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VerifyNIN Services
Verify NIN Online
Privacy Policy
VerifyNIN Services - Privacy Policy
We are VerifyNIN Services (we, us, our). We are a registered business with Business number BN3220641 and our registered office is at 3 New world city,Ugbuwangue Warri Delta State.
We are committed to protecting the privacy and security of the personal data which we process for you.
This Privacy Policy describes how we collect, use and look after your personal data when you use VerifyNIN Services, powered by VerifyNIN Nigeria (the Services), our online software application made available at https://verifynin.ng/ (our Website) or when you visit the Website (regardless of where you visit it from). It also tells you about your rights and how the law protects you.
To assist you in understanding this Privacy Policy, we have set out in the Schedule a glossary of terms used in this Privacy Policy, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.
1. About this Privacy Policy
1.1 This Privacy Policy supplements the other notices and terms published on our Website (including the VerifyNIN Services Access Terms (the Access Terms) and our Website Terms of Use (the Website Terms) and is not intended to override them.
Where you are the controller of personal data
1.2 Our Solution enables you to undertake and access the results of checks (including identity and document verification checks, business and company register checks, and/or background checks) undertaken in respect of third parties, including your clients and potential clients. Carrying out these checks involves the processing of personal data relating to individuals, including clients who are themselves individuals, and employees or representatives of clients which are corporate entities.
1.3 When you use VerifyNIN Services to undertake checks you will be the controller of, and responsible for, the personal data collected and processed in the course of carrying out the checks. We will act as a processor in respect of all such personal data.
1.4 Further information about how we process personal data about your clients and potential clients when you use VerifyNIN Services to undertake checks is set out in the Access Terms. The remainder of this Privacy Policy deals with the situation where we collect and use personal data relating to you and your representatives in connection with your use of the Solution, or when you visit our Website.
Where we are the controller of personal data
1.5 We are the controller of, and are responsible for, the personal data we collect about you and your representatives when you use the Solution, or when you visit our Website. References in the remainder of this Privacy Policy to personal data refer to personal data of this type (and not the personal data about your clients and potential clients which we may process when you use VerifyNIN Services to undertake checks).
Where a third party is the controller of personal data
1.6 Our Website may include links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control over these third-party websites, plug-ins or applications and are not responsible for their Privacy Policies, therefore you should read their Privacy Policies to understand what personal data they collect about you and how they use it.
2. The data we collect about you
2.1 We may collect, use, store and transfer the types of personal data about you listed in Part 1 of the Schedule.
2.2 We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.
2.3 Our Website is not intended for children and we do not knowingly collect data relating to children.
2.4 When you use the Solution, or when you visit our Website, we do not collect any special categories of personal data or any information about criminal convictions and offences. By contrast, when you use the Solution to undertakes checks in respect of your clients and potential clients we may process special categories of personal data – information on these processing activities is contained in the Access Terms (and not in this Privacy Policy).
2.5 If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it:
2.5.1 we may not be able to enter into or perform the contract with you; and/or
2.5.2 we may have to cancel the supply of services to you and/or the contract (as applicable).
We will notify you of this at the relevant time if applicable.
3. How personal data is collected
We collect personal data in the following ways:
Direct interactions | You may provide personal data when you order services from our Website or otherwise correspond with us (by post, phone or email) or where we contact you to ask you to leave a review of our services. |
Publicly available sources | We may collect personal data from publicly availably sources such the Electoral Register and credit reference agencies, based inside Nigeria. |
Third parties | We may receive personal data from: (a) analytics providers based outside Nigeria, such as Google or Salesforce; (b) advertising networks; (c) search information providers; and (d) our suppliers such as website support and maintenance providers. |
4. How we use your personal data
4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:
4.1.1 to perform the contract we are to enter into or have entered into with you for the sale and supply of services;
4.1.2 to comply with a legal obligation; or
4.1.3 where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4.2 Part 2 of the Schedule sets out the lawful basis we will rely on to process your personal data.
4.3 Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your
5. Change of purpose
5.1 We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose or we have a lawful basis to change the purpose.
5.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to use your personal data in this manner.
5.3 We may process your personal data (without your knowledge or consent) where this is required or permitted by law.
6. Marketing
6.1 You will only receive marketing communications from us, if you have:
6.1.1 purchased services from us; or
6.1.2 you have provided your consent to receive marketing communications;
and have not opted out of receiving marketing communications, unsubscribed from our mailing list or withdrawn your consent.
6.2 We may ask you as part of our follow-up process to leave a review of our services.
6.3 We will not share your personal data with third parties for their marketing purposes.
6.4 How to opt out – You can opt out of email marketing by clicking the unsubscribe button within the particular marketing email. You can also withdraw your consent to receive marketing communications and asked to be removed from our mailing list at any time by contacting us.
6.5 Even if you opt out of receiving marketing communications, we may still use your personal data for other purposes provided we have a lawful basis to do so.
7. Disclosure of your personal data
7.1 We will only share your personal data with the Third Parties set out in Part 4 of the Schedule. We require all Third Parties to respect the security of your personal data and to treat it in accordance with the law. Such Third Parties can only process your personal data for specified purposes and in accordance with our instructions.
7.2 Some Third Parties may be based outside of Nigeria, and therefore your personal data may be transferred outside of Nigeria. Whenever we transfer your personal data out of Nigeria, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
7.2.1 we will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data;
7.2.2 we use specific contracts which give personal data the same protection it has in Nigeria with our service providers.
8. Data security
8.1 We operate appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access to personal data is restricted to individuals who have a business need to know it, are under confidentiality obligations and can only process it on our instructions.
8.2 We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data retention
9.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
9.2 We may update our data retention practices from to time and you can request details by contacting us. However, we are legally required to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after the end of the tax year in which they cease being customers, for tax purposes.
9.3 We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.
10. Your legal rights
10.1 Your legal rights in relation to your personal data are set out in full in Part 3 of the Schedule. If you wish to exercise any of your rights, please contact us.
10.2 You will not have to pay a fee to exercise any of your rights unless your request is clearly unfounded, repetitive or excessive. In which case, we may charge a reasonable fee for this information or refuse to comply with your request.
10.3 We may ask you to provide further information to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.
10.4 We aim to respond to all legitimate requests within one month. If your request is particularly complex or you have made a number of requests, it may take us longer to respond. In this case, we will notify you and keep you updated.
11. Contact details
11.1 If you have any questions about this Privacy Policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
Email address: support@verifynin.ng
Postal address: VerifyNIN Services, 3 New world city, Ugbuwangue, Warri Delta State.
12. Complaints
12.1 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), Nigeria Data Protection Commission (NDPC) (www.ndpc.gov.ng). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
13. Your duty to inform us of changes
13.1 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
14. Updates
14.1 We may change this Privacy Policy from time to time by updating this page. Please check it regularly to ensure that you are aware of any changes.
14.2 This Privacy Policy was last updated in January 2025.
Schedule
Part 1 – Types of personal data
Contact data | Billing address, email address and telephone number. |
Financial data | Bank account and payment card details (collected by Systemspecs/Remita,Rave/Flutterwave/Pastack in connection with payments you make in connection with the Solution, in accordance with their privacy notice at Privacy Policy (verifynin.ng)). |
Identity data | First name, last name, username or similar identifier, title. |
Marketing and communication data | Your preferences in receiving marketing from us and our third parties and your communication preferences. |
Profile data | Your username and password, and orders made by you. |
Transaction data | Details about payments to and from you and other details of services you have purchased from us. |
Part 2 – Lawful basis for processing and processing activities
The lawful basis upon which we may rely on to process your personal data are:
Consent | You have given your express consent for us to process your personal data for a specific purpose. |
Contract | The processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you. |
Legal obligation | The processing is necessary for us to comply with a legal or regulatory obligation. |
Legitimate interests | The processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you via our Website. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest. |
Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.
Purpose/Activity | Type of data | Lawful basis for processing |
To register you as a new customer. | Contact and identity | To perform our contract with you. |
To process your order, manage payments, fees and charges and debt recovery. | Contact, financial, identity, marketing and communications and transaction |
|
To manage our relationship with you and notify you of changes to our Terms or Privacy Policy. | Contact, identity, profile, and marketing and communications |
|
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | Contact and identity |
|
To deliver relevant website content to you and measure or understand the effectiveness of our advertising. | Contact, identity, profile, marketing, communications | As necessary for our legitimate interests in studying how customers use our services, to develop them, to grow our business and to inform our marketing strategy. |
Part 3 – Your legal rights
You have the following legal rights in relation to your personal data:
Correction | You can ask us to correct any incomplete or inaccurate personal data we hold about you. |
Erasure | You can ask us to delete or remove your personal data where:
We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request. |
Object | You can object to the processing of your personal data where:
In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms and in such circumstances we can continue to process your personal data for such purposes. |
Restrict processing | You can ask us to suspend or restrict the processing of your personal data, if:
|
Request a transfer | You can request a transfer of your personal data which is held in an automated manner and in relation to which you provided your consent for us to process such personal data or which we need to process to perform our contract with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format. |
Withdraw your consent | You can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent. |
Part 4 – Third Parties
Service providers | Our IT and system administration service providers, acting as processors. Our debt collection agencies and other debt management service providers, acting as processors. Our customer relationship management software and service providers, acting as controllers and processors, (and the integrated applications we use as part of our service provision) who require your personal information to provide our services to you and otherwise manage our relationship with you. |
Payment Gateway Providers | Systemspecs/Remita,Rave/Flutterwave/Pastack, acting as a controller, who requires information to collect and process payments on our behalf for services ordered through our Website, debts or disbursements paid to us, or to issue refunds, and who will process your personal data in accordance with its processing terms which can be found here: Privacy Policy (verifynin.ng). |
Professional advisors | Acting as processors or controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. |
HM Revenue & Customs, regulators and other authorities | Acting as processors or controllers who require reporting of processing activities in certain circumstances. |
Other third parties | Such third parties whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy. |
Part 5 – Glossary
Aggregated data | Information such as statistical or demographic data which may be derived from personal data but which cannot by itself identify a data subject. |
Controller | A body that determines the purposes and means of processing personal data. |
Data subject | An individual living person identified by personal data (which will generally be you). |
ICO | Information Commissioner’s Office, Nigeria Nigeria Data Protection Commission (NDPC). |
Personal data | Information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data. |
Processor | A body that is responsible for processing personal data on behalf of a controller. |
Special categories of personal data | Information about race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life and sexual orientation. |