TERMS OF USE

INTRODUCTION

This Terms of Use is made with specific reference on how WSTC Financial Services Limited and WSTC Securities Limited (jointly known as “WTSC”, “We” or “Us”) obtains, uses and protects your Bank Verification Number (BVN).

HOW WE COLLECT PERSONAL DATA

We are legally obligated to collect and process your BVN in accordance with the CBN Directive of the Revised Regulatory Framework for BVN Operation and Watch-List for the Nigerian Banking Industry 2021(the “CBN Directive”). We shall request for your BVN Details in fulfilment of a legal obligation which makes you identifiable by your unique identity in relation to your financial records verifiable across the Nigerian Banking System and its regulators. Your BVN information may be obtained when you:

• Open an account with Us;
• Fill forms, questionnaires or surveys;
• Contact customer care services for compliant/enquiry;
• Provide card details to purchase a product or service.

HOW WE USE YOUR PERSONAL DATA

The BVN information we have obtained may be used in the following ways,

• To process transactions;
• To issue annual report to the CBN in line with the regulations;
• To Verify your identity in certain transactions;
• Issuance of an Incidence report to the NDPB in the event of a breach.

LEGAL BASIS FOR PROCESSING BVN

We shall only process your BVN while relying on any of the underlisted legal basis for processing personal data:

1. Consent – You accept these terms of Use and hereby give us consent to save, process and use your BVN to the extent as allowed by law when you click on the “allow” button.
2. Compliance with Legal Obligation – The CBN Directive requires that we collect your BVN to process transactions. We shall collect and use your BVN details in compliance with the provisions of the CBN Directive and subject to any other legal obligation that may be in force from time to time.

• Public Interest: Where processing is necessary for the performance of a task or function carried out in the interest of the public.

1. Legitimate Interest – means the interest of our business in conducting and managing our business to enable us to give you the best services and most secure experience.
2. Performance of Contract – This will apply where processing is necessary for the performance of a contract to which you are a party or in order to take steps prior to entering into a contract with you;
3. Vital interests: This is where processing is required for the protection of your vital interests.

SECURITY

We have secured robust security infrastructure as well as other technologies and policies to ensure your BVN data is adequately protected from incidences of data breach. We shall take steps to protect your information from unauthorised access, unlawful processing, accidental loss, destruction and damage. Kindly restrict third party access to sensitive data such as your password and login details and same should remain confidential. We reiterate that we are in compliance with the Global Information Security Management System (ISMS) to minimise or limit possibilities of data privacy breach.

DISCLOSURE OF YOUR PERSONAL DATA

We shall not disclose your BVN details to third parties without your consent. Where data is to be transferred to other countries who do not have data protection laws, we are obligated to ensure that such transfer is in line with the provisions contained in Article 2.12 of the Nigeria Data Protection Regulation 2019.

We shall not obtain consent from you where we are sharing your BVN details with;

1. any member of our group, including our subsidiaries, our holding company and its subsidiaries as defined under the Nigerian Companies and Allied Matters Act, Cap C20, Laws of the Federation of Nigeria, 2004
2. authorised employees of WSTC, for the purpose of rendering services to you.

• selected third parties including but not limited to analytics and search engine providers, regulators and finance houses.

We may also not obtain consent where we share your BVN details in any of the following instances:

1. if we are under a duty to disclose your BVN Details in compliance with a legal obligation, or in order to enforce or apply our terms of use and other agreements or as mandated by an Order of court with competent jurisdiction;
2. where we are requested to provide information by authorized third parties of regulatory/governmental agencies investigating illegal activities;

• in the event of a merger or any acquisition made by a third party, in which case we will disclose your BVN details to the prospective buyer;

INDEMNITY

By your consent to this Terms of Use, you acknowledge that while using the services, OTPs or other security PINs may be sent to your email, phone number, etc in order to authenticate the process being part of your personal data, and you hereby warrant that the contact information so provided is true and accessible to you alone. You hereby also indemnify Us against any loss suffered for your inability to use the services due to non-authentication of your information.

CHANGES TO THIS TERMS OF USE

Any changes we make to this Terms of Use will be posted on this page where appropriate or communicated to you by e-mail. Please check back frequently to see any updates or changes to this Terms of Use.