National Peer Group Educator Programme (NAPGEP) APP Privacy

This privacy policy governs your use of products, services, content, features, technologies or functions offered by Central Bank of Nigeria or through any of its agents/representatives (collectively referred to herein as “the Bank”) and all related sites, applications and services (collectively referred to herein as “National Peer Group Educator Programme (NAPGEP) services”) including, without limitation, when you provide any information in relation to your use of NAPGEP app. By voluntarily providing us with personal and other information, signing up for, accessing, or using the NAPGEP app, you accept and consent to this privacy policy.

Thereby, acknowledging and agreeing that such information may be transferred from your current location to the offices and servers of the bank and authorised third parties. For the avoidance of all doubt, by accepting and consenting to this privacy policy, you expressly consent to the bank’s collection, use, disclosure and protection of your personal information and hereby direct the bank to collect, use, disclose and/or protect such data in a manner consistent with the requirements of the law and this privacy policy.

Ownership

The app and its content, materials or information contained therein constitute the intellectual property of the Central Bank of Nigeria (CBN) and shall be used only in accordance with the Terms and Conditions contained herein or as may be revised from time to time by the CBN. The materials contained in this app are protected by intellectual property laws including copyright, patent and trademark laws and any unauthorized use may constitute intellectual property right infringement and violation of other relevant laws.

Overview

The Bank (hereinafter referred to as “we” or “us”) has adopted this Privacy Policy to govern the use of National Peer Group Educator Programme (NAPGEP) app Services by all users (hereinafter referred to as “you”). For the avoidance of doubt, this Privacy Policy applies to all users, unless otherwise expressly excluded by written agreement. By consenting to, and agreeing to the terms of this Privacy Policy, you expressly consent and agree to us processing the data you submit and/or generate in the manner set out herein. The Bank takes its access to such information very seriously and will use it only in accordance with the terms of this Privacy Policy, which describes the information we collect and how we use, share and protect that information. For the purposes of this Privacy Policy, the term “information” means any confidential and/or personally identifiable information or other information related to users of National Peer Group Educator Programme (NAPGEP) app.

Collection of Use of Data

We collect and may use information such as:

  1. Your account information which includes without limitation: name, address, phone number(s), email address, username, photograph, IP address, government-issued identification number(s), date of birth, physical address, and other information as may be determined by the Bank from time to time;
  2. Communications between you and us for customer service and/or other purposes (e.g., by emails, or phone calls);
  3. Data generated during the usage of the National Peer Group Educator Programme (NAPGEP) app.

Data Generated and Other Data

We also automatically collect and may use the following data:

  • Cookies: We use cookies on our National Peer Group Educator Programme (NAPGEP) app to collect data about your visit and to allow you to navigate from page to page without having to login again on each page. We use cookies to recognize you as a user, customize the app, content and advertising, measure promotional effectiveness, help ensure that your account security is not compromised, mitigate risk and prevent fraud, and to promote trust and safety on the app. Cookies also allow us to count visits and see which areas and features of our app are most popular. We do not link the information we store in cookies to any information you submit while on our app. However, our use of cookies and other technologies may allow us and third parties to collect information about your browsing activities over time and across different websites following your use of the app.

  • Analytics:When you visit use the app, we may use third party analysis tools to collect data about your computer and internet connection. That information includes the IP address of your computer and/or internet service provider, when you access the app, the internet address of websites from which you link to the app and from which you came before landing on the portal, the browser that you are using, and your navigation and preferences on the app. All this information is used internally for the purpose of understanding how the app is being used and improving our app. We may also use third party analysis tools to collect data about your use of our applications. The information collected identifies the nature and timing of the actions you take within our applications, including installation, registration, uploading, and certain types of navigation. All this information is used internally for the purpose of understanding how our applications are being used and to facilitate the improvement of said applications.

  • Site Management: We aggregate data that we collect about the use of our app for administration purposes, to protect and improve our app and our systems, to better understand the preferences of users and optimize the content that we serve, to identify server problems, to compile aggregated statistics about usage, and to improve our marketing and research.

    • Data Protection and Security

  • Data Protection:The Bank is committed to observing high standards of information security. We use computer safeguards such as firewalls and data encryption, enforce physical access controls to our buildings and files, and authorize access to personal information only for those employees who require it to fulfil their job responsibilities. While we use reasonable physical, electronic and procedural safeguards to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration and destruction, please be advised that we do not accept responsibility for the security of any data transmitted over the internet or information stored, posted or provided directly to a third-party website, which is governed by that third party’s policies.

  • Password Protection: Ability to securely use National Peer Group Educator Programme (NAPGEP) app also depends on your protection of your login credentials. We strongly recommend that you do not share your password(s) or security information with anyone. The Bank will never ask you for your password. Therefore, any email or other communication requesting your password or any similar security information should be treated as unauthorized and suspicious. In the event that you receive such a communication, please promptly forward it to [email protected]. If you do share your password(s) with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you will generally be considered responsible for any and all actions taken using your password. If you believe that someone else has obtained access to your password, please change it immediately by logging in to your account and changing your profile settings. We also recommend that you also contact [email protected] immediately.

  • Data Retention: Our retention and use of your information will be in accordance with applicable law, including our legal obligations, interest in resolving any disputes, and the enforcement of all relevant agreements. It is important to note that the retention period may extend beyond the end of your relationship with us, as required by law or as deemed necessary in our absolute discretion.

    • Data Sharing and Disclosure

    The Bank works with third-party service providers that offer important functions to us, which facilitate or support the service provided through the NAPGEP app in some way. We, therefore, disclose user data to such third-party service providers from time to time so that their services can be effectively performed. The Bank may also share your information for the purposes of fraud prevention, risk management, customer service, legal compliance and the provision of our services, particularly in circumstances where:

    1. You have consented or otherwise given us permission to share said information;
    2. We have aggregated or de-identified the information, so that it cannot reasonably be used to identify you;
    3. It is required by a third party service provider who we use in delivering our service, including certain advertising, referral, operations, financial services and technology services (such as hosting providers, identity verification, support, payment, and email service providers);
    4. It is, or we reasonably believe it to be, required by applicable law or legal process;
    5. It becomes necessary in order to protect the rights, property and safety of the Bank , our users and the public, including, for example, in connection with court proceedings, or to detect or prevent criminal activity, fraud, material misrepresentation, or to establish our rights or defend against legal claims.

    Other Websites, Social Medial Platforms and Online Services

    The NAPGEP app may incorporate links to other websites, social media platforms or online services, whose privacy policies may differ from those of the Bank. Please be aware that if you submit information to any such website, social media platform or online service, your information is governed by their privacy policies, which should be read carefully prior to use. The Bank is not responsible for the practices or procedures of such third parties.

    Notification of Changes

    This Privacy Policy may be revised over time as new features are added to the NAPGEP app or as we incorporate suggestions from our users. We may change this Privacy Policy at any time by posting a revised version of it in this location. Unless we have reasonable cause to do otherwise, we will provide you with at least 30 days’ prior notice of the effective date of the revised privacy policy. This notice may take the form of a post on first page of the app before you login and/or an email. As of the effective date of the revised privacy policy, you will be considered to have consented to all changes if you continue to use the app. If, however, you disagree with any terms of this Privacy Policy, you may request for the closure of your account at any time by contacting [email protected]

    Accountability

    The Bank is responsible for ensuring that our day-to-day practices and procedures comply with this Privacy Policy. Should you wish to access your information or have any questions about this Privacy Policy, the Bank’s information practices, or your relationship with the Bank, please feel free to contact us at [email protected].

    Governing Law

    This Terms and Conditions shall be governed, construed and enforced in accordance with the laws of the Federal Republic of Nigeria.