Privacy Policy

1. Introduction

This Policy applies to the Personal Data collected by Divest when you use our website, mobile application, social media platforms, tools and any other platform belonging to Divest (collectively, the "Services") or otherwise interact with us as described below. We may update this Policy from time to time and at our sole discretion. Where updates are made to the Policy, we will notify you of same by revising the date at the top of this Policy, and in some cases, provide you with additional notice (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 privacy practices as well as ways in which you can protect your privacy. By accessing or choosing to use any of our platforms, you agree to be bound by this Policy.

2. Consent

You accept this Policy when you give consent upon access to our platforms, or use our Services, technologies, features, content or functions offered on our website, mobile applications, digital platforms, social media, amongst other platforms which may be contemplated to be used by Divest.

3. Collection of Personal Data

You may be asked to provide your Personal Data, anytime you contact us or interact/access any of Divest's platforms, and we shall use your Personal Data in accordance with this Policy, relevant laws, regulations and implementation framework.

3.1 Categories of Personal Data

We collect Personal Data you provide to us when you apply for a Divest account or when you communicate with us about your Divest account. The types of Personal Data we may collect include, but not limited to, your name, address, phone number, email address, date of birth, bank account information, BVN, username, password, and next of kin details.

3.2 Personal Data About Your Transactions With Us

As you use your Divest account to perform financial transactions, we collect Personal Data in connection with each transaction, including transaction time, Naira amount and merchant details. We may also collect photos, memos or other information that you attach to your transactions.

3.3 Personal Data From Other Sources

When you create a Divest account, we may collect information about you, including Personal Data, prior addresses and names from non-affiliated third party service providers in order to verify your identity and for fraud prevention. Also, based on the fact that we work closely with third parties (including financial service providers, security agencies, etc), we will notify you when we receive information about you from them and the purposes for which we intend to use that information.

3.4 Other Personal Data we collect

We may collect Personal Data you provide to us, such as your name, email address and any other information you choose to provide. For example, we may collect such information if you request an invite to join Divest or if you enter into any contest or promotion. In a case where you choose to enable access to your contacts via our mobile application, we may upload your contact data to our servers so we can show you your friends who are also registered on the Divest platform as users.

3.5 Personal Data We Collect Automatically from our Services

When you access or use our Services, we automatically collect Personal Data and other 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.
• Location Information: We may collect your location information from your mobile device with your prior consent. Also, we have incorporated Google Maps into our Services, and you may consent to the collection of location information by Google Maps in connection with your use of this maps service. Any information collected via your use of Google Maps will be transmitted directly to Google and is not collected by us.
• Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information on our Services and other websites. Cookies are small data files stored on your hard drive or in device memory that help us to improve our Services and your experience. We may also collect information using web beacons (also known as "tracking pixels").
• How We Respond to Do Not Track Signals: We allow Do Not Track browser configurations. We use cookies and other tracking technologies, and Do Not Track status may alter the available services with certain browsers.

The app does use third party services that may collect information used to identify you. Links to privacy policy of third party service providers used by the app:

• Google Play Services
• AdMob
• Firebase Analytics
• Fabric
• Crashlytics
• Adjust
• Facebook

4. Use Of Personal Data

We may use your information, including Personal Data as follows:

• Provide, maintain and improve our Services
• Provide and deliver the products and services you request, process transactions and send you related information, including confirmations.
• Verify your identity and prevent fraud.
• Send you technical notices, updates, security alerts and support and administrative messages.
• Respond to your comments, questions and requests and provide customer service.
• Communicate with you about products, services, offers, promotions, rewards, and events offered by Divest and others, and provide news and information we think will be of interest to you.
• Monitor and analyze trends, usage and activities in connection with our Services.
• Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests.
• Process and deliver contest or promotion entries and rewards.
• Link or combine with information we get from others to help understand your needs and provide you with better service.
• Carry out any other purpose for which the information was collected.

Divest is based in Nigeria and the Personal Data we collect is governed by the General Application and Implementation Directive (GAID) 2025, and all other applicable data protection and privacy laws. By accessing or using the Services, you consent to the processing and transfer of your Personal Data in and outside Nigeria.

5. Lawful Basis For Processing Personal Data

We will only use your Personal Data if we have a proper reason for doing so. We consider the lawful basis for using your Personal Data as set out in the General Application and Implementation Directive (GAID) 2025. This include:

• To comply with our legal and regulatory obligations.
• To perform a contract with you or to take steps at your request before entering into a contract.
• To use your Personal Data as is necessary for our legitimate interests or the legitimate interests of others.
• To protect your interest, the interest of another Data Subject or for the performance of a task carried out in the public interest.

6. Disclosure Of Personal Data

We may disclose any information we collect about current and former customers to affiliates and non-affiliated third parties as follows:

• With financial service providers, including the financial institutions identified in your cardholder bank agreement.
• With another user, when you sign up for Divest's services via a referral link.
• With non-financial companies, such as email service providers that perform marketing services on our behalf.
• With a non-affiliated third-party to access and transmit your personal and financial information from a relevant financial institution.
• With other non-affiliated companies for our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations.
• In response to a request for Personal Data, if we are required by, or we believe disclosure is in accordance with, any applicable law.
• With relevant law enforcement officials 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.
• In connection with, or during negotiations of, any merger, sale of Divest's assets, or financing.
• With your consent or at your direction.

We will usually not share your Personal Data with other third parties without your consent. Where we need to transfer your Personal Data to another country, we shall ensure that such country has adequate and sufficient data protection laws.

7. Your Choices

7.1 Account Information: You may edit your Personal Data by logging into your account via our Services. If you wish to delete or deactivate your online account, please contact us.

7.2 Promotional Communications: You may opt out of receiving promotional emails and text messages from Divest by following the instructions in those messages.

7.3 Location Information: If you initially consent to the collection of location information, you may be able to subsequently stop this collection through your device operating system settings.

7.4 Cookies: Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject browser cookies.

7.5 Social Sharing Features: Our Services include social sharing features for common social networks to let users share content.

7.6 Analytics and Advertising Services Provided by Others: We may allow others to provide analytics services on our behalf and to serve advertisements on our behalf across the Internet.

8. Your Rights

General Application and Implementation Directive (GAID) 2025 gives you certain rights in respect of the Personal Data we hold about you:

• You have a right to consent to this Policy and to withdraw your consent at any time.
• You have a right to a copy of the Personal Data we hold about you.
• You have a right to freely transfer your data received from us to any other person.
• You have the right to have the Personal Data we hold about you corrected.
• In some circumstances, you have the right to the deletion of the information that we hold about you.
• You have a right to lodge a complaint with the Nigerian Data Protection Bureau (NDPB).
• You have the right to ask us not to process your Personal Data for marketing purposes.

9. Security

Divest takes reasonable measures to help protect all Personal Data about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. We have implemented strong controls and security safeguards at the technical and operational levels.

Where you have chosen a password that allows you to access certain parts of the website, you are responsible for keeping this password confidential. We have also taken measures to comply with provision of security facilities through the set up of firewalls, encryption and continuous capacity building.

10. Where We Store Your Personal Data

The Personal Data that we collect from you will be transferred to and stored at a destination outside Nigeria. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely.

11. How Long We Keep Your Personal Information

We will hold your Personal Data on Divest's systems in line with our Retention Schedule to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.

12. Breach Of Personal Data

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data, we shall, within 72 (Seventy-Two) hours of having knowledge of such breach, report the details of the breach to NDPC.

13. Governing Law

This Policy is made pursuant to the General Application and Implementation Directive (GAID) 2025 and other relevant Nigerian laws and regulations.

Contact Us

If you have any questions, comments or concerns about this Privacy Policy, please contact us at: compliance@divestpro.xyz

You can also write us as follows: compliance@divestpro.xyz