Privacy Policy Overview

This Privacy Policy explains Suretree Systems Limited’s (the “Company”, “We”, “Us”) online information practices and your related choices. The Company owns, operates, or enables users to obtain information from several interactive websites and connected applications as well as provide online comparison of services, including but not limited to savings, loans, healthcare, internet providers and insurance (“Our Services”). This Privacy Policy applies to all information collected from and about You, by Suretree Systems Limited, irrespective of how it is collected or stored, and describes, among other things, the types of information collected about You as You utilize Our Services.

This Privacy Policy is in compliance with the relevant Data Protection Regulations and is applicable to any Personal Information, which is given by You to Us (User Information) via our website. Your Privacy is important to us and this Policy is devised to help you feel more confident about the privacy and security of your personal details. Except as otherwise stated in this Policy, the Company is a Data Controller (in the manner defined in the Nigerian Data Protection Regulation 2019 (“the Regulations”).

In this Policy:

“Consent” means any voluntary, specific, informed and clear indication through a statement or any affirmative action by You signifying an agreement to process personal data relating to You.

“Personal Information” refers to information that is about any individual that can be used on its own or with other information directly or indirectly to identify, contact or locate a single person, or to identify an individual in a context. It includes but is not limited to a name, an identification number, physical address, email address, IP address and location data.

“You” means you, the user(s) of the Site collectively and/or individually as the context allows

“We/Us/the Company” means Suretree Systems Limited and any affiliate of Suretree Systems Limited

“Processing/Process of Personal Information/Processed” means anything that is done with personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction

1. Who we are

This Website on which this Privacy and Cookies Policy is made available is operated by Suretree Systems Limited (Suretree, we, us or our). Our registered number is 1531203 and our registered address is 256 Murtala Muhammed Way, Alagomeji-Alagomeji-Yaba, Lagos, Nigeria.

2. Privacy and Cookies Policy

• This Privacy and Cookies Policy sets out the basis on which we collect your personal data and use Cookies. Please read through it carefully before using the Website.
• We are committed to protecting your privacy online. We appreciate that you do not want the personal information you provide to us distributed indiscriminately. On this platform, we explain how we collect information, what we do with it and what controls you have.
• By clicking “I agree” to this privacy and cookies policy on this Website, you consent to the collection and use of your personal information in accordance with this Privacy and Cookies Policy.
• Kindly be informed that our Policy is subject to change from time to time without notice to reflect changes in our practices with respect to processing your information or changes in the applicable law. Please review this page regularly to stay abreast of such changes If you continue to use the Website after any such revisions take effect then it means that you have agreed to the revised Privacy and Cookies Policy.
• This Privacy and Cookies Policy was last updated on 29th January 2021.

3. Scope

These Policies apply to all activity on our Website and social media platforms, if any, in which the provision and processing of Information is required. However, information that is classified as public is not subject to this Privacy and Cookies Policy.

4. Other Applicable Terms

In addition to this Privacy and Cookies Policy, our Website Terms of Use also apply to your use of the Website and are, where relevant, incorporated by reference into this Privacy and Cookies Policy.

5. Consent

• As above, consent within the meaning of this Policy is your agreement to provide Information when requested or when you freely provide information in accordance with this Privacy and Cookies Policy. Your consent will always be sought for the collection, processing, use or storage of Information for any purpose. You will also be made aware of the purpose for which your Information is collected, and your Information will only be applied towards that purpose.
• At any time when your consent is requested, you will also have the option of objecting to the processing of your Information by not providing the requested details or action, as the provision of your Information is absolutely voluntary. Please note however that where you object to the provision of relevant Information, we may be unable to proceed with the provision of our services to you.
• Where you wish to provide Information of third parties, you are required to ensure that the consent of such third parties is sought and obtained prior to providing it to us. By providing the Personal Information of third parties, this consent will be deemed to have been sought and obtained.
• For the avoidance of doubt, we will only collect and/or process your Information where:
  • you give us your consent to process your data for one or more purposes;
  • it is necessary for the performance of an order or instruction issued by You;
  • it is required for compliance with a legal obligation to which we are subject;
  • it is necessary to protect the vital interests of the data subject or of another Person; or
  • it is necessary for the performance of a task carried out in the public interest or in the exercise of official public mandate vested in us.

  Please note that you have a right to withdraw your consent at any time. More information on the withdrawal of your consent is contained in Clause 16 (“Your Rights”) below.

  Notwithstanding anything provided in this Privacy and Cookies Policy and subject to applicable law, we reserve the right to use, access, preserve and disclose information if we believe it is reasonably necessary to respond to claims against us or comply with any law, regulation, legal process or governmental request, to enforce or administer the Terms of Use of our Website or our other policies or agreements with Users, to conduct customer support, or detect, prevent or otherwise address fraud, security or technical issues and to protect or enforce our rights, property or safety and those of others.

6. Information we may collect from you

• 6.1 We may collect and process the following information about you:
  • Personal information (such as your name, date of birth, email, postal address, BVN, your demographic information etc.) that you provide when you register as a user of the Website, upload or submit any material via the Website or request for any information;
  • in connection with your account, your log-in and password details;
  • regarding details of any transactions made by you through the Website;
  • communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Website and its content;
  • details of your visits to the Website, the resources you access and any data you download;
  • technical information from your mobile device relating to the services you receive; and
  • information that you post in the form of comments or contributions to discussions.
• 6.2 You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services.

7. How we use your information

We will use the personal information you provide to:

• 7.1 identify you when you sign into your account;
• 7.2 enable us to provide you with requested comparison of the services, products and information offered through the Website and communicate with you about promotional offers;
• 7.3 administer your account with us;
• 7.4 execute your orders placed on the Site for Our Services including processing your payment information..
• 7.5 analyse the use of the Website and the people visiting in order to improve our content and services including research into our users’ demographics;
• 7.6 send you information we think you may find useful or which you have requested from us, including receipt of marketing communications, or that of carefully selected third parties; provided you have indicated that you are happy to be contacted for these purposes;
• 7.7 allow, with your prior consent, carefully selected third parties to send you information directly which you may find useful regarding their products and services;
• 7.8 improve and optimize our Website;
• 7.9 share with third parties/affiliates, both as necessary for marketing purposes, insofar as this does not conflict with the requirements for the protection of your Information;
• 7.10 update or confirm existing records;
• 7.11 respond to your enquiries and instructions;
• 7.12 comply with legal authority or other lawful requests by regulators; and
• 7.13 to fulfil our general business operation needs including accounting, recordkeeping and other administrative functions.

Any further processing of your Information will only be for archiving or statistical purposes.

You can always update or amend the Information provided to us through our self-service portal if subscribed thereto. Other means of updating your Information include written requests through e-mail or letters or verbal requests over the phone.

8. Disclosure of Personal Information

Personal data will be used only for reasons specified in “How we may use your data” above. Personal information shall not be disclosed or sold to any third party except by your consent (where you consent we should draw your attention to the fact that this information may be transferred within or outside Nigeria), or where the law requires we do so (example, to law enforcement agents, courts or others, e.g., in response to a subpoena or court order).

We may share personal information with the following categories of third parties:

• Third party service providers/media partners/affiliates that provide services to us or to whom we outsource certain services, such as data hosting or software or technology services.
• Our professional advisers, such as accountants for data audit purposes
• Government and/or regulatory authorities.
• Professional indemnity insurers.
• Tax authorities and/or corporate registries.In addition, we may disclose personal information to other third parties under the following circumstance:
• Protect our rights
  Notwithstanding anything provided in this Policy and subject to applicable law, we reserve the right to use, access, preserve and disclose information if we believe it is reasonably necessary to respond to claims against us or comply with any law, regulation, legal process or governmental request, to enforce or administer the Terms of Use of our Site or our other policies or agreements with Users, to conduct customer support, or detect, prevent or otherwise address fraud, security or technical issues and to protect or enforce our rights, property or safety and those of others.

  We may also share, aggregate or de-identify information with third parties for research, marketing, analytics and other purposes, provided such information does not identify an individual.

9. Data Retention

We will only retain your Information for a period for which is reasonably necessary for the provision of our services to you and to fulfill the reasons for which it was collected. Further, we will delete Information where:

• it is no longer necessary in relation to the purposes for which it was collected or processed;
• you withdraw your consent to the processing of your Information;
• you object to the processing of your Information and there are no overriding legitimate grounds for the processing;
• your personal information is found to have been processed at variance with the provisions of the law; or
• compliance with a legal obligation requiring the erasure of Personal Data.

10. Information sharing

• 10.1 We may share your information with carefully selected third parties. You can decline to receive information regarding products and services or those of third parties, or to sharing of your details with third parties so that they can send you information regarding their products and services, either at the point such information is collected on the Website or, where you do not wish us to continue to use your information for these purposes , by following the unsubscribe instructions on any communications sent to you. You can also exercise this right at any time by reaching out to us using the contact us details at the end of this Privacy and Cookies Policy.
• 10.2 We may disclose aggregate statistics about visitors to the Website in order to describe our services to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information.
• 10.3 We may disclose your personal information to any of our affiliates, or to our agents or contractors who assist us in providing the services we offer through the Website, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.
• 10.4 In the event that we undergo re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to such third party.
• 10.5 We may disclose your personal information if legally entitled or required to do so (for example if required by law or by a court order or if we believe that such action is necessary to prevent fraud or cybercrime or to protect the Website, or the rights, property or personal safety of any person).

12. Cookies and similar technology

• 12.1 The Website also uses Cookies or similar technology to collect information about your access to the Website.
• 12.2 Cookies are pieces of information that include a unique reference code that a website transfers to your device to store and sometimes track information about you. A number of Cookies we use last only for the duration of your web session and expire when you close your browser. Other Cookies are used to remember you when you return to the Website and will last for longer periods.
• 12.3 We use Cookies to:
  • remember you as a user of our website (this means we can identify the number of unique visitors we receive and allows us to make sure that we have enough capacity for the number of Users we get);
  • allow you to navigate the Website more quickly and easily;
  • remember your login session so you can move from one page to another within the Website;
  • store your preferences;
  • customise elements of the layout and/or content of the pages of the Website for you; and
  • collect statistical information about how you use the Website so that we can improve the services we offer to you..
• 12.4 All Cookies used on our Website are set by us.
• 12.5 Most computer and some mobile web browsers automatically accept Cookies but, if you prefer, you can change your browser settings to prevent that or to notify you each time a Cookie is set. Please note however, that by blocking or deleting Cookies you may not be able to take full advantage of the Website
• 12.6 Our Cookies may perform these services:

  Essential session management

  • create a specific log-in session for a visitor to the Website in order that the Website remembers that a visitor is logged in and that their page requests are delivered in an effective, secure and consistent manner;
  • recognise a returning visitor to the Website
  • recognise registered members of the Website
  • we may also log information from your computer including the existence of Cookies, your IP address and information about your browser program in order to allow us to diagnose problems, administer and track your usage of our services;

  Functionality

  • customise elements of the promotional layout and/or content of the pages of the Website for example by storing a country code and providing users with content relevant to their country; and

  Performance and measurement

  • collect statistical information about how our visitors use the Website so that we can improve the most popular services demanded on the Website.

13. Public forums

The Website may, from time to time, make chat rooms, message boards, news groups and/or other public forums available to its Users. Any information that is disclosed in these areas becomes public information and you should exercise caution when making use of these forums and never disclose your personal information.

14. External links

The Website may, from time to time, contain links to external Websites. We are not responsible for the privacy policies or the content of such Websites.

15. Security

• 15.1 We place great importance on the security of all personally identifiable information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.
• 15.2 You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the Website whilst it is in transit over the internet and any such submission is at your own risk.
• 15.3 It is advisable to close your browser when you have completed your user session to help ensure others do not access your personal information.

16. Your Rights

• 16.1 Right to Withdraw Consent

  You have a right, at any time, to withdraw your consent to the processing of your Information. Withdrawing consent is as straightforward as giving consent and you can do so via our Website, where you are subscribed or have an account, or by written requests through email or letters or by verbal requests over the phone. Please note that where applicable, this may mean that we will be unable to proceed with the provision of our services to you. The withdrawal of your consent cannot be backdated and thus will have no effect on processing already performed during the period of consent.

• 16.2 Right to Access, Change, Deletion, Restriction, Objection, Copies

  You have the right to:

  • access your Information;
  • receive copies of Information (subject to a possible fee in the case of excessive requests);
  • object to processing of your Information;
  • restrict the processing of your Information;
  • rectify or update inaccurate Information;
  • request the deletion of your Information.
• 16.3 The Right to Complain to the Regulator and Seek Redress

  Where You consider that your Personal Information has been misused in any manner, you are entitled to make a complaint before the relevant supervising authority or the courts of competent jurisdiction. We recommend you lodge this complaint as soon as you become aware of the breach. We will endeavour to remedy the breach as soon as practicable depending on the circumstances of the breach and within 30 days of our receipt of notice of the breach.

  Please notify us immediately or within 90 days of discovery of a breach and we will endeavour to resolve the issue within 30 days of acknowledging receipt of the complaint:

  • If you believe your account for Our Services has been compromised
  • If you believe your personal information has been used for a fraudulent activity
  • If you have been contacted by someone via email or SMS about your account on Our Services requesting for your password
  • If you have any other enquiry regarding information privacy and security.

17. Transfer and Storing of Personal Information Outside Nigeria

Due to the international nature of our business operations, You understand that We may need to process, transfer, or store your Personal Information in countries other than Nigeria. Further, we may be required to host, process, store or transfer your Personal Information to other countries to enable us to actualize a contract with a third party for your benefit or your protection as a user of Our Services.

The Company shall take steps to ensure that the countries have adequate data protection laws and the requisite policies to protect your Personal Information in the manner required by the Regulations.

18. Contact us

19. Disclaimer

This Policy only covers our operations on the Site, on our social media platforms and any other online marketing or sales channels. Any third-party to which we may provide links may have in place their own privacy and data protection policies, which may differ from ours. We accept no responsibility or liability in respect of Personal Information provided to any third-party platforms.

Do note that We are not responsible for any information which you voluntarily provide about yourself in certain public areas of Our Services such as the chat forums, message boards, blogs or other publicly accessible interaction, or information that you decide to hold out to the public in your member profile or any other aspect of Our Services which permits users to upload or post content. We do not recommend that You make your Personal Information available in these and other similar areas when using Our Services.