1. Introduction
Step By Step Company (“SBS”, “We”, “us”) operating through ‘DoveKash’ app values your privacy and are committed to protecting your personal information. This Privacy Policy outlines how we collect, use, and disclose your information when you use our Service. It also explains your privacy rights and how the law safeguards your data. It also explains your rights regarding your information and how the law helps protect your privacy. By clicking the “accept” button or using our services, you agree to the terms of this policy. Please take a moment to review it carefully.
We may update or modify this Privacy Policy periodically to reflect changes in our practices, services, or legal requirements. Whenever we make updates, we will revise the "Last Updated" date at the top of this policy to indicate the most recent changes. In certain cases, we may also notify you directly by sending an additional communication, such as an email or a prominent notice on our website, to ensure you are aware of the updates. We encourage you to review this Privacy Policy regularly to stay informed about how we protect and manage your personal information.
2. Information we may gather about you?
The personal data we collect and process may include the following:
2.1 Basic information such as your name, date of birth, employer, title, age, and any affiliations with individuals or organizations.
2.2 Contact information, including your physical address, email address, fax number, and telephone number.
2.3 Technical information, such as your IP address, and data collected during your visit to our website.
2.4 Payment information related to transactions or services you request.
2.5 Confidential data generated by us as part of the services we provide.
2.6 Details related to your visits to our offices, including any interactions or meetings.
2.7 Any other information that you may voluntarily provide to us.
3. Commitment to protecting your personal Information
We are fully committed to safeguarding your personal information and ensuring its security. To achieve this, we have implemented a range of robust technical and organizational measures designed to protect your data from unauthorized access, misuse, or unlawful processing, as well as to prevent accidental loss, destruction, or damage.
Our security practices are comprehensive and continually updated to address emerging threats and vulnerabilities. These measures include, but are not limited to:
a. Data Encryption
We use state-of-the-art encryption technologies to ensure that your personal information is securely transmitted and stored. This protects your data from being intercepted or accessed by unauthorized parties.
b. Regular Security Audits and Assessments
Our security systems are routinely audited and tested to ensure their effectiveness. We also conduct risk assessments to identify and mitigate potential vulnerabilities in our data protection practices.
c. Secure Data Storage
Personal data is stored in secure facilities with multiple layers of protection, both physical and digital, to guard against unauthorized access, theft, or loss.
d. Employee Training and Awareness
All employees who handle personal information are regularly trained on data security best practices and privacy regulations to ensure that they are aware of their responsibilities in protecting your data.
e. Incident Response and Breach Notification
In the unlikely event of a data breach, we have a well-defined incident response plan in place. This plan allows us to swiftly mitigate the impact and notify affected individuals in compliance with applicable data protection laws.
In addition to these security measures, we maintain a clear data retention policy, ensuring that your personal information is only retained for as long as necessary for the purposes outlined in this Privacy Policy, or as required by law.
We continually review and update our security practices to keep pace with new developments in technology and to ensure your data is always protected against evolving security risks. Your privacy and the security of your personal information are our top priorities.
4. Use of Your Personal Information
We will only use your personal information in accordance with applicable laws and regulations. Our use of your personal data is based on the lawful grounds set forth by relevant data protection laws. Below are the specific purposes for which we may process your personal information:
4.1 Processing Your Transactions: We will use your personal information as necessary to process and complete transactions you initiate with us. This includes delivering products or services, and providing updates on the status of your transaction.
4.2 Assessing Your Eligibility for Offers : To ensure we can offer you the right products or services, we may process your personal data to assess your eligibility for special offers, promotions, or services. This processing is based on our legitimate interest in determining your suitability for specific offers, which helps us provide you with timely and relevant opportunities. This process may also expedite future transactions with us.
4.3 Providing Requested Products and Services: We may process your personal information to fulfill requests for products or services you have made. This is necessary for the performance of the contract between us and is central to our ability to provide you with the services or products you have requested.
4.4 Compliance with Legal Obligations: We will process your personal data as necessary to comply with our legal obligations and to follow your instructions, ensuring that we meet our commitments to you under applicable privacy laws, such as the Nigerian Data Protection Act (NDPA,2023 and other applicable regulations.
4.5 Obtaining Consent: In certain cases, we will only process your personal information if you have given us explicit consent (where required by law). In cases where your employer or another organization shares your personal information with us, they must have obtained your consent for this disclosure, where necessary. If we require your consent for any specific purpose, you will be clearly informed, and you may withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
4.6 Legitimate Interests: We may also process your personal information if we have a legitimate interest to do so, provided that such interests are not overridden by your rights and freedoms. For example, we may process your information for purposes like fraud prevention, improving our services, or ensuring the security of our website and business operations.
4.7 Withdrawal of Consent: If you have given us explicit consent for certain uses of your personal data, you may withdraw that consent at any time. You have the right to change your preferences or withdraw consent for specific activities, and we will respect your decision. However, please note that withdrawal of consent may affect our ability to provide certain services or fulfill transactions, depending on the nature of the consent.
5. What Happens if You Fail to Provide Personal Data?
In some cases, providing personal information is necessary to process your transactions, respond to your requests, or meet legal obligations. If you choose not to provide the required information, we may not be able to complete certain transactions or provide certain services. For example, failure to provide payment details may prevent us from processing an order or completing a service agreement.
Where applicable, we will inform you of any mandatory data requirements before initiating any processing, and we will explain the consequences of not providing the necessary information.
We are committed to ensuring that your personal data is used only for legitimate purposes, and we will always act in accordance with relevant data protection laws and regulations. If you have any concerns about how we handle your personal data, please feel free to contact us.
6. Methods We Use to Collect Your Data
We use a variety of methods to collect data from and about you. These methods include both direct interactions and automated technologies. Below are the key ways we may collect your personal information:
6.1 Direct Interactions
You may provide us with your personal data directly when you interact with us in various ways, including when you:
Apply for our products or services: When you request or sign up for our offerings, we may collect your Identity, Contact, and Financial Data necessary to process your request.
Seek employment with us: If you apply for a job with our company, we may collect your personal details, such as your name, contact information, resume, and work experience.
Provide services as a vendor or partner: If you represent a company that provides services to us, we may collect business and personal data relevant to the relationship, including contract details and payment information.
Request marketing materials or communications: If you express an interest in receiving marketing communications, we will collect your contact information to send you relevant updates, offers, or promotions.
Enter competitions, promotions, or surveys: When you participate in any of our promotional activities or surveys, we collect personal data such as your contact information, preferences, and responses.
Provide feedback or contact us: If you reach out to us with inquiries, feedback, or concerns (via phone, email, or other methods), we collect your contact details and any information you provide to address your requests or improve our services.
6.2 Automated Technologies or Interactions
As you use our website or interact with our online services, we may automatically collect Technical Data related to your device, browsing actions, and usage patterns. This data is collected through the use of cookies, server logs, and similar tracking technologies, which help us understand how you engage with our site and improve your experience.
Cookies and Similar Technologies: Cookies are small files stored on your device that track your browsing activity. They help us personalize your experience, analyze website traffic, and identify areas for improvement. In addition to our own cookies, we may also use third-party cookies that gather information about your interactions with our website. For more information on how we use cookies and how you can manage them, please refer to our Cookie Policy below.
Technical Data Collected: This includes information such as your IP address, browser type and version, operating system, device type, pages you visited, and time spent on our site. We may also track the links you click, search terms you enter, and any forms you complete.
Third-Party Tracking: If you visit other websites that use our cookies, we may also receive technical data from those sites to further analyze your browsing behavior across multiple platforms. This helps us understand your preferences and provide more relevant content and advertisements.
By using our website, you consent to our collection of data through these automated methods. You have the option to manage your cookie preferences through your browser settings, although this may affect your experience with our website.
7. Sharing your personal data
Regardless of how we collect your personal data, it may be shared across all of our offices, as listed on our website. We ensure that each of our offices maintains a consistent standard of data protection. When we share your personal data with third parties, we do so in compliance with applicable data protection laws and will implement appropriate safeguards to ensure that your information remains secure.
8. Marketing
We would like to keep you informed about our products and services that may be of interest to you. With your consent, or where it aligns with our legitimate interests, we may send you information via post, email, phone, text message (SMS), or automated calls. We will only request your preference to receive marketing communications when you check the appropriate boxes. If you have previously agreed to receive such communications, you can opt out at any time by contacting us.
9. Retention of Your Personal Data
We will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including meeting any legal, regulatory, accounting, or reporting obligations. Once your personal data is no longer needed for these purposes, or if you withdraw your consent (where applicable), we will delete it. However, we may retain certain information if required by law or authorized for other legitimate reasons.
10.Your Rights Regarding Personal Data
In addition to the rights provided under applicable data protection laws, and where permitted or required by law or our professional obligations, we will make your personal data available to you upon request. You have the right to request a copy of your personal data, and if any inaccuracies are identified, we will promptly correct them.
Except as otherwise stated, we do not engage in automated decision-making or profiling based solely on your personal data.
You also have the right to withdraw your consent for specific processing activities at any time. If you choose to withdraw your consent, we will stop processing your personal information for the purposes for which you initially provided it. However, please note that if we have another lawful basis to continue processing your data (such as fulfilling a contract or complying with legal obligations), we may still retain and process your data for those purposes, even after you withdraw consent.
We are committed to ensuring your rights are respected and will act promptly upon receiving any requests regarding your personal data.
11. Opting out
You can ask us to stop sending you marketing messages at any time by contacting us at outreach@dovekash.ng
12. Information Collected from Your Device
In order to provide you with a superior experience while ensuring the safe and efficient operation of our application, we need to request certain permissions from you. You can view and manage these permissions at any time in your device settings:
Location Permission: By obtaining your approximate location, we can monitor transaction security, provide you with customized services, and locate you in emergencies.
Device Information Permission: Collecting device identification information helps enhance security and allows us to create personalized services for you.
SMS permission: To ensure the smooth processing of your loan application, we may request access to your SMS permissions, which will allow us to securely read the verification codes and bank transaction confirmation messages that we send to you for identity verification and credit assessment. We use industry-leading encryption technology to protect your information, and we promise not to read any SMS content unrelated to the loan, nor will we share your SMS information with any third parties. You can manage or withdraw this permission at any time, as we prioritize user privacy and data security.
Camera Permission: Used for user identity verification and to conduct risk assessment.
Calendar Permission: Access to your calendar information facilitates scheduling and setting up payment reminders for you.
Bluetooth Permission: Enables Bluetooth functionality to ensure the security of data transfer and facilitate information sharing.
13.Behavior Data Collection and Usage Description
1. Purpose of Data Collection: To enhance user experience and optimize services, we have integrated behavior data tracking technology in our application to collect user behavior data within the app.
2.Scope of Data Collection: We collect the personal information you provide, and behavioral data including but not limited to click behavior, page viewing duration, and scrolling behavior within the app. This data is used to analyze user behavior patterns so that we can better understand user needs and improve our services.
3. Data Usage: The collected behavior data will only be used for internal analysis to optimize product design, enhance user experience, and conduct market research. We promise not to use this data for any commercial purposes without user consent.
4. Data Security: We use industry-standard encryption technology to protect your data security and prevent unauthorized access or disclosure during transmission and storage.
5. User Consent: We respect the user's right to choose whether to authorize us to collect and use your behavior data.
6. Third-Party Disclosure: We will not share the collected behavior data with any third party unless it is a necessary partner for providing services, and we will inform you clearly and obtain your consent before sharing.
14. Other Websites
Our website may contain links to external websites that are not operated by us. This Privacy Policy applies only to our website and services. When you visit other websites via links on our site, we encourage you to read their privacy policies, as they may differ from ours.
15. Contact Us
We keep our Privacy Policy under regular review, and we will place any updates on this web page.
If you have enquiries or want to exercise your right, please contact us at outreach@dovekash.ng