Privacy Notice

Introduction

This privacy and data protection notice (the notice) will explain how our website and mobile application uses the personal data we collect from our customers and related partners when they use our services. It describes our commitment to treat your information with the utmost care and confidentiality in compliance with applicable data protection laws, and in alignment with global industry best practices. This notice explains your privacy rights regarding SaltinGStein Limited’s (“SGS”, “we”, “us” or “our”) collection, use, storage, sharing and protection of your personal information.

This Privacy Notice describes a user’s privacy rights regarding our collection, use, storage, sharing and protection of personal information. It applies to the website and all related sites, applications, services and tools regardless of how they are accessed or used. This Notice does not apply to services that are not owned or controlled by SGS, including third-party websites and the services of other SGS’s merchants that may be accessible through links which are present on our website and all related sites, applications, services and tools. You are encouraged to review the privacy notice of such merchant or third party.

We conduct business in a responsible and sustainable manner and ensure customer information is securely collected, processed, and stored based on business requirements. In furtherance of this and compliance with industry regulations, we have provided appropriate documentation, which includes this notice. We therefore provide notice about this notice and applicable procedures.

Throughout this Privacy Notice, we use the term “personal information or data” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been made anonymous such that it does not identify a specific user. To use our website, application or any of our products or services, your consent is required for the use of your data as described in this Notice. This Privacy Notice is intended to set certain standards across the operations of SaltinGStein Limited.

The Information We Collect

As part of our operations, SaltinGStein Limited may collect and process certain types of personal identifiable information (such as Name, email address, phone number, contact address, limited financial information, location data, device data, KYC details) of individuals which include current, past and prospective employees, merchants, suppliers/vendors, customers of merchants, Users and other individuals whom SaltinGStein Limited communicates or deals with, jointly and/or severally (“Data Subject(s)”).

We use your Personal Information to:

• Provide you with the required services;
• Respond to your questions or requests;
• Improve features, website content and analyse data to develop products and services;
• Address inappropriate use of our website and Mobile Application;
• Prevent, detect and manage risk against fraud and illegal activities using internal and third-party screening tools;
• Send you marketing content, newsletters, and service updates created by SGS, however, we will provide you with an option to unsubscribe if you do not want to hear from us;
• Verify your identity and the information you provide in line with SGS’s statutory obligations using internal and third-party tools;
• Maintain up-to-date records;
• Resolve disputes that may arise, including investigations by law enforcement or regulatory bodies;
• Any other purpose that we disclose to you in the course of providing SGS’s services to you.

We may retrieve additional Personal Information about you from third parties and other identification/verification services such as your financial institution and payment processor. With your consent, we may also collect additional Personal Information in other ways including emails, surveys, and other forms of communication. Once you begin using our services through your SaltinGStein Limited account we will keep records of your transactions and collect information of your other activities related to our services. We will not share or disclose your Personal Information with a third party without your consent except as may be required for the purpose of providing you with our services or under applicable legislation.

Purpose Limitation

SaltinGStein Limited collects Personal Information only for identified purposes and for which consent has been obtained. Such Personal Information cannot be reused for another purpose that is incompatible with the original purpose, except consent is obtained for such purpose.

Data Minimization

SaltinGStein Limited limits Personal Information collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed. SaltinGStein Limited will evaluate whether and to what extent the processing of Personal Information is necessary and where the purpose allows, anonymized data will be used.

Updates, Modifications & Amendments

We may need to update, modify or amend our Privacy Notice as our technology evolves and as required by law. We reserve the right to make changes to this Privacy Notice from time to time and notify Users of material changes. The Privacy Notice will apply from the effective date provided on our website.

We advise that you check this page often, referring to the date of the last modification on the page. If a User objects to any of the changes to this Privacy Notice, the User must cease using this Site, or terminate their account in the event an account has been created.

Age Restriction

Our website and services are not directed to children under 18. We do not knowingly collect information from children under 18. If as a parent or guardian, you become aware that your child or ward has provided us with any information without your consent, please contact us through the details provided in this Privacy Notice.

Cookies

We use cookies to identify you as a User and make your user experience easier, customise our services, content and advertising; help you ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our website. Cookies allow our servers to remember IP addresses, date and time of visits, monitor web traffic and prevent fraudulent activities.

Our cookies never store personal or sensitive information; they simply hold a unique random reference to you so that once you visit the site we can recognize who you are and provide certain content to you. If your browser or browser add-on permits, you have the choice to disable cookies on our website, however this may impact your experience using our website.

How We Protect Your Information

SaltinGStein Limited shall establish adequate controls in order to protect the integrity and confidentiality of Personal Information, both in digital and physical format and to prevent Personal Information from being accidentally or deliberately compromised. SaltinGStein Limited is committed to managing your Personal Information in line with global industry best practices and in compliance with regulatory requirements. We store and process your personal information on our computers in Lagos, Nigeria and anywhere else where our facilities are located. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration.

Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorization controls. We have also taken additional measures by ensuring our system complies with industry information security standards.

Employees may have access to Personal Information only as is appropriate for the type and scope of the task in question and are forbidden to use Personal Information for their own private or commercial purposes or to disclose them to unauthorized persons, or to make them available in any other way. Staff are trained on data privacy obligations and access is restricted to need-to-know personnel only.

Marketing and Sharing Personal Information

SaltinGStein Limited does not sell, trade or rent personal information to anyone. However, to enable us to render our services to you on our website, we may share your information with trusted third parties, such third parties include financial institutions, payment processors, verification services, sanctions screening and identity verification services as well as any third parties that you have directly authorized to receive your Personal Information. Your Personal Information may be stored in locations outside the direct control of SGS, for instance, on servers or databases co-located with hosting providers.

We may disclose your Personal Information in compliance with applicable law or a legal obligation to which we are bound.

The use of your information by such third party will be subject to their applicable privacy notice, which you should carefully review.

Grounds for Processing of Personal Information

Processing of Personal Information by SaltinGStein Limited shall be lawful if at least one of the following applies:

• the Data Subject has given consent to the processing of his/her Personal Information for one or more specific purposes;
• the processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which SaltinGStein Limited is subject;
• processing is necessary in order to protect the vital interests of the Data Subject or of another natural person; and
• processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in SGS.

For the purpose of this Privacy Notice, consent means any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which they, through a statement or a clear affirmative action, signify their agreement to the processing of Personal Information relating to them.

Data Subject Rights

Individuals who have Personal Information held by SaltinGStein Limited are entitled to reach out to SaltinGStein Limited to exercise the following rights:

• Right to request for and access their Personal Information collected and stored.
• Where data is held electronically in a structured form, such as in a Database, the Data Subject has a right to receive that data in a common electronic format;
• Right to information on their personal information collected and stored;
• Right to objection or request for restriction;
• Right to object to automated decision making;
• Right to request rectification and modification of Personal Information which SaltinGStein Limited keeps;
• Right to request for deletion of their data;
• Right to request the movement of data from SaltinGStein Limited to a third party; this is the right to the portability of data; and
• Right to object to, and to request that SaltinGStein Limited restricts the processing of their information;
• Right to lodge a complaint with the Nigeria Data Protection Commission.

To make your request, please fill out our Data Subject access request form: Data Subject Request Form.

Your request will be reviewed by SGS’s Data Protection Officer and carried out except as restricted by law or SGS’s statutory obligations. You may decline to provide your personal Information when it is requested by SGS, however, certain services or all the services may be unavailable to you. You may review your account settings and update your Personal Information directly or by contacting us.

The Data That We Retain

We will retain your information for as long as your account is active or as needed to provide our services to you, comply with our legal and statutory obligations or verify your information with a financial institution.

SaltinGStein Limited is statutorily obligated to retain the data you provide us with in order to process transactions, ensure settlements, make refunds, identify fraud and in compliance with laws and regulatory guidelines applicable to us, our banking providers and card processors.

Therefore, even after closing your SaltinGStein Limited account, we will retain certain Personal Information and transaction data to comply with these obligations. All Personal Information shall be destroyed by SaltinGStein Limited where possible. For all Personal Data and records obtained, used and stored by SGS, we shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity and requirement to retain.

The length of storage of Personal Information shall, amongst other things, be determined by relevant legislation.

Transfer of Personal Information

SaltinGStein Limited may engage the services of third parties in order to process the Personal Information of Data Subjects collected by the SGS. The processing by such third parties shall be governed by a written contract with SaltinGStein Limited to ensure adequate protection and security measures are put in place by the third party for the protection of Personal Information in accordance with the terms of this Privacy Notice.

Transfer of Personal Information to Foreign Country

Where Personal Information is to be transferred outside Nigeria, SaltinGStein Limited (“SGS”) shall ensure that such transfer is carried out in compliance with the Nigeria Data Protection Act (NDPA), the General Application and Implementation Directives 2025 (GAID), and, where applicable, the General Data Protection Regulation (GDPR).

SGS shall only transfer Personal Information where one of the following conditions applies:

• The recipient country has been formally recognised by the Nigeria Data Protection Commission (NDPC) or, where applicable, the European Commission, as providing an adequate level of data protection;
• The transfer is governed by an approved Cross-Border Data Transfer Instrument (CBDTI) under the NDPA or an appropriate safeguard under the GDPR, including standard contractual clauses, binding corporate rules, approved codes of conduct, or certification mechanisms; or
• In the absence of an adequacy decision or appropriate safeguards, the transfer is based on a recognised lawful basis, including:
  • the explicit consent of the Data Subject, after being informed of the associated risks;
  • the necessity of the transfer for the performance of a contract with the Data Subject or pre-contractual measures taken at their request;
  • the necessity of the transfer for the conclusion or performance of a contract in the interest of the Data Subject;
  • important reasons of public interest;
  • the establishment, exercise, or defence of legal claims; or
  • the protection of the vital interests of the Data Subject or another person where the Data Subject is incapable of giving consent.

SGS will take all necessary steps to ensure that Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside Nigeria, the United States, the United Kingdom and the European Union shall be provided to you upon request.

Contact SGS’s Data Protection Officer (DPO)

If you have any questions relating to this Privacy Notice or would like to find out more about exercising your data protection rights, please reach out to our DPO via email at dpo@saltingstein.com.

SaltinGStein Limited maintains a data breach procedure in order to deal with incidents concerning Personal Information or practices leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information transmitted, stored or otherwise processed.

You may contact our DPO upon becoming aware of any breach of Personal Information or if your access credentials have been compromised, to enable us to take the necessary steps towards ensuring the security of your Personal Information or account.