© 2020 Interswitch Group. All Rights Reserved.
Protected by The Nigeria Data Protection Regulation 2019
Privacy Policy
1 ABOUT ECLAT/INTERSWITCH
e'Clat Healthcare Limited is a wholly-owned Nigerian medical services company that aims to improve healthcare delivery in Africa using technological innovative frameworks. We specialize in assisting healthcare service providers in planning, designing, and operating their unique practices. Our products and services are essential building blocks for successful healthcare. We are a member of the Interswitch Group.
Interswitch is an Africa-focused integrated digital payments and commerce company that facilitates the electronic circulation of money as well as the exchange of value between individuals and organizations on a timely and consistent basis.
This privacy policy will explain how our organization uses the personal data we collect from our customers and related partners when you use our website or subscribe to use any of our products and services.
2 INTRODUCTION
Interswitch conducts business in a responsible and sustainable manner and ensures customer information is securely collected, processed, and stored based on business requirements. in furtherance of this and compliance with industry regulations, Interswitch has made appropriate documentation, which includes a privacy policy. Interswitch, therefore, provides notice about this policy, applicable procedures, and identifies the purposes for which personal information is collected, used, processed, disclosed, retained, and disposed of.
Throughout this Privacy Policy, we use the term “personal information or data” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been made anonymous so that it does not identify a specific user.
3 SCOPE AND CONSENT
As a Customer, you accept this Privacy Policy when you sign up for, access, or use our products, services, content, features, technologies, or functions offered on our website and all related sites, applications, and services (collectively referred to as “Interswitch Services”).
This Privacy Policy is intended to govern the use of Interswitch Services by users (including, without limitation those who use these Interswitch Services in the daily course of their trade, practice, or business) unless otherwise agreed through contract. Users reserve the right to exercise their data protection rights as listed under the Customer Data Protection Rights.
4 COLLECTION OF PERSONAL INFORMATION
We collect Personally Identifiable Information (PII), otherwise known as Personal Information or Personal Data. They include Name, email address, phone number, contact address, limited financial information, location data, device data, etc.
5 HOW WE COLLECT PERSONAL INFORMATION
Customers' data is collected electronically and manually when they visit our website and register to use any of our services. This is collected electronically with exchanges between your system (Computer, Server, Mobile Device) or service provider's system and our system.
We collect Customers' data manually when they complete our product and services registration forms in registering to use any of our services. Similar data are also collected when customers or visitors' visit our physical locations for inquiries or business relationship.
We collect information from or about customers from other sources, such as through your contact with us, including our Customer Support interfaces - email, portal, phone calls, social media, and other communication channels; Customer support teams, Customer response to surveys, Training programs, Corporate Social Responsibility events, Promotional events, and interactions with members of the Interswitch Group or other companies (subject to their privacy policies and applicable law).
We may also obtain information about you from third parties such as credit bureaus and identity verification services.
6 HOW WE USE COLLECTED INFORMATION
We collect personal information to provide users of our services with a secure, smooth, efficient, and customized experience. Furthermore, the information collected may also be used to provide Interswitch Services and customer support; process transactions and send notices about your transactions; verify your identity, including during account creation and password reset processes; resolve disputes, collect fees, and troubleshoot problems; manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities; detect, prevent or remediate violations of policies or applicable user agreements.
We also collect personal information to improve Services by customizing your user experience; measure the performance of the Interswitch Services and improve their content and layout; manage and protect our information technology infrastructure; provide targeted marketing and advertising, provide service update notices, and deliver promotional offers based on your communication preferences; contact you at any telephone number, by placing a voice call or through text (SMS) or email messaging; perform creditworthiness and solvency checks, and compare information for accuracy and verify it with third parties.
Additionally, we may contact you via electronic means to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, or as otherwise necessary to service your account. Furthermore, we may contact you to offer coupons, discounts, and promotions, and inform you about Interswitch Services or its group services.
Finally, we may contact you as necessary to enforce our policies, applicable law, or any agreement we may have with you. When contacting you via phone, to reach you as efficiently as possible we may use, and you consent to receive, auto dialed or prerecorded calls and text messages. Where applicable and permitted by law, you may decline to receive certain communications.
7 PROTECTION AND STORAGE OF PERSONAL INFORMATION
We store and process your personal information on our computers in Lagos, Nigeria, and anywhere else where our facilities are located. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration.
Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. We have also taken additional measures by ensuring our system complies with industry information security standards.
8 MARKETING
We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may combine customer's information with information collected from other companies and use it to improve and personalize Interswitch Services, content, and advertising. We have also included an opportunity for customers that had initially subscribed to receiving notification or information about their activities in relation to the use of Interswitch's service to unsubscribed or request to be removed from applicable databases.
9 SHARING PERSONAL INFORMATION WITH OTHER INTERSWITCH USERS
When transacting with others, we may provide those parties with information to complete the transaction, such as your name, account ID, contact details, shipping and billing address, or other information needed to promote the reliability and security of the transaction. If a transaction is held, fails, or is later invalidated, we may also provide details of the unsuccessful transaction.
To facilitate dispute resolution, we may provide a buyer with the seller's address so that goods can be returned to the seller. The receiving party is not allowed to use this information for unrelated purposes, such as to directly market to you, unless you have agreed to it. Contacting users with unwanted or threatening messages is not authorized by Interswitch.
We may provide or display customer information to a third-party while consummating transactions to validate that transactions are being exchanged with valid receivers.
We work with third parties, including merchants, to enable them to accept or send payments from or to Customers using Interswitch Services. In doing so, a third party may share information about customers with us, such as email address or mobile phone number, to inform such customer that a payment has been sent. We use this information to confirm that users are Interswitch customer and that Interswitch as a form of payment can be enabled, or to send customer notification of payment status. Also, we may oblige a request to validate that a customer transacts business with Interswitch.
Customer's card information may be available for their reuse subsequent if they chose to be remembered at previous attempts. Do note that merchants, sellers, and users involved in transactions may have their own privacy policies, and Interswitch does not allow the other transacting party to use this information for anything other than providing Interswitch Services, Interswitch is not responsible for their actions, including their information protection practices.
Interswitch will not disclose your credit/debit card number or bank account number to anyone or with the third parties that offer or use Interswitch Services, except with customers' express permission or if we are required to do so to comply with credit/debit card rules, a subpoena, or other legal processes.
10 SHARING PERSONAL INFORMATION WITH THIRD PARTIES
We may share customers' personal information with:
Members of the Interswitch group to provide joint content, products, and services (such as registration, transactions, and customer support), to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about their products, services, and communications. This information will only be used for marketing communications only if customers have requested for the services.
Financial institutions that we partner with to jointly create and offer a product may only use this information to market Interswitch related products unless the customer has given consent for other uses.
Credit bureaus and collection agencies to report account information, as permitted by law. Banking partners as required by credit/debit card association rules for inclusion on their list of terminated merchants.
Companies that we plan to merge with or are acquired by. (Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to customer personal information. Customers will receive prior notice if personal information would be used contrary to this policy).
Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Interswitch or one of its affiliates; when we need to do so to comply with law or credit/debit card rules; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement.
Other unaffiliated third parties, for the following purposes:
Other third parties with your consent or direction to do so.
11 CROSS BORDER TRANSFERS OF PERSONAL INFORMATION
Interswitch is committed to adequately protecting customers' personal information regardless of where the data resides and to providing appropriate protection for where such data is transferred across borders, including outside of Nigeria. We have further taken measure to ensure our relationships are with countries that are governed by similar data protection regulation as we are, and further assessment of other entities are being taken to provide a reasonable assurance of the safety of customer's information.
12 CUSTOMER DATA PROTECTION RIGHTS
The right to access - Customer has the right to request copies of their personal data. Interswitch may charge a fee for this service if it will require a substantial amount of resources to accomplish.
The right to rectification - Customers have the right to request that Interswitch correct any information they believe and have proven have been captured inaccurately. Customers also have the right to request Interswitch to complete the information they believe is incomplete.
The right to erasure - Customers have the right to request that Interswitch erase their personal data, under certain conditions. These conditions are not limited to regulatory requirements, law enforcement agencies, or where such action may cause disruption to our system.
The right to restrict processing - Customers have the right to request that Interswitch restrict the processing of their personal data, under certain conditions. (as above)
The right to object to processing - Customers have the right to object to Our Company's processing of your personal data, under certain conditions. (as above)
The right to data portability - Customers have the right to request that Interswitch transfer the data that we have collected to another organization, or directly to them, under certain conditions. (as above)
Customer requests based on any of the rights above shall be handled between 2 to 4 working weeks. Customer may contact us by email or writing:
Email us at [email protected]
13 THE USE OF COOKIES AND SIMILAR TECHNOLOGIES
When Customers access our websites or use Interswitch Services, we may place small data files on your computer or other devices. These data files may be cookies, pixel tags, “Flash cookies,” or other local storage provided by your browser or associated applications (collectively referred to as “Cookies”). These technologies are used to recognize users as customers; customize Interswitch Services, content, and advertising; measure promotional effectiveness; help ensure that account security is not compromised; mitigate risk and prevent fraud, and to promote trust and safety across Interswitch Services and related sites.
Users can freely decline our Cookies if the web browser or browser add-on permits unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with users' use of our websites and Interswitch Services.
14 PRIVACY POLICIES OF OTHER WEBSITES
This privacy policy applies to only Interswitch Group and not any other brands, though the mentioned on our Websites. Neither does it apply to our Merchants, Vendors, or other related partners.
15 CUSTOMER CONSENT
Please refer to the end of this notice for providing your consent. Your consent to personal data collection and processing may be revoked by notifying us via our contact page. For users below the age of 16, the consent should be provided by the holder of parental responsibility of the child.
Please note, in case you choose to not provide us with the consent or withdraw the consent at any given point of time, we shall not be able to provide the services as detailed in section 2.2 of this notice.
16 AVAILABLE REMEDIES
In the event of a violation of this Policy by the Company, we shall immediately upon becoming aware of such violation, assess the extent of the violation and take specific actions such as correction, modification, or transfer of the data, subject to the lawful demands of the data subject. The specific actions of correction, modification, and transfer shall be effected within 30 days, subject to external factors not within the reasonable control of the Company.
17 CHANGES TO OUR PRIVACY POLICY
We review our privacy policy periodically and when there is any substantial change to business or regulatory requirements. At the minimum, we shall review this annually and communicate via our communication channels such as Newsletter, on Website, Social Media Accounts.
18 HOW TO CONTACT US
Customers who have concerns, questions about the privacy policy or would like to exercise t heir protection rights can contact us through the following channels:
Email us at [email protected]
Call us: 016283888
Customer Contact Centre 0700-9065000
Or write to us at Interswitch Limited, 1648C Oko-Awo Street, Victoria Island Lagos.
19 DECLARATION
I have read all the terms and conditions within this Notice and hereby agree/ disagree to use of my personal data for the above-mentioned purposes.
© 2020 Interswitch Group. All Rights Reserved.
Protected by The Nigeria Data Protection Regulation 2019
Interswitch is regulated by the Central Bank of Nigeria