This Policy applies to the services provided by SparkApp NG Ltd (, “Spark”, “Spark App”, “We”, “Us” or “Our”).
Collection and Control of Personal Information
As part of our operations, We may collect offline or online data that makes a person identifiable such as names, addresses, e-mail addresses, usernames and passwords, digital footprints, photographs, National Identity Numbers, financial data etc.
Personal information provided by you when We initiate a business relationship should be accurate and relevant to enable us to process your request. You consent to our collection, use, storage and disclosure of this information to appropriate third parties for the purposes described in this policy.
Spark will ask you to grant us permission to continually have access to your Contacts on your mobile device, mainly the names and phone numbers of your Contacts as you have saved them on your mobile device. We ask for this permission so we can always and accurately let you know which of your Contacts are, or are not, already using Spark, so we can maintain an amazing transaction experience for you.
Information You Provide to Us
Customers: we collect personal information from our customers when you apply for an account or when you communicate with us about your account. You may edit your account profile information by logging into your account via our services. If you wish to delete or deactivate your online account, please contact us, but note that we may retain certain information as required by law or for legitimate business purposes. You may opt out of receiving promotional emails and text messages by following the instructions in those messages. Please note that if you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.
Business partners: we collect and process personal information of relevant prospects, customers and partners before we establish, execute or terminate a contract.
Information About Your Transactions with Us
We collect personal information in connection with each transaction, including transaction time, amount and merchant or beneficiary details. We may also collect photos, memos or other information that you attach to your transactions.
For clarity, personal information means any information, whether sensitive or non-sensitive, that can, by itself or in combination with other information that is readily available, identify an individual.
Information from Other Sources
We may collect personal information from nonaffiliated third parties, such as statutory authorities, to verify your identity and for fraud prevention purposes when you create an account. It may include your prior address and names. The information may come from you or our affiliates and third parties. When providing personal information about others like employees, dependents, you must obtain their consent prior to your disclosure to us.
Social Sharing Features
You can engage with us through social media websites or features such as plug-ins or applications on our services that integrate with social media sites. You may also choose to link your Spark Account to third party social media sites. When you link your account or engage with us on or through third party social media sites, plug-ins, or applications, you may allow us to have ongoing access to certain information from your social media account (e.g., name, e-mail address, photo, gender, birthday, the posts or the ‘likes’ you make).
If you post information when you interact with our websites through social media sites, plug-ins or other applications, depending on your privacy settings, this information may become public on the internet.
Information We Collect Automatically from Our Services
When you access or use our services, we automatically collect information about you as follows:
Log Information: We log information about your use of our services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our services.
Device Information: we collect information about the computer or mobile device you use to access our services, including the hardware model, operating system and version, unique device identifiers and mobile network information.
If you initially consent to the collection of location information by Spark or google maps within our mobile application, you may be able to subsequently stop the collection of information through your device operating system settings or your online account settings. If either of these opt-out options are not available to you, you may also disable location information by following the standard uninstall process to remove our mobile application from your device.
Information collected by cookies and other tracking technologies: We use various technologies to collect information on our services and other websites, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve our services and your experience, see which areas and features of our services are popular and count visits. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our services.
We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.
These cookies and tracking pixels are served from third-party services that may serve their own cookies. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
Protection of Personal Information
Spark collects personal information in a transparent way with the cooperation and knowledge of interested parties. The personal information collected is processed in a lawful, fair, and transparent manner. Personal information available to us are protected in the following manner:
Our data is always:
1. Accurate and kept up-to-date.
2. Collected fairly and for lawful purposes only.
3. Processed by Spark within its legal and moral boundaries and in line with the laws of Nigeria.
4. Protected against any unauthorized or illegal access by internal or external parties.
Our data will not be:
- Communicated informally
- Stored for more than a specified amount of time
- Transferred to organizations, states or countries that do not have adequate data protection policies
- Distributed to any party other than the ones agreed upon by the data owner (exempting legitimate requests from law enforcement authorities or by an order of a court of competent jurisdiction)
Spark is the sole owner of the information collected on our services. Spark will not sell or rent this information to anyone. Spark is based in Nigeria and the information We collect is governed by Nigerian law.
Spark takes reasonable measures to help protect all information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Additionally, Spark implements policies designed to protect the confidentiality and security of your personal information.
To protect our customers, only employees, agents and contractors who need your information to service your accounts have access to the information you provide us. We also give you information that can help you keep your personal information safe.
Here are some of the ways we protect you:
- We use anti-virus protection to help us detect and prevent viruses.
- Our firewalls help block unauthorized access by individuals or networks
- We use encryption software to create a secure connection with your browser when you login, or fill out an application, or register in online services
- We don’t and will not share your usernames and passwords with anyone
- We automatically log you out of your secure session after a period of inactivity to help protect against others seeing or using your online accounts
- We monitor activities for potential fraud
- We will only retain personal information for as long as is reasonably necessary and as long as we are providing services to you. Where you close your account, your information is 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 the applicable law.
Disclosure Of Personal Information
We may disclose any information we collect as follows:
(1) To your financial service providers, including the financial institutions identified in your Spark account registration application that provide banking services in connection with your Spark account;
(2) To statutory bodies in accordance with Nigerian law;
(3) To another user, when you sign up for Spark’s services via a referral link. The user that referred you may receive information indicating that you have enrolled with Spark. You may avoid this sharing by not using a referral link to enroll;
(4) To business partners, affiliated companies and authorized service providers, we disclose personal information to as is necessary to provide our products and services. These service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements. We do not rent, sell or otherwise disclose personal information about our online visitors with unaffiliated third parties for their own marketing use.
(5) To anybody where you have given express consent to such disclosure.
(7) With other non-affiliated companies for our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations or report to credit bureaus. For example, in connection with our everyday business purposes, we may share information about you as follows:
- In response to a request for information, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process; with relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud; if we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Spark or others;
- In connection with, or during negotiations of, any merger, sale of Spark’s assets, financing or acquisition of all or a portion of our business to another company; and with your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.
(8) We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. For example, we may share transaction zip codes and merchant names with third parties to improve our accuracy in geo-locating transactions and to improve the clarity of transaction descriptions.
Transfer of Data
Your personal information collected by us may be stored and processed outside Nigeria in a location where, our affiliates, or our data processors maintain facilities. Whenever we transfer your Personal Data out of Nigeria, we ensure a similar degree of protection is afforded to it by ensuring adequate safeguards are implemented. We ensure your Personal Data is protected by requiring all Our affiliates and processors to follow the same rules when Processing your Personal Data.
Data Protection Rights
It is important to us that you are fully aware of all your data protection rights. Every user of Our service is entitled to the following:
- You have a right to request copies of your personal information.
- You have the right to request that we transfer the information that we have collected to another organization, or directly to you, under certain conditions.
- You have the right to request that we restrict the processing of your personal information, under certain conditions.
- You have the right to object to our processing of your personal information, under certain conditions.
- You have the right to request that we correct any information you believe may be inaccurate. You also have the right to request that we complete information you believe may be incomplete.
- You have the right to request that we erase your personal information, under certain conditions.
- You have the right to withdraw consent at any time where we are relying on consent to process your personal information.
Updates and changes to privacy statement
We may change this policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and in some cases, we may provide you with additional notice (such as by adding a statement to the homepages of our website or mobile application or by sending you an email notification). We encourage you to review the policy whenever you interact with us to stay informed about our information practices. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the course of your relationship with us.
How to Contact Us
If you feel that we are not abiding by this policy, object to our processing of your personal information or you would like to exercise any of your data protection rights, please contact us immediately via email at email@example.com. For further enquiries, you may reach us at:
Office Address: NO 16 IDOWU MARTINS, VICTORIA ISLAND, LAGOS ISLAND, LAGOS STATE.
Where you are not satisfied treatment of your complaint and you wish to make a further complaint to the Nigeria Data Protection Bureau (NDPB), you may contact the NDPB office.
The NDPB’s address: No. 5, Donau Crescent, off Amazon Street, Maitama, Abuja, Nigeria.
Helpline number: +234 703 116 7741.
NDPB website: https://ndpb.gov.ng/