Trinity Financial Services (TFS) Privacy Policy

By accessing or using the Services, or by accepting our Terms and Conditions (the “Terms”) or any other terms that incorporate this Privacy Policy by reference, you agree on behalf of yourself and any organization that you represent (together, “you”) that you have read and understood this Privacy Policy and that you consent to the collection, use, and sharing of information as discussed below. If you do not agree with this Privacy Policy, do not access or use the Services or the Platforms. This Policy is incorporated into and made a part of our Terms and Conditions.

USERS’ PRIVACY RIGHTS

This Policy describes the User’s privacy rights regarding Trinity Financial Services' collection, use, storage, sharing, and protection of a User’s personal information on the Platforms and in respect of the Services.
If a User creates a username, identification code, password, or any other piece of information as part of the Platform’s access security measures, such information will be treated as confidential and will not be disclosed to any third party. Trinity Financial Services reserves the right to disable any User identification code or password, whether chosen by a User or allocated by the Platform, at any time if, in Trinity Financial Services' opinion, a User has failed to comply with any of the Terms (including this Privacy Policy). If a User is aware or suspects that anyone other than themselves is aware of a User’s security details, kindly notify Trinity Financial Services as soon as possible via the contact information provided below.

Trinity Financial Services
Data Protection Officer
19B, Odudu Eleyiwo Road Oniru, VI, Lagos.
info@trinityfinancialng.com

By continuing to use our website and mobile application (the “Mobile App”), you acknowledge and agree that you have carefully read and understood the terms of use and privacy policy.

Your rights in relation to Your Personal Data are as follows:
1. The right to have access to Your Personal Data.
2. The right to be informed about the processing of Your Personal Data.
3. The right to rectify any inaccurate Personal Data or any information about You.
4. The right to review, modify, or erase Your Personal Data and any other information we have about You.
5. The right to restrict the processing of Your Personal Data.
6. The right to block Personal Data processing in violation of any law.
7. The right to be informed about any rectification or erasure of Personal Data or restriction of any processing carried out.
8. The right to the portability of Your Personal Data.
9. The right to lodge a complaint to a supervisory authority within Nigeria.

USERS’ PERSONAL INFORMATION
Trinity Financial Services collects and uses any information you supply when you interact with the mobile app. This includes personal details like your name, Bank Verification Number, Valid Identification, address, and picture. By using the mobile app to transact, you also share details of your transactions with us. Additionally, we may request explicit permission to access other information like your address book, location, photos, and data from your camera.

Details you give when you sign up on the Mobile App, like your BVN, name, date of birth, gender, phone number, residential address, and email address. Images would also be collected for the purpose of KYC and other features like adding your profile picture. Information you give us through the in-app chat so we can help you. We shall also access your contact list information to enable you to perform certain functions like sending airtime and data to a person on your contact list. We may collect internet protocol (IP) address, browser type, device ID, internet service provider (ISP), information about your computer and software, links materials You request, your approximate location, referring/exit pages, date/time stamp, and other metadata. Platforms may embed Javascript code into page loads, which instructs Users’ web browsers to make web requests back to our servers to collect information about the User page views and other activities. We collect certain information from the User’s browser using small data files called “cookies”. The Platform may use session cookies to help recognize a User who visits multiple pages during the same session so that the User does not have to enter a password to access each page. Session cookies terminate once the User closes the browser. We also use persistent cookies to collect, store, and track information. The Platform uses persistent cookies to store the User’s login ID (but not the User’s password) to make it easier for the User to login when the User returns to the website. We encode our cookies so that only us can interpret the information stored in them. You can remove or block persistent cookies using the settings in your browser, but this may limit your ability to use our Platform. We may employ a software technology called clear gifs or web beacons that help us better manage content on the Platform as well as on the Platform emails, by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar function to cookies and are used to track the online movements of the Web users. In contrast to cookies, which are stored on a User’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence.

GOVERNING PRINCIPLES
Trinity Financial Services will always comply with the principles outlined below for the purpose of collecting, storing, and using a User’s personal information.

• Data shall be collected and processed with a specific, legitimate, and lawful purpose which shall be consented to by the User before collection and processing;
• Data may be further processed for archiving, scientific research, historical research, and statistical purposes for public interest without obtaining the consent of the User;
• Data collection and processing shall be adequate, accurate, and with consideration for the dignity of the human person;
• Data shall only be stored for the period which is reasonably needed and as required by the relevant and applicable laws; and
• Data shall be secured against all foreseeable hazards and breaches such as theft, cyberattack, viral attack, dissemination, and manipulations of any kind.

The lawful basis we rely on for processing your Personal Information are:
• Your consent; Where you agree to us collecting your Personal Information by using our Services.
• We have a contractual obligation: Without your Personal Information, we cannot provide our Services to you. Trinity Financial Services also has a legal obligation to ensure full compliance with all Anti-Money Laundering and Counter-Terrorist Financing Laws. Trinity Financial Services protects against fraud by checking your identity with your Personal Information.

SHARING AND PROTECTION OF USERS’ PERSONAL INFORMATION TO THIRD PARTIES
Trinity Financial Services provides such information to our subsidiaries, affiliated companies, or other trusted third-party service providers or persons for the purpose of processing personal information on our behalf, including validating user credentials, securing data storage, marketing, customer service, fraud detection, and other applicable services. Trinity Financial Services requires that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures we consider essential and relevant subject to applicable law. Trinity Financial Services requires that these third-parties providers use PII and PID only in connection with the services they perform for Trinity Financial Services.

Trinity Financial Services may share User information with law enforcement agencies, government officials, or other third parties in the event of a court order or similar legal procedure, regulatory disclosure, or when Trinity Financial Services believes in good faith that the disclosure of User information is necessary or advisable to report suspected illegal activity or to protect Trinity Financial Services' property or legal rights.

Except as expressly disclosed in this Privacy Policy, Trinity Financial Services will not sell or disclose User information to third parties. Trinity Financial Services may disclose aggregated or other types of non-personally identifiable information to third parties for various purposes.

SECURITY OF USERS’ PERSONAL INFORMATION
Trinity Financial Services has implemented physical, technical, and procedural safeguards to protect User information from unauthorized access, disclosure, alteration, or destruction. Trinity Financial Services uses computer safeguards such as firewalls and data encryption and authorizes access to personally identifiable information only for those employees, contractors, and agents who require it to fulfill their job
 responsibilities.

Trinity Financial Services utilizes a higher duty of care to protect User information, such as credit card or bank account numbers. If disclosure of a particular type of User information could cause direct financial loss, Trinity Financial Services further encrypts such information and transmits it under Secure Socket Layer (SSL).

Trinity Financial Services shall only retain personal information reasonably required to keep providing Services to you. Where Trinity Financial Services no longer provides services to you, your information will be stored on our servers to the extent necessary to comply with regulatory obligations and for the purpose of fraud monitoring, detection, and prevention. Where we retain your Personal Information, we do so in compliance with limitation periods under applicable law.

LOCATION
All Personal Information you provide to us is stored on our secure servers as well as secure physical locations and cloud infrastructure (where applicable) for the purposes of providing seamless services to you, including but not limited to ensuring business continuity. The data that we collect from you may be transferred to or stored in cloud locations at globally accepted vendors’ data centers. Whenever your information is transferred to other locations, we will take all necessary steps to ensure that your data is handled securely and in accordance with this privacy policy.

DATA CONFIDENTIALITY RIGHTS

REPORTING A PERSONAL DATA BREACH
Trinity Financial Services is required to comply with the Nigeria Data Protection Regulation 2019 (“NDPR”) and other relevant laws and regulations regarding reporting requirements in relation to data breaches and report any personal data breach where there is a risk to the rights and freedoms of a User. Where a personal data breach results in a high risk to a User, such a User also has to be notified unless subsequent steps have been taken to ensure that the risk is unlikely to materialize, security measures were applied to render the personal data unintelligible (e.g., encryption), or it would amount to disproportionate effort to inform the User directly. In the latter circumstances, a public communication must be made, or an equally effective alternative measure must be adopted to inform such a User so that he/she can take any necessary remedial action.

CHANGES TO THIS POLICY
We may amend this Privacy Policy at any time by posting a revised version on this page. The revised version will be effective at the time we post it unless we provide additional notice or an opportunity to “opt-in” because changes are material or retroactive. If you keep using our Services, you consent to all amendments to this Privacy Policy.
You can always see the most updated changes to this Privacy Policy here or by contacting our Data Protection Officer at Contact Us info@trinityfinancialng.com.

GOVERNING LAW
This Policy is made according to the provisions of NDPR and any other relevant Nigerian laws, regulations, or international conventions applicable to Nigeria.

April 2024