compliance obligations such as identity verification. Where this is done, we will do so in accordance with our data transfers policy which includes vetting those recipients to ensure they have adequate data protection practices and are in countries with adequate data protection laws
You may object to the transfer of your data. Where there is no other lawful basis for such transfer, we will heed your request. However, please note that we may have to offboard you or restrict the services we provide to you where such request is heeded.
You may object to the transfer of your data. Where there is no other lawful basis for such transfer, we will heed your request. However, please note that we may have to offboard you or restrict the services we provide to you where such request is heeded.
Redirection to third party websites or platforms
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.
Contact us
If you have any question or request about any provision of this Privacy Notice or just any other enquiry about our privacy compliance program, please reach us via privacy@deexoptions.com
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