Privacy Policy

Introduction
We are Swifno Limited (“Swifno”), a company incorporated under the laws of Nigeria with its registered office at Suite 45 Swift Plaza, No. 20 Agunwa Aniekwe Street, Wuye District, Abuja, FCT. For any access request, questions, or inquiries about how we use your Personal Data and our privacy practices, please contact us at info@swifno.com

Overview
Swifno Limited and its affiliates (“we”, “us”, “our” collectively, “Swifno”) is committed to protecting the rights and privacy of individuals in accordance with the Data Protection Legislation. This Privacy Policy describes how we collect and process your personal information through your use of our website (the “site”) and your online account you open with us (the “Account”), to create your Account profile as a customer or courier, to ensure security of the website and to enable you to use the products and the Account (collectively the “Services”).This Privacy Policy is applicable to all Swifno Services accessed by you. Please note this Privacy Policy will be agreed between you and Swifno (hereinafter "We", "Us" or "Our", if applicable). We may periodically make changes to this Privacy Policy and notify you of these changes by publishing the modified terms on our platforms. We recommend that you review this Privacy Policy regularly.

Personal Data We May Collect About You
We may collect, use or process Personal data such as:
Identity Data: Information such as; your full name, email address, phone number, gender, postal address, language and your date of birth. This data is to enable us to verify your identity in order to offer our Services to you. You may give us additional information that qualifies as Personal Data as part of your use of the Account and/or any of the Services. ·

Log/Technical Data: When you access Swifno Services, our servers automatically record information that your browser sends whenever you visit a website, links you have clicked on, length of visit on certain pages, unique device identifier, information on your page interaction (e.g., scrolls and clicks), log-in information, internet protocol (IP) address, location and other device details.

Transactional Data: This is information relating to a payment or transaction when you as a user (using one or more of our payment processing Services) are using our products or Services.

Marketing and Communications Data: This includes both a record of your decision to subscribe to or withdraw from receiving marketing materials from us or from our third parties. This also includes the content of your communication with us through mobile calls, call recordings, online chats or other means of communication.

Records of your discussions with us, if we contact you and if you contact us.

Cookie Collection: We automatically receive and store certain types of information whenever you interact with our website. We utilize cookies to provide a better customer experience and to enable use of access on our portals. For example, like many websites, we use "cookies," and other unique identifiers and we obtain certain types of information when your Web browser or device accesses our Services. Refer to your Web browser cookies setting options for more information how to manage your cookies settings. Please note that we may not be able to provide you with all the site features and Services functionalities should you choose not to accept the use of certain types of cookies preferences. Please refer to our cookie policy.

We may also collect, store, use and transfer non-Personal Data or anonymized data such as statistical or demographic data.As a principle, we do not collect any Sensitive Personal Data. However, if we do collect any Sensitive Personal Data, we will ensure compliance with the Data Protection Legislation.This Privacy Policy applies to Swifno Services only. We do not exercise control over the sites displayed or linked from within our various Services. These other sites may place their own cookies, plug-ins or other files on your computer, collect data or solicit personal information from you. Swifno does not control these third-party websites and we are not responsible for their privacy statements. Please consult such third parties’ privacy statements and set appropriate controls from your settings when using any third-party services.

How We Get Your Personal Data & Why We Have It
The Personal Data we have about you is directly made available to us when you:

Sign up or register to use a Swifno Account.
Use any of our Services; online/offline.
Contact our customer support team or correspond with us.
Fill in our online forms or respond to surveys.
Apply for employment opportunities we advertise.
Contact us for other reasons.

We may also receive personal information from online vendors and service providers, and from customer lists lawfully acquired from third-party suppliers. In addition, we may use the services of third-party service suppliers for technical support of your online transactions and for maintaining your account. We will have access to any information you provide to such suppliers, service providers, and third-party e-commerce services. We will use the Personal Information in accordance with the provisions of this Privacy Policy. This information will be disclosed to third parties outside the company only in accordance with this Privacy Policy and the legislation of your state.

The Legal Basis For Using Your Personal Data
The legal basis we rely on for processing your Personal Data are:
Your consent: Where you agree to us collecting and using your Personal Data.

We have a contractual obligation: Without your Personal Data, we cannot provide our Services to you.

We have a legal obligation: We have a legal obligation and responsibility to act in compliance with applicable laws, legislations and regulations to prevent fraud by verifying your identity, terrorism financing, proliferation financing and money laundering. To ensure we are fully compliant with all applicable financial legislations such as Anti-Money Laundering and Counter Terrorist Financing Laws, we must collect and store your Personal Data.

We have a legitimate interest: In certain instances, and as permitted by law, we may rely on legitimate interests in our business to process your Personal Data. These may include sharing your data with our affiliates, or protecting against fraud by checking your identity before providing you with a service.

How We May Use Your Personal Data
We may use your Personal Data that we collect to:

Use of Swifno products and your Account: We use your Personal Data or information such as your name, email address, phone number to set up your account, verify your identity, process your requests, process payments to and from your Account and communicate with you about our; products, services, and promotional offers. The above processing is required and necessary to enable us provide our Services to you in accordance with our terms and conditions.

Provide, troubleshoot, and improve the Service: We use your Personal information to provide functionality, analyse performance, fix errors, and improve the ability and effectiveness of the Services. This processing is required for the purpose of our legitimate interests.

Recommendations: We may use your Personal information to recommend features, products, and services that might be of interest to you and to identify your preferences. We use your personal information to provide and suggest tailored content to personalise your experiences with our Services. This processing is necessary for the purpose of our legitimate interest in delivering or presenting relevant contents to our customers.

Comply with legal and contractual requirements: We are required to utilise and retain personal information for legal and compliance purposes, including but not restricted to prevention, detection, or investigation of a crime; or fraudulent acts. In relation to internal and external audit obligations, information security purposes, and as required to provide such information under applicable law.

Communicate with you: We use your personal information to communicate with you in relation to the Services via different channels (e.g., by phone, email, chat).

Advertising: Subject to any preferences you have chosen (where applicable), we may use your personal information to display interest-based ads for features, products, and services that might be of interest to you. During the period of our contractual and legal obligations in relation to your information and unless specifically instructed otherwise by you, for a reasonable period of time after the contractual relationship has ended in order to inform you about our products, services, promotions and special offers which we think may be of interest to you. Except where we use your information for marketing purposes on the basis of your prior written consent and subject to any opt out preferences you inform us in relation to electronic direct marketing communications, we process personal information for marketing purposes as required for the purpose of our legitimate interests in promoting our services and products.

Fraud Prevention: We process information to prevent or detect fraud and abuse in order to protect the security of our customers, couriers, and others.

Risk Management: To provide the services and products for you and for our legitimate purposes, we process personal data to manage and evaluate risks to our business and customers.

Use data analytics to improve our website, products or Services, user experience and to optimize our Services.

How Long we keep your information: We will keep your information on our database for as long as it is strictly necessary for the purpose of which the information is collected, being the period during which we are contracted to provide you with our services or for such longer periods as required under enabling laws, and also in accordance with tax obligations.

For other purposes, for which we provide specific notices at the time of collection.

Your Data Protection Rights
By virtue of the Data Protection Legislation, below are the rights you have as a User in relation to your Personal Data:

Right to be informed on how we process your data. This Privacy Policy explains our privacy practices.

Right to request for access to all or copies of your Personal Data by signing into your Account or contacting us. We will not give you any personal data we hold on other individuals.

Right to request that Swifno delete or erase your Personal Data. Please note that this is a limited right which applies where the continued processing of your Personal Data has no legal justification. The exceptions to this right is, where the applicable law requires Swifno as a regulated supply chain and logistics organisation, to retain a historical archive of your personal data to fulfil regulatory requirements or where we retain a core set of your personal data to ensure we do not inadvertently contact you in future, where you object to your data being used for marketing purposes.

Right to correct or rectify any Personal Data that you provide which may be incorrect, out of date or inaccurate. You also have the right to ask us to update information you think is incomplete or outdated.

Right to opt-out of direct marketing. You have a right to ask us not to contact you for marketing purposes by adjusting your notification preferences on the settings page of our Sites or by opting out via the unsubscribe link in marketing emails we send you.

Right to object to processing: You have the right to object to or restrict the processing of your Personal Data in certain circumstances. Please note that where you object to or restrict us from processing your Personal Data, we might be unable to provide our Services to you.

Right to withdraw your consent where you had previously given the same.

Right to not be subject to a decision based solely on automated processing.

Right to request that we move or transfer your Personal Data across different Services we provide, or have it moved or transferred from us to another company in a structured, commonly used and machine-readable format. The exception to this right is where your request is not technically feasible or possible.

You can exercise your rights at no cost. However, we are permitted by law to refuse your request or charge a reasonable fee where your request is excessive, manifestly unfounded or would impose unreasonable costs on us. If we decide to charge a fee, we will inform you before treating your request.If you wish to exercise any of your rights set out above, please contact us at info@swifno.com. Where we are unsure of your identity, we might ask you for proof of your identity for security reasons, before dealing with your request. Where a third-party exercise any of these rights on your behalf, we would need sufficient proof that you have authorized them to act on your behalf.

Disclosing Your Personal Data
We may disclose or share your Personal Data with third parties as may be reasonably necessary for the purposes set out in this Notice. We share Personal Data with external third parties in the following limited circumstances:

We provide such information to our subsidiaries or affiliated entities for the purpose of processing Personal Data on our behalf. We require that these parties agree to process such information based on our instructions, implement appropriate confidentiality and security measures and comply with the Data Protection Legislation.

We share your data with our third-party providers or service providers, financial partners or suppliers for the purpose of effectively providing our Services to you. These services include identity verification and fraud prevention, customer service and support, analytics, payment facilitation by our banking and financial service partners including the card networks, communication service providers and information technology services.

We may share your Personal Data to comply with a subpoena, court order, summons, police or other law enforcement agencies, regulatory requests (which may be outside your country of residence) or as required by law.

We may share your Personal data where disclosure is reasonably necessary to:

Satisfy any applicable law, regulation, legal process or enforceable governmental request;
Detect or prevent fraud including investigation of potential violations to our Terms of Service;
Detect, prevent, or otherwise address security or technical issues, or;
Protect against imminent harm to the rights, property or safety of Swifno, its Users or the public as required or permitted by law.
We have your consent. In some instances, we may provide a service through a third party, which would require us to share your Personal Data to third parties authorised by you to receive such Information. The use of your Personal Data by an authorised third party is subject to the third party's Privacy Policy and Swifno shall bear no liability for any breach which may arise from such authorization by you.
If Swifno becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we may share your Personal Data with parties involved in the transaction and any entity that acquires our business will continue to process your Personal Data in line with this Privacy Policy, or a revised version that we will communicate to you.

Data Security & Retention
The security of your Personal Data is important to Swifno. We are committed to protecting the information we collect. We maintain administrative, technical and physical controls designed to protect the Personal Data you provide, or we collect against loss or theft, as well as against any unauthorised access, risk of loss, disclosure, copying, misuse or modification.Other security measures include but are not limited to, secure servers, firewalls, data encryption and granting access only to specific employees in order to fulfil their job responsibilities.When you use any of your Services, we implore you to always use strong passwords (a combination of letters, numbers, upper and lower cases and special characters), enable two-factor authentication on your Accounts, ensure you do not share your password with anyone, and that your login credentials are kept confidential at all times.We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of your Personal Data is protected and maintained. We would take all reasonable steps to ensure that your Personal Data is secured and well protected.We will only retain Personal Data on our servers for as long as is reasonably necessary as long as we are providing Services to you. If you close your Account, your data is stored on our servers to the extent necessary to comply with regulatory and Anti-Money Laundering obligations and for the purpose of fraud monitoring, detection and prevention. Where we retain your Personal Data, we do so in compliance with limitation periods or retention obligations imposed by applicable law.

Marketing
We may process your Personal Data in order to contact you or send you marketing content and communication about our products and services, Services or surveys, where we have obtained your consent. You may exercise your right to object to such contact from us or opt out from the marketing communication. Please note however that if you opt-out of marketing content, we may still send you messages relating to transactions and our Services, related to our ongoing business relationship.We may ask you for permission to send notifications to you. Our Services will still work if you do not grant us consent to send you notifications.

Cookies
Like many other websites, we use cookies to distinguish you from other Users, to measure your engagement with our website and to customise and improve our Services. Depending on how you manage your cookies settings and preferences, we may place cookies on your device when you visit our website. We will only place advertising and analytics cookies if you consent or accept these cookies. Some browsers may automatically accept cookies, while some can be modified to decline cookies or alert you when a website wants to place a cookie on your computer. If you do choose to disable non-essential cookies, it may limit your ability to get a full experience of our website.

Minors
Swifno products and services are not directed at persons under the age of eighteen (18) and we do not collect any Personal Data knowingly or directly from individuals who fall within this category. Any minor who is found using the services of Swifno shall have his/her Account immediately blocked. Swifno reserves the right to conduct a security review to validate your identity and age. Registration of the Account authorises us to conduct such security reviews supplied by you against third party databases.Where you have any belief that Swifno has mistakenly or unknowingly collected information from a minor, please contact us to enable us to investigate and restrict such data collection.

Updates to Our Privacy Policy
From time to time, we may change, amend or review this Privacy Policy to reflect new Services or changes and place any updates on this page. All changes made will be posted on this page and where changes will materially affect you, we will notify you of this change by placing a notice online, on your Swifno dashboard or by email.

Contact Us
Swifno Limited has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Protection Legislation. To exercise your rights or if you have any inquiries, comments or concerns with our privacy practices, please contact us at info@swifno.com. We will investigate and work on resolutions for your concerns within thirty (30) days and/or in accordance with the Data.

Protection Legislation
Where we require more time to resolve your inquiry, we would communicate with you. We may request additional details from you regarding your inquiries and keep records of your requests and resolution.

Legal Disclaimer
We are not responsible for events beyond our direct control. Due to the complex and ever-changing nature of our technologies and business, we provide comprehensive, but we do not guarantee an error-free, operation regarding the confidentiality of your personal information when you visit other websites using links located on our website. Websites that are beyond our control, and especially not covered by this Privacy Policy, should provide you with an opportunity to familiarize yourself with their security policies. If you visit other websites, you should be aware that the operators of these websites can collect your personal information, which they will use in accordance with their privacy policy, which will differ from ours.Be careful, we do not guarantee the security of your data, while it is being transmitted through channels of communication.
ANY DATA, WHICH YOU SEND, IS SENT AT YOUR OWN RISK. We are also not responsible for any direct or indirect damage arising from the unlawful use or theft of your Personal Information.

Consent To Privacy Policy
Your use of our services is your voluntary agreement with our Privacy Policy and you thereby give us the right to collect, process, and store your personal data. This Privacy Policy should be read in conjunction with our Terms and Conditions and any additional applicable Terms and Conditions published on our platforms and websites. We may periodically make changes to this Privacy Policy and will notify you of these changes by publishing the modified terms on our platforms and websites. Your continued use of our services following any changes to this Privacy Policy constitutes your acceptance of the changes. This is our entire and exclusive Privacy Policy on March 26, 2025, it supersedes any earlier version and applies only to Swifno. We recommend that you revisit this Privacy Policy regularly.

Definitions
Account: means a profile created by a User on the Swifno platform or any Swifno product.

Cookies: A cookie is a small data file that is transferred to your computer or mobile device. It enables us to remember your account log-in information, IP addresses, web traffic, number of times you visit, browser type and version, device details, date and time of visits.

Data Protection Legislation: means the Nigeria Data Protection Act 2023, Nigeria Data Protection Regulation 2019 and/or any other applicable legislation on the protection of personal data in Nigeria.

Personal Data: Any information that can be used to identify a living or natural person including email address, date of birth, mobile number, residential address, payment card, financial information such as bank account number, etc.), government-issued Identity credentials (e.g., national ID number, international passport, driver’s licence number, etc), or taxpayer identification number. It may also include information that is linked to you, for example, your internet protocol (IP) address, log-in information, information about your device or device’s web browser.

Services: means any products, applications, features, related websites, tools, software, offerings or any service offered by Swifno to you or accessed by you.

Sites: means any platform including but not limited to mobile applications, websites and social media platforms.

User: means an entity (“merchant/courier”) or individual, who uses the Services or accesses the Sites, and has agreed to use the end services of Swifno Limited.

Sensitive Personal Data: means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic, biometric data or any other category defined from time to time by the applicable Data Protection Legislation.

This Privacy Policy was last updated in March 2025.

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