1. Introduction

This Privacy Policy has been created by Suretree Connect Limited (“we”, “our”, “us”) to explain how we collect, use, store, disclose and protect your Personal Data, including any other information when you use, access, and register on the ‘MAXELLA APP’ (‘the App’) services including the procurement, product sign-ups and utilization of any of the Products and Services available on the App at any time.

By accessing or using our services, you agree to the terms of this Privacy Policy and hereby consent to Suretree Connect Limited saving, processing and using your Personal Data to the extent allowed by law when you provide us with details of your Personal Data or by clicking on the “accept” button. You have the right to withdraw your consent at any time, provided that we do not have another legal basis to keep processing your Personal Data.

Changes to this Privacy Policy may occur from time to time. Where changes are made, the revised date will be noted at the first page of this policy. In some cases, we may provide you with additional notice (such as by adding a statement to the homepages of our website or by sending you an email notification).

We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.

2. Collection of Information

We may collect and process the following information about you:

1. Information that you provide to us, for example when you fill out a contact or web form, or if you register to receive alerts or updates.
2. Personal data such as your full name, address, date of birth, nationality, marital status, contact details, and other related information.
3. Bank details or payment information for processing transactions made.
4. Personal Data obtained such as IP addresses, browser type, operating system, referring URLs, location data and other technical data that may be automatically collected during your interaction with our website or services.
5. Data related to the security of your interactions with our services, such as security questions, account activity, and logs of system access for fraud prevention or identification purposes.
6. Information provided during interactions with third-party services that may be integrated into our system (for example, through payment processors or authentication systems).
7. Records of communications with you, including emails, messages, and customer support queries. We may also ask you to complete surveys for research purposes, although you don’t have to respond to these.
8. Social media information (where applicable) if you interact with us through social media platforms or our own social media accounts.
9. Any other relevant data we collect to provide services related to the use, enhancement and optimization of the Maxella App.

3. Use of Personal Data

We may use your Personal Data, including non-public Personal Data for the following purposes:

1. To provide, maintain, and improve our services.
2. To process and deliver the products and services you request including processing transactions, confirming your applications, and sending you related information.
3. To verify your identity, prevent fraud and ensure the integrity of our services. This may include biometric identity verification, cross-referencing your submitted data, and validating the authenticity of government-issued identification.
4. To send you technical notices, updates, security alerts and administrative messages related to the security and functionality of our services.
5. To respond to your comments, questions and requests and provide customer service.
6. To communicate with you about products, services, offers, promotions, rewards, and events offered by Suretree Connect Limited or trusted third parties, and provide news or information we believe will be of interest to you.
7. To monitor and analyse trends, usage patterns, and activities in connection with our services in order to improve user experience and service offerings.
8. To personalize and improve your experience with our services by providing advertisements, content or features that match your user profile or interests.
9. To link or combine your personal data with information we obtain from external sources in order to understand your needs and provide you with better, more tailored services.
10. To ensure compliance with relevant laws, regulations, and industry standards, data protection and security requirements.
11. To improve the performance, security and functionality of our online platforms and systems.
12. To carry out any other purposes for which your personal data was collected, in compliance with data protection laws and regulations.

Suretree Connect Limited is based in Nigeria and the information we collect in respect of your use, interface, engagement and interaction with the Maxella App is governed by the Nigeria Data Protection Act (NDPA) and any other applicable data protection laws in Nigeria. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to Nigeria.

4. Disclosure of Information

Suretree Connect Limited may disclose Personal Data with other entities in the following limited circumstances:

1. We may provide such Personal Data to affiliated companies or other trusted businesses or persons for the purpose of processing Personal Data on our behalf. These entities will act in accordance with our instructions and in compliance with the NDPA and any other applicable data protection laws and any other appropriate confidentiality and security measures. When these third parties no longer require your Personal Data to fulfill their services, they will securely dispose of it in accordance with the NDPA and any other applicable data protection laws. 
2. We may share your personal data with other non-affiliated companies to facilitate business operations, process transactions, maintain accounts, or provide marketing services on our behalf. This may include sharing information with external marketing platforms, email service providers, or customer engagement services. 
3. In response to a request for Personal Data, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process.
4. In certain circumstances, we may disclose your personal data if required by law, regulation, or a legal process, such as in response to court orders, subpoenas, or other legal requests. We will disclose only the data necessary to fulfill such requirements.
5. We may share personal data with law enforcement officials, regulators, auditors, or other third parties if we believe such disclosure is necessary to comply with a legal obligation, prevent fraud, protect the rights or safety of individuals, or investigate potential criminal activity.
6. In the event of a merger, acquisition, financing, or sale of all or a portion of our business, we may disclose personal data to the relevant parties involved in the transaction. Any transfer of personal data will be subject to appropriate confidentiality provisions.
7. We may share your personal data with your consent or at your direction, especially if we notify you in advance that your personal data will be shared in a specific manner and you provide your consent.
8. We may also share aggregated or de-identified or anonymized Information, which cannot reasonably be used to identify you.
9. We may disclose your personal data to third parties in the event of suspected fraud or when necessary to prevent fraud, financial crimes, or security risks, including cooperating with relevant authorities and security firms.
10. We may share personal data to contractors who require the data to provide services to Suretree Connect Limited. These parties are obligated to process personal data in compliance with applicable data protection laws and confidentiality agreements.
11. When Suretree Connect Limited does not have a lawful basis for disclosure of your Personal Data, Suretree Connect Limited will obtain consent from you before sharing your Personal Data with third parties. Where Suretree Connect Limited needs to transfer your Personal Data to another country, such country must have an adequate data protection law.

5. Security

Suretree Connect Limited takes reasonable measures to help protect all Personal Data about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Suretree Connect Limited implements policies designed to protect the confidentiality and security of your Personal Data, including a Data Protection Policy. We have also taken measures to comply with provision of security facilities for the protection of your Personal Data through the set-up of firewalls, limited access to specified authorized individuals, encryption and continuous capacity building for relevant personnel. We therefore have digital and physical security measures to limit and eliminate possibilities of data privacy breach incidents.

6. How Long We Keep Your Personal Data 

We will hold your Personal Data on our systems for as long as it is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.

7. Where We Store Your Personal Data

The Personal Data that Suretree Connect Limited collects from you may be transferred to, stored, and processed in locations outside of Nigeria, including within countries where our affiliated partners, service providers, or data centers are located. By submitting your Personal Data, you consent to this transfer, storage, and processing, in accordance with the terms of this Privacy Policy.

We take steps to ensure that your Personal Data is handled securely and with the appropriate level of protection, irrespective of where it is stored or processed. Suretree Connect Limited will take all necessary steps to ensure that such transfers are in compliance with applicable data protection laws and are conducted in a lawful manner.

8. Your Rights As A Data Subject

The law gives you certain rights in respect to your Personal Data Suretree Connect Limited holds about you. Below is a highlight of some of those rights. At any point while we are in possession of or processing your Personal Data, you, the Data Subject has the following rights:

• 1. RIGHT OF ACCESS: You have the right to request a copy of the information that we hold about you. We will respond to your access request within one-month of receiving your request. Where we are not able to provide this personal data to you within the One-Month timeline provided by law, we will communicate same to you, and may request an additional time within which we will provide the information to you. Your Personal Data shall be provided to you in a structured, commonly used and machine-readable format.
• 2. RIGHT TO RECTIFY:  You have the right to correct the Personal Data we hold about you that is inaccurate.
• 3. RIGHT TO BE FORGOTTEN: In certain circumstances you may ask for the data we hold about you to be erased from our record.
• 4. RIGHT TO RESTRICT PROCESSING: Where certain conditions apply, you have a right to restrict processing of your Personal Data.
• 5. RIGHT TO PORTABILITY: You have the right to have your Personal Data transferred to another organisation.
• 6. RIGHT TO OBJECT: You have the right to object to the Processing of Personal Data.

If you wish to exercise your rights, you may contact our Data Protection Officer at dpo@suretree.com

9. Breach/Privacy Violation

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data, Suretree Connect shall within 72 (Seventy-Two) hours of having knowledge of such breach report the details of the breach to Nigeria Data Protection Commission (NDPC).

Where we ascertain that such breach is detrimental to your rights and freedoms in relation to your Personal Data, we shall within 7 (Seven) days of having knowledge of the occurrence of such breach take steps to inform you of the breach incident, the risk to your rights and freedoms resulting from such breach and any course of action to remedy said breach.

10. Questions or Concerns

If you have any questions or concerns about this Privacy Policy or would like to contact us for any reason, you can contact us dpo@suretree.com