privacy policy

Introduction

Esportcave Limited (“Esportcave”, “we”, “us”, “our” “Company”), recognizes your privacy rights as guaranteed under the 1999 Constitution of the Federal Republic of Nigeria, the Nigerian Data Protection Regulation (NDPR), and other applicable privacy laws in Nigeria. Thus, it is important to us as a law-abiding organisation that your Personal Data is managed, processed and protected in accordance with the provisions of the applicable laws. In the course of our business and/or your engagement with us and third parties through our Platforms (this includes but are not limited to our websites, digital platforms, mobile applications, physical operations/offices, amongst others), we may process your Personal Data, subject however to the terms of this Policy. This Privacy Policy (“Policy”) explains our privacy practices concerning how we collect and process your Personal Data and describes your rights as a user of any of our services and Platforms.

This Policy applies to all our Platforms, and all related sites, applications, services and tools regardless of how they are accessed or used. In this Privacy Policy, “we”, “us” or “our” refers to Esportcave Limited and its successors, agents and assigns, while “you”, “your” refers to you and/or any person who subscribes for, uses or authorizes the use of the Service.
Our Privacy Policy explains our user’s privacy rights regarding:
  1. What Personal Data we collect
  2. Why we collect such Personal Data
  3. The use of such Personal Data
  4. The storage, sharing and protection of such Personal Data

Consent

As a user of any of our Platforms, you accept this Privacy Policy when you sign up for, or use our products, services, content, technologies or functions offered on our Platforms and all related sites and services (“Services”).

Definition of Terms

For the purpose of this Policy:

Personal Data: means any information relating to you, including your name, identification number, location data, online identifier address, photo, email address, pins, passwords, bank details, posts on our Platforms, religion, date of birth, health, race/tribe, nationality, ethnicity, political views, trade union membership, criminal records, medical information, and other unique identifiers such as but not limited to MAC address, IP address, IMEI number, Bank Verification Number, IMSI number, SIM and others. It also includes factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.
Process/Processing: means any operation or set of operations which is performed on your Personal Data or 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.
Consent: We kindly request that you carefully read this Policy and click on the ‘Agree’ icon below, if you consent to the terms of this Policy, particularly concerning processing your Personal Data. That notwithstanding, if you proceed to use any of our Platforms and services, it will be deemed that you have provided your express consent to the terms of this Policy..
Age: You must be at least 18 years old to use our services or any of our Platforms. Individuals under the age of 18, or the applicable age of maturity, may utilize our Platforms services only with the involvement of a parent or legal guardian, under such person’s account. Regardless, all Personal Data which we may process shall be in accordance with this Policy and other applicable laws..

COLLECTION OF PERSONAL DATA

In the course of your engagement with us or with third parties through our Platforms, we may collect your Personal Data and non-Personal Data in the following ways:
  • Automatic Information collection: We may automatically collect Information upon your engagement with us or our Platforms through your computer, mobile phones, forms, documents made available to us and other access devices. The information sent includes, but is not limited to, data about our pages you access, geo-location information; statistics on page views; traffic to and from our Platforms.
  • Information from downloads: When you download or use our digital Platforms or access our site, we may receive non-personal information from your mobile device about your location, number of downloads, geolocation of downloads. You may disable your location in the settings menu of the device.
  • Physically or Digitally Provided Personal Data:We may collect and process your Personal Data when you create and/or update your account on our Platform; complete forms, questionnaires, surveys etc. We may also collect Personal Data from the information you provide to us through documents, letters, e-mail, agreements, correspondence, ID cards, passports, or through any other means by which you wilfully provide information to us. When you use Esportcave Services, we may also collect Personal Data about your transactions and your activities. In addition, when you open an account on our Platform, we may collect Personal Data such as your contact information, which includes your name, address, phone number, email or other similar information; financial information such as your full bank account numbers and/or credit card or debit card numbers.
  • Third Parties: We may also receive your Personal Data from third parties such as, guardians, financial institutions, identity verification services, vendors, and service providers etc.
  • Social Media: We also receive Personal Data through your engagements with us on social media sites (e.g., Facebook, Instagram, LinkedIn, Twitter, etc). This includes but are not limited to your replies to our posts, your comments, enquiries, messages to us, etc. We may also collect Personal Data from your public profile and updates on social media.

ACCESSING YOUR PERSONAL DATA

When accessing our Platforms, we may collect Personal Data about you and your interactions with the Services to which we undertake to keep secure and confidential.
When accessing our Platforms, we may collect Personal Data about you and your interactions with the Services to which we undertake to keep secure and confidential.
When you download or use our mobile applications or access one of our mobile optimized sites, we may receive Personal Data about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices allow you to control or disable location services in the device's setting menu. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or the manufacturer of your particular device.

USING YOUR PERSONAL DATA

In the course of your engagements with us or through our Platforms, we collect Personal Data for various legal reasons, largely to enable us to personalize your experience and to provide a more efficient service to you. Some of the reasons we collect Personal Data are to:
  • provide services and customer support;
  • process transactions, payment requests, and send notices about transactions
  • create an account with us for the provision or use of our services
  • communicate with you about your account or transactions with us and send you information or request feedback about features on our website and applications or changes to our policies
  • send you periodic emails and updates pertaining to our products and services
  • verify customers’ identity, including during account creation and password reset processes
  • manage your account and provide you with efficient customer service;
  • send you offers and promotions for our services and investment opportunities
  • resolve disputes, process payments and troubleshoot problems
  • detect, investigate and prevent activities that may violate our policies or be illegal
  • manage risks, or to detect, prevent, and/or remediate fraud, violation of policies and applicable user agreements or other potentially prohibited or illegal activities
  • execute our contractual obligations to you
  • improve our services and functionality by customizing user experience
  • measure the performance of our services and improve their content and layout
  • manage and protect our information technology infrastructure
  • provide targeted marketing and advertising, provide service or transaction update notices, and deliver promotional offers based on communication preferences
  • obtain a means by which we may contact you either by telephone, text (SMS), email messaging, social media, etc
  • conduct background checks, compare information for accuracy and verify same with third parties
  • identify or address a violation and administer our policies and terms of use
  • comply with legal, contractual and regulatory obligations
  • execute your specific requests or use same for a specific purpose as you may instruct
  • investigate and respond to your complaints or enquiries
  • process your access to our services, Platforms, or functions from time to time
If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is required and obtain your consent.

LAWFUL BASIS FOR PROCESSING

We can only use your Personal Data if we have a lawful basis for doing so. We consider that the lawful basis for processing your Personal Data are as follows:
  • To comply with our legal and regulatory obligations
  • To perform a contract with you or to take steps at your request before entering into a contract
  • If we have your consent for specific processing of your Personal Data for one or more specific purposes
  • To use your Personal Data in our business interest to enable us to give you the best services
  • For the performance of a task or function carried out in the interest of the public
  • When it is required for the protection of your vital interests.

STORAGE AND PROTECTION OF YOUR PERSONAL DATA

We protect your Personal Data using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, unauthorised disclosure and alteration. Some of our safeguards include firewall protection, Virtual Private Network (VPN) protection, encryption of data, authorization keys for authorised access and strong passwords. Access to our various platforms is restricted to authorized users only. Your Personal Data is also stored on our secure servers as well as secure physical locations and cloud infrastructure (where applicable). Please be aware that, despite our best efforts, no security measures are perfect or impenetrable.
We will retain your Personal Data for the length of time needed to fulfil the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law. To dispose of Personal Data, we may anonymize it, delete it or take other appropriate steps. Personal Data may persist in copies made for backup and business continuity purposes for additional time.
We will take all necessary measures to ensure that your Personal Data is safe, however, you are also required to ensure that access codes, PINs, passwords, usernames, and all other information or hints that may enable third-party access to your accounts on our Platforms are secure. We therefore strongly advise you to keep such information secure and confidential. If you use a third party’s device (laptops, phones, public internet, etc.) to access your account, kindly ensure that you always log out. Kindly note however, that certain devices are programmed to save passwords or usernames, as such, we advise that you use third-party devices with extreme caution. If you believe that an unauthorized person has accessed your information, please contact us immediately.

PROCESSING YOUR PERSONAL DATA

In order to execute our obligations to you or process your transactions, we may be required to process your Personal Data, such as your name, account number, account ID, contact details, shipping and billing address, or other information needed to complete the transaction. We also work with third parties, including financial institutions, vendors, service providers, who at one point or the other facilitate transactions executed on our Platforms. For completeness, in the course of your engagement with us or use of our services and Platforms, we may share your Personal Data with different stakeholders, including but not limited to Financial institutions; service providers; Credit bureaus and collection agencies to report account or credit information; Esportcave subsidiaries and affiliates; Regulatory or judicial authorities; or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Esportcave. Please note that the aforementioned parties may be within or outside Nigeria.
We may also process your Personal Data when we believe, in our sole discretion, that the disclosure of your Personal Data is necessary to comply with applicable laws and judicial/regulatory orders; conduct investigations; manage existing or imminent risks, prevent fraud, crime or financial loss, or for public safety or to report suspected illegal activity or to investigate violations of our Terms and Conditions.
In all cases, we will ensure that your Personal Data is safe, and notify the receiving party of the confidential nature of your Personal Data, particularly the need to maintain the confidentiality of same and prevent unlawful or unauthorised usage.

YOUR RIGHTS AS A DATA SUBJECT

You have the following rights regarding your Personal Data collected by us:
  • Right to access your Personal Data being held by us. Request for such information may be sent to [*].
  • Right to request that your Personal Data be made available to you in an electronic format or that it should be sent to a third party (Kindly note that we have the right to decline such request if it is too frequent, unreasonable, and likely to cause the substantial cost to us. In any event, we will communicate the reason for our refusal);
  • Right to rectify any inaccurate, incomplete Personal Data. As such, if you discover any inaccuracy in your Personal Data, kindly notify us promptly and provide us with documentary evidence to enable us to update the requisite changes.
  • Right to withdraw consent for the processing of your Personal Data, provided that such withdrawal shall not invalidate any processing hitherto done based on the consent previously given by you;
  • Restrict or object to the processing of your Personal Data provided that we may be compelled to process your Personal Data where required under law, regulatory authorities, or court of law.
  • Right to request that your Personal Data be deleted. We may however continue to retain the information where required under law, contract, regulatory authorities, or court of law.

DISCLOSURES OF PERSONAL DATA

We may share your Personal Data with:
  1. Members of Esportcave to provide joint content, products and services (such as registration, transactions and customer support), to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about their products, services, and communications. Members of the group will use this Personal Data to send you marketing communications and opportunities only if you have requested their services.
  2. Credit bureaus and collection agencies to report account or credit information, as permitted by law.
  3. Companies that we plan to merge with or are acquired by. (Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to your Personal Data. If your Personal Data could be used contrary to this policy, you will receive prior notice).
  4. Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Esportcave or one of its agents; when we need to do so to comply with law; or when we believe, in our sole discretion, that the disclosure of Personal Data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement.
Other unaffiliated third parties, for the following purposes:
  1. Fraud Prevention and Risk Management: to help prevent fraud or assess and manage risk.
  2. Customer Service: for customer service purposes, including to help service your accounts or resolve disputes.
  3. Legal Compliance: to help them comply with anti-money laundering and counter-terrorist financing verification requirements.
  4. Service Providers: to enable service providers under contract with us to support our business operations, such as fraud prevention, marketing, customer service and technology services. Our contracts dictate that these service providers only use your Personal Data in connection with the services they perform for us and not for their own benefit.

CROSS-BORDER TRANSFERS OF PERSONAL INFORMATION

We operate globally, and in a bid to serve you better, we may transfer your Personal Data to third parties in locations around the world for the purposes described in this Privacy Policy. That notwithstanding, Esportcave is committed to adequately protecting your Personal Data regardless of where the Data is transferred or hosted. Please be rest assured that all our affiliates are bound by the same level of strict confidentiality with respect to your Personal Data.

SOFTWARE

If you download or use our software, such as a stand-alone software product, an app, or a browser plugin, you agree that from time to time, the software may download and install upgrades, updates and additional features from us in order to improve, enhance, and further develop the software. We may utilise your Personal Data to internally evaluate our software.

PERIOD OF STORAGE

We retain your Personal Data for as long as necessary for the purpose(s) for which it was collected. The period of data storage is also subject to legal, regulatory, administrative and operational requirements.

Exceptions

Please note that this Policy does not apply to Information that is already in the public domain through no fault of ours.

DATA BREACH / 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, we reserve the right to restrict your access to our Platforms and shall within 72 (Seventy-Two) hours of having knowledge of such breach report the details of the breach to NITDA. Furthermore, where we ascertain that such breach is detrimental to your rights and freedoms in relation to your Personal Data, we shall 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.

DISPUTE RESOLUTION

We are dedicated to ensuring that you are satisfied with our management of your Personal Data. However, in the unlikely event that you have a complaint, please contact us via the details below, stating your name and details of your complaint. Upon receipt of your complaint, we will endeavor to contact you within 3 (three) working days with a view to amicably resolving such dispute within the shortest possible time. The foregoing notwithstanding, all disputes arising from this policy shall first be resolved by negotiation. However, if parties fail to resolve the disputes amicably by such mutual consultations, parties shall further attempt to resolve the dispute by mediation.

CONTACT US

If you have questions regarding your data privacy rights or would like to submit a related data privacy right request, kindly contact us via the information below:

Esportcave Limited

Please allow up to 1 (One) month for requests to be processed. The Company reserves the right to charge a reasonable fee to process excessive or repeated requests.

AMENDMENT

We may amend or revise this Policy at any time by posting a revised version on our website. Notice of the amendment shall be posted on our website and the revised version will be effective from the date of publication. Kindly, note that your continued use of our Platform after the publication of the revised version constitutes your acceptance of our amended terms of the Policy.