Our Policy

April 12, 2021



Who we are.

Glover Limited and all of its subsidiaries (referred to as “Glover” or “we” or “our” or “us”) respects your privacy and is committed to protecting your personal data. This privacy policy sets out the terms upon which personal data we collect from you, or that you provide to us, will be processed by us. It also informs you as to how we look after your personal data and tells you about your privacy rights and how the law protects you.

Scope

This Privacy Policy applies to users, customers employees, third parties, visitors, clients and other connections (referred to as “you” or “Users”) who order, sign up or interact with us or any of our products, services, information, content, functions, features and tools (“our Services” or “the Service”) provided on our website, mobile application or API (altogether referred to as “Glover Platform”).

User reserves the right to exercise their privacy and data protection rights under any applicable law or regulation.

Consent

You accept and consent to the terms of this Privacy Policy when you order, sign up or interact with us or any of our Services regardless of how they are accessed or used.

Changes to this Privacy Policy

We may modify this Privacy Policy from time to time by publishing or uploading an updated version on our website. The updated version will become effective as of the published date.
Furthermore, if any revised version includes a substantial change in terms, Users shall be informed via email (sent to the email address specified in your account), by means of a notice on the Glover Platform.

Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact us below –

Customer Service Desk
Email address: hello@gloverapp.co

This Terms of Use (this “Agreement”) is an agreement between you and Glover Technologies Limited, including but not limited to legal persons, unincorporated organizations that provide Glover Services.

This Terms of Use governs your use of all Glover Services. You unconditionally accept and agree to be bound by the terms and conditions set out in this Terms of Use including the Privacy Policy as well any applicable laws and guidelines when you access the Glover Platform or use any of the Glover Services. If you disagree with any part hereof, kindly desist from using the Glover Platform or any of the Glover Services. You should read all of these terms carefully.

Our Services

Glover is an electronic payment services provider and acts as such by creating, hosting, maintaining and providing Glover Services our website, mobile application or API (altogether referred to as “Glover Platform”).

Our services enable you and other users congregated on the Glover Platform to –
a) Buy and sell your local and international gift cards;

b) Pay utility bills and purchase airtime top-up; and

c) Convert airtime top-up into cash; (altogether referred to as “Glover Services”)

Eligibility

To be eligible to use or access the Glover Platform and the Glover, the following conditions must be met by you –

a) must create a Glover user account on the Glover Platform;

b) as an individual, be at least 18 or be of legal age to form a binding contract under applicable laws;

c) as an individual, legal person, or other organization, you have full power, authority and capacity to accept these Terms of Use;

d) as an employee or agent of a legal entity, you must have the full power, authority and capacity to accept these Terms of Use on their behalf and bind such legal entity to these Terms of Use;

e) you have not been previously restricted from using or accessing the Glover Platform and Glover Services

f) your use of Glover Services will not violate any applicable laws and regulations applicable to you, including but not limited to regulations on anti-money laundering, anti-corruption, and counter-terrorist financing

Use of Information

You hereby acknowledge that in order to use or access the Glover Platform or Glover Services, you must provide us with correct and updated Personal Information.

Personal Information may include –identity data, identity documents, transaction data, and technical data. Your Personal Information shall be properly protected and kept confidential at all times.

We may use, process, store and transfer your Personal Information in order to –

a) provide Glover Services to you;

b) comply with applicable laws and regulatory requirements;

c) secure your Glover user account and maintain data and information security;

d) verify the identity details and bank account details which you provide to us;

e) protect our vital interests and that of others;

f) provide service communications;

g) provide customer service;

h) facilitate corporate reorganisations; and

i) implement direct marketing campaigns.

Security and unauthorised use

Glover remains committed to providing adequate data and information security to ensure that the detection and prevention of fraudulent and unauthorised access to Glover user accounts, however, it is of utmost importance that Glover Users treat the credentials used to access Glover Platform as confidential information and avoid the disclosure of same to anybody.

You hereby agree that you are responsible for maintaining adequate confidentiality and control of any and all credentials that you use to access the Glover Services or Glover Platform.

You acknowledge that Glover shall not in any way be liable for any loss, damage or costs caused by authorized or unauthorized use of your Glover user account credentials.

We will never request for your credentials via email, SMS or any other means. If you receive such communication, please disregard and contact us below –

Glover Fraud Desk
Email address: frauddesk@gloverapp.co

You should immediately notify Glover if you believe there has been an unauthorized transaction or unauthorized access to your Glover user account or your password or PIN has been compromised.

Transaction Cancellation, Modification or Refund.

While making a bill payment transaction to a third-party merchant using Glover Services, if you input an incorrect amount or reference number you cannot rectify or reverse the completed transaction on the Glover Platform.

Glover shall not be obliged to make a refund or amend the erroneous transaction. You must directly contact the third-party merchant for any refund, rectification or reversal of such erroneous transaction.

Confirmation of Gift card values

The details of every gift card including – card currency, card type, receipt type (where receipts are required), and card value shall be verified and confirmed when you upload the gift card on the Glover Platform.

You hereby acknowledge that estimated pay-out amount of a gift card is subject to confirmation and may vary if there is any variance in the card details you provided upon verification and confirmation.

Prohibited Activities

During the use of the Glover Platform or Glover Services and in the course of your interactions with Glover, affiliated third parties or other Glover users, you will not –

a) Breach this Terms of Use, any policy and/or any agreement that you have agreed to with Glover;

b) Breach any applicable laws and regulations;

c) Engage in or facilitate fraudulent activities including but not limited to taking any actions that defraud Glover or a Glover user;

d) Infringe on Glover or any third party's copyright, patent, trademark, trade secret or other intellectual property rights, or rights of publicity or privacy;

e) Sell counterfeit goods and/or product or service that is prohibited by law or is contrary to public order or good moral;

f) Act in a manner that is defamatory, trade libellous, threatening or harassing to Glover, our employees, agents or other Glover users;

g) Provide false, inaccurate or misleading Personal Information;

h) Engage in potentially fraudulent or suspicious activity and/or transactions;

i) Receive or attempt to receive chargeback from both Glover and the Merchant,
bank or card issuer for the same transaction during the course of a dispute;

j) Take any action that imposes an unreasonable or disproportionately large load on our infrastructure; and

k) Facilitate any viruses, trojan horses, worms or other computer programming routines that may damage, detrimentally interfere with, surreptitiously intercept or expropriate any system, data or Personal Information;

Termination and Restriction of Access

You hereby acknowledge that Glover reserves the right to restrict access to your Glover account and/or the termination of this Agreement upon the reasonable suspicion that you have contravened any of the terms and conditions contained in this Terms of Use

Glover, in its sole discretion, reserves the right to terminate this Agreement and/or restrict access to the Glover Services and Glover Platform for any reason and at any time upon notice and payment to you of any unrestricted funds held in your wallet. If we limit access to your Glover user account, including through the placement of a lien, we will provide you with notice of our actions, and the opportunity to request restoration of access if, in our sole discretion, we deem it appropriate. Further, you acknowledge that Glover’s decision to take certain actions, including limiting access to your Glover user account, may be based on confidential criteria that is essential to our management of risk, the security of other Glover users’ accounts and the Glover Platform. You agree that Glover is under no obligation to disclose the details of its risk management or its security procedures to you.

Disclaimers and Limitation of Liability

Disclaimer

THE GLOVER SERVICES AND PLATFORM ARE PROVIDED “AS IS” AND WITHOUT ANY REPRESENTATION OF WARRANTY, WHETHER EXPRESS, IMPLIED OR STATUTORY. GLOVER, OUR PARENT AND AFFILIATES, OUR OFFICERS, DIRECTORS, AGENTS, JOINT VENTURES, EMPLOYEES AND OUR SUPPLIERS SPECIFICALLY DISCLAIM ANY IMPLIED WARRANTIES OF TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT.

Glover does not guarantee continuous, uninterrupted or secure access to any part of the Glover Services, and operation of the Glover Platform may be temporarily suspended for maintenance or upgrade or interfered with by numerous factors outside of our control. Glover will make reasonable efforts to ensure that service requests are processed in a timely manner, but Glover makes no representations or warranties regarding the amount of time needed to complete processing because the Glover Services are dependent upon many factors outside of our control, such as delays in the banking system or delays by partners and vendors.

Glover does not have any control over the products or services provided by third-parties and paid for with the Glover Services. Hence, Glover cannot ensure that the third-party would actually complete the transaction or is authorized to do so.

Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, GLOVER AND ITS SUBSIDIARIES AND AFFILIATES, OFFICERS, DIRECTORS, AGENTS, EMPLOYEES OR SUPPLIERS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS OR REVENUES, WHETHER INCURRED DIRECTLY OR INDIRECTLY, OR ANY LOSS OF DATA, USE, GOODWILL, OR OTHER INTANGIBLE LOSSES, RESULTING FROM (i) YOUR ACCESS TO OR USE OF OR INABILITY TO ACCESS OR USE THE GLOVER SERVICES AND PLATFORM; (ii) ANY CONDUCT OR CONTENT OF ANY THIRD PARTY ON THE SERVICES, INCLUDING WITHOUT LIMITATION, ANY DEFAMATORY, OFFENSIVE OR ILLEGAL CONDUCT OF OTHER USERS OR THIRD PARTIES; (iii) ANY CONTENT OBTAINED FROM THE SERVICES; OR (iv) UNAUTHORIZED ACCESS, USE OR ALTERATION OF YOUR TRANSMISSIONS OR CONTENT.

To the maximum extent permitted by law, in no event will any liability of Glover and its subsidiaries and affiliates, officers, directors, agents, employees or suppliers to any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with any use of, or inability to use of the Glover Platform, any content displayed on Glover Platform and any linked third-party websites exceed (in aggregate) the fees earned by Glover in connection with your use of the Glover Platform in the 6 (six) month period immediately preceding the event giving rise to the claim for liability.

Changes

Glover reserves the rights to make changes to this Terms of Use without notice. You are required to visit this page regularly as your continued use of the Glover Platform or Glover Services will be deemed as an unconditional acceptance and agreement to be bound by the revised Terms of Use.

Notwithstanding the foregoing, will do our best to notify you of any changes to the Terms of Use and any such notice will be published on the Glover Platform by posting same on our website, sending push notifications through on the mobile app or sending an email to the email address associated with your Glover user account.

Governing Law

This Agreement and the rights and obligations of the Parties hereunder shall be governed by and interpreted and construed in accordance with the laws of Nigeria.

The Data We Collect From You

Personal data or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may store and process all or part of your personal data in Nigeria and elsewhere in the world where our facilities or our service providers are located.

Further details are provided below.

Identity Data

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, signature, billing address, delivery address, email address, BVN etc.

We may collect, use, process, store and transfer your Identity Data in order to provide our Services, comply with applicable laws and regulatory requirements, detect and prevent fraud, protect our vital interests and that of others, provide Service communications, provide customer service, maintain data and information security, facilitate corporate reorganisations, implement direct marketing campaigns

Transaction Data

Transaction Data includes details about payments to and from you and other details of Services you have received from us.

We may collect, use, process, store and transfer your Transaction Data in order to provide our Services, comply with applicable laws and regulatory requirements, detect and prevent fraud, protect our vital interests and that of others, provide customer service, ensure quality control, maintain data and information security, research and development purposes, enhance customer experience and implement direct marketing campaigns.

Technical Data

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, browser fingerprint, authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.

We may collect, use, process, store and transfer your Technical Data in order to provide our Services, comply with applicable laws and regulatory requirements, detect and prevent fraud, research and development purposes, enhance customer experience and implement third party marketing campaigns.

Anonymised and Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for the purpose of analyzing web traffic and functionality of our website. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Transaction Data and Technical Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Disclosure Of Your Personal Data

We may share your personal data with certain third-party which we deem necessary in order to provide our Services effectively or comply with applicable laws and regulatory requirements.

Our engagement terms with these third parties shall require them to only use your information in connection with the services they perform for us and prohibit them from selling your information to anyone else. Such engagements shall also be subject to professional duty of confidentiality where applicable.

Further information are set out below –

a) Third party identity verification service providers – In order to detect and prevent fraudulent transactions and comply with applicable laws and regulatory requirements, we may share your personal data with third party identity verification service providers who shall verify your identity against available public records and other third-party databases.

b) Banks and other financial institution partners – In order to process payments and withdrawals and comply with applicable laws and regulatory requirements we may share your personal data with banks and financial institutions.

c) Service providers – We may share your personal data with service providers that we engage their services to execute different business functions. Examples of these service providers include – cloud storages, network infrastructure providers, marketing, data analytics etc.

d) Professional advisors – We may share your personal data with professional advisors in order to avail ourselves with technical, financial or legal consulting services or in compliance with our legal obligations.

e) Companies or other entities during corporate reorganisations – If a change in our corporate structure occurs as a result of the sale, transfer or merger of parts of our business or our assets or that of another entity by us, then the new corporate entity may use your personal data in the same way as set out in this privacy policy. You will receive prior notice of any change in applicable policies.

f) Law enforcement agents and officials – We may share your personal data where we are bound by law or any legal procedure to share same or when we believe in good faith that the disclosure of your personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our Terms of Services or any other applicable policies.

Use Of Cookies And Similar Technologies

When you access our websites or use our Services, we may place small data files on your
computer or other device. 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 –
a) recognise Users as customers;

b) customise the Service, content, and advertising; measure promotional effectiveness;

c) help ensure that account security is not compromised;

d) mitigate risk and prevent fraud; and

e) promote trust and safety across the Service 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 your use of our websites and the Service.

Third Party Websites

The Glover Platform may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Glover Platform, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information.

Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information.

We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Glover Platform.

Data Security

We have put in place appropriate security measures (and contractually require third parties we share your information with to maintain) appropriate physical, technical and administrative safeguards to prevent the personal data from being accidentally loss, misuse or in an unauthorised access, alteration or disclosure of your personal data. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

The security of your personal information it is instructive to note that no method of electronic transmission or storage of data guarantees 100% security. Thus, we strive to use commercially acceptable means to protect your personal information and we cannot guarantee its absolute security.

Based on the foregoing, we have established appropriate procedures 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.

Retention Of Personal Data

We will only retain your personal information for as long as reasonably necessary to –
a) provide our services to you,

b) archiving purposes to detect and investigate fraudulent transactions,

c) comply with our legal obligations under financial or anti-money laundering laws

d) satisfying any tax, accounting or reporting requirements; and

e) upon our reasonable belief that there is a prospect of litigation in respect to our relationship with you.

Your Rights

Under certain circumstances, you can exercise certain rights provided under applicable laws and regulations in relation to the personal information we hold. These rights include the right to –
a) give and withdraw consent;

b) request access to your personal information;

c) request the rectification of your personal information;

d) request erasure of your personal information;

e) object to the processing of your personal information;

f) request that we restrict the processing of your personal information;

g) request the transfer of your personal information to you or a third party; and

h) complain at any time with any relevant authority for data protection issues.

Limitation Of Liability

We will not be responsible for a breach of personal information which happens due to –
a) an event which is beyond our control;

b) an act or threats of terrorism;

c) an act of God (such as, but not limited to fires, explosions, earthquakes, drought, tidal waves and floods) which compromises our data protection measures;

d) war, hostilities (whether war be declared or not), invasion, the act of foreign enemies, mobilisation, requisition, or embargo;

e) rebellion, revolution, insurrection, or military or usurped power, or civil war which compromises our data protection measures;

f) the transfer of your personal information to a third party on your instructions; and

g) the use of your personal information by a third party designated by you.