Privacy Policy

In the course of providing products or services to you or our client and performing due diligence checks in connection with our products or services (or discussing the possible products or services we might provide), we generally collect personal information about you from a variety of sources, such as: website visits, applications, identification documents, curriculum vitae, personal financial statements, interactions with relationship managers, and other third parties (credit bureaus, payment gateways, other financial institutions…) and other written or electronic communication reflecting information such as your name, address, passport details, identification numbers, biometric information, telephone number, occupation, assets, income and any other information we deem necessary.

The personal information that we may collect depends on the specific services, activities or products we undertake but typically includes: your name; age; date of birth; gender; home address; email address; BVN; telephone number; other contact details; country of residence; passport number and other national ID numbers; employment details (for example, the organization you work for, your job title); family circumstances (for example, your marital status where you enter it in a form on our website or it appears in any documentation you provide to us); financial information (for example, your income, bank statements, where you enter such information in a form on our website or it appears in any documentation that you provide to us or authorize us to access from your bank and financial institutions); details of how you use any product or service provided by Operation Smile Foundation; postings on any blogs, forums, wikis, and any other social media applications and services that we provide; IP address; browser and device type; user name that is used by you for one of our products or services; language; access times and duration; details of how you like to use our website or the interactive products, tools, other technology or services we provide to you or our clients; websites that you visited before and after visiting our website; details of how you like to interact with us, and similar information.

The types of personal information and ‘sensitive’ or ‘special categories’ of personal information that we collect will generally vary depending on the nature of the products and services that we provide to you and how you use our website. In some cases, the ‘sensitive’ or ‘special categories’ of personal information that we collect may include information collected as part of KYC and anti-money laundering checks that we must conduct before accepting you as a customer.

In some rare circumstances, we will also gather other ‘special categories’ of personal information about you because you volunteer that data to us (for example, it appears in a copy of your resume/CV that you upload to our website). In some other circumstances, the personal information we collect from you is needed to meet our legal or regulatory obligations or to provide you with the products or services requested by you.

In some cases, we may also collect personal information about you indirectly from third parties including but not limited to:

- your employer

- third parties such as providers of ‘know your client’ and anti-money laundering services which we use to help us meet our legal requirements in this area and to help us verify your identity where we provide you with products or services

- background check providers which we sometimes use to verify your identity when you apply for a product of ours
third party service providers that help us to operate our website

- your banks and financial institutions.

We will use your personal information to provide you with products or services. As part of this, we may use your personal information in the course of correspondence relating to those products or services. Such correspondence may be with you, our customers, our service providers or public or judicial authorities with the necessary authorization.

In many cases, we also use your personal information to conduct due diligence checks in advance of providing products or services to you, and to process an application from you or a prospective client to receive products or services from us. If you are referred to us by an intermediary or similar third party, we also typically use your personal information to assess whether to accept or reject your referral to Operation Smile Foundation by that intermediary or similar third party.

We use the information we collect from all of our services to provide, maintain, protect and improve them, to develop new ones, and to protect Operation Smile Foundation and our users. We always safeguard the confidentiality of information provided to us by our Members.
We may use information about you for purposes such as:

- Enabling you to access and use our Services
- To manage and improve our website
- Sending you marketing, advertising, educational content and promotional messages and other information that may be of interest to you, including information about us, our Services, or general promotions for business partner campaigns and services. You can unsubscribe or opt-out from receiving these messages.
- To administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners
- Measuring, customizing and improving the Services and developing new products
- Sending to you service, support and administrative messages, reminders, technical notices, updates, security alerts and information requested by you
- Investigating and preventing fraudulent transactions, unauthorized access to Services, and other illegal activities
- Requests and communications from public or judicial authorities
- Financial accounting, invoicing and risk analysis purposes
- Recruitment and business development purposes
- Protecting our rights and those of our customers
- Client relationship purposes, which involve contacting you to receive feedback on Operation Smile Foundation products or services and contacting you for other marketing or research purposes
- For other purposes about which we obtain your consent
You may request the complete removal of your information from our systems at any time; such removal will be completed within 30 days of our receipt of your written request.

We are continually striving to improve our Service. Being able to identify how our Members are using our Services plays a major role in helping us make our software better.

Whenever you use our services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request.

We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems).

Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.

Also, OSFng respects the privacy of children. We do not knowingly collect names, email addresses or any other personally identifiable information from children. We do not knowingly market to children nor do we allow children under 18 to open online accounts."

How We Protect Your Information
We take appropriate technical and organizational measures to prevent loss, unauthorized access, misuse, modification or disclosure of information under our control. This may include the use of encryption, access controls and other forms of security to ensure that your data is protected. We require all parties including our staff and third-parties processing data on our behalf to comply with relevant policies and guidelines to ensure confidentiality and that information is protected in use, when stored and during transmission. Our security controls and processes are also regularly updated to meet and exceed industry standards.

Where We Store Your Information
All Personal Information you provide to us is stored on our secure servers as well as secure physical locations and cloud infrastructure (where applicable). The data that we collect from you may be transferred to and stored at a destination outside Nigeria or the European Economic Area (“EEA”). Whenever your information is transferred to another location, we will take all necessary steps to ensure that your data is handled securely and in accordance with this privacy policy.

How Long We Store Your Information
We retain your data for as long as is necessary for the purpose(s) that it was collected. Storage of your data is also determined by legal, regulatory, administrative or operational requirements. We only retain information that allows us comply with legal and regulatory requests for certain data, meet business and audit requirements, respond to complaints and queries, or address disputes or claims that may arise.

Data which is not retained is securely destroyed when it is identified that is no longer needed for the purposes for which it was collected.

Our Privacy Policy applies to all of the services offered under Operation Smile Foundation and its affiliates and services offered on other sites (such as our advertising services), but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not apply to products and services offered by other companies or individuals, including sites that may include Operation Smile Foundation services, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services.

Compliance and cooperation with regulatory authorities
We regularly review our compliance with our Privacy Policy. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

Updates to our privacy policy
Last modified: November 12, 2020

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes).
Your continued use of the Services will be deemed acceptance of any updated policy.