We provide products or services to you or our client;
You visit or use our website; and/or
Performing any other activities that form part of our business.
Who we are
You can read more about us: www.menopays.com
Security and Confidentiality
We understand the value of your Personal Data and therefore will take all
reasonable steps to protect your Personal Data from loss, misuse or unauthorised
alteration. Your Personal Data is stored in databases that have built-in safeguards
and firewalls to ensure the privacy and confidentiality of that information. Where you
have chosen a password that allows you to access certain parts of the website and
mobile application, you are responsible for keeping this password confidential. We
advise you not to share your password with anyone.
Our security systems meet or exceed industry standards and we are constantly monitoring internet developments to ensure our systems evolve as required. We also test our systems regularly to make sure our security mechanisms are up to date.
Personal Data is information that identifies or relates specifically to you including your financial information, for example, your name, age and identity number, your assets and liabilities, your income and your payment records. Essentially, any information that we know about you will be regarded as your Personal Data.
Personal Data we Collect
In the course of providing products or services to you or our client and performing
due diligence checks in connection with our products or services (or discussing the
possible products or services we might provide), we generally collect your Personal
Data. We also typically collect your Personal Data when you visit or use our
The Personal Data we may collect depends on the specific services, activities or products we undertake but typically includes: your name; age; date of birth; gender; home address; email address; telephone number; other contact details; country of residence; passport number and other national ID numbers; employment details (for example, the organization you work for, your job title); family circumstances (for example, your marital status where you enter it in a form on our Website or it appears in any documentation you provide to us); financial information (for example, your income, where you enter such information in a form on our Website or it appears in any documentation that you provide to us); details of how you use any product or service provided by Menopays; postings on any blogs, forums, wikis, and any other social media applications and services that we provide; IP address; browser and device type; username that is used by you for one of our products or services; language; access times and duration; details of how you like to use our Website or the interactive products, tools, other technology or services we provide to you or our clients; websites that you visited before and after visiting our Website; details of how you like to interact with us, and similar information.
The types of personal information and ‘sensitive’ or ‘special categories’ of Personal Data we collect will generally vary depending on the nature of the products and services that we provide to you and how you use our Website. In some cases, the ‘sensitive’ or ‘special categories’ of personal information that we collect may include information that is collected as part of KYC and anti-money laundering checks that we must conduct before accepting you as a customer.
In some rare circumstances, we will also gather other ‘special categories’ of Personal Data about you because you volunteer that data to us (for example, it appears in a copy of your resume/CV that you upload to our Website). In some other circumstances, the Personal Data we collect from you is needed to meet our legal or regulatory obligations or to provide you with the products or services requested by you. In some cases, we may also collect your Personal Data indirectly from third parties such as: (i) your employer; (ii) third parties such as providers of ‘know your client’ and anti-money laundering services which we sometimes use to help us meet our legal requirements in this area and to help us verify your identity where we provide you with products or services; (iii) background check providers which we sometimes use to verify your identity when you apply for a product of ours; and (iv) third-party service providers that help us to operate our Website.
How we use Information about you
a. Use of Personal Data to provide Products and Services
We will use your Personal Data to provide you with products or services. As
part of this, we may use your Personal Data in the course of correspondence
relating to those products or services. Such correspondence may be with you,
our customers, our service providers or public or judicial authorities with the
In many cases, we also use your Personal Data to conduct due diligence checks in advance of providing products or services to you and to process an application from you or a prospective client to receive products or services from us. If you are referred to us by an intermediary or similar third party, we also typically use your Personal Data to assess whether to accept or reject your referral to Menopays by that intermediary or similar third party.
b. Use of Personal Data Collected through Our Website In order to make your use of this loan product and electronic service offered by Menopays as successful as possible, it is necessary for us to find out exactly what you need and want from us and to ascertain whether you are eligible to get a loan. The following are some of the reasons why we would collect your Personal Data:
- To identify you;
- Notify you about changes to our services;
- Improve our product to ensure that content is presented in the most effective manner for you and for your device;
- Measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- In order for us to process your instructions or requests;
- In order for us to ensure that you meet our lending criteria, we may collect and analyse your Personal Data and combine all the information that we have about you to compile a credit profile of you in order for us to grant you a loan and to meet your specific needs.
Once we have collected and analysed your Personal Data, we may send you promotional material or details which we think may be of interest to you but will only do so with your permission. If any of this promotional information relates to products, promotions, news or services of a third party, and if you indicate that you would like more details, we may inform the third party to contact you directly. We will, however, only inform a third party to contact you directly if you have indicated that this is agreeable to you.
c. Use of Personal Data for Other Activities that Form Part of the Operation
of Our Business
We generally use your Personal Data collected through this Website for the purposes of, or in connection with:
- applicable legal or regulatory requirements;
- requests and communications from public or judicial authorities with the necessary authorisation;
- financial accounting, invoicing and risk analysis purposes;
- prudent operational management (including credit and risk management, audit, training and similar administrative purposes);
- client relationship purposes, which involve: (i) contacting you to receive feedback on Menopays products or services; and (iii) contacting you for other marketing or research purposes;
- recruitment and business development purposes;
- services we receive from our professional advisors, such as lawyers, accountants and consultants;
- arrangements we have in place with intermediaries, brokers and other individuals and entities that partner with us;
- protecting our rights and those of our customers; and
- meeting our corporate and social responsibilities.
Legal Basis for Processing of Personal Data
We will only process your Personal Data where we have a legal basis to do so. The
legal basis will depend on the purpose for which we have collected and use your
The legal basis for processing is any of the following:
(a) Consent: This will apply where you have provided your consent to the processing of your personal data for one or more specific purposes.
(b) Performance of a contract with you: This will apply where processing is necessary for the performance of a contract to which you are a party or in order to take steps prior to entering into a contract with you.
(c) Protection of vital interests: This is where processing is required for the protection of your vital interests.
(d) Compliance with law: Where we are subject to a legal obligation and need to use your Personal Data in order to comply with that obligation.
(e) Public interest: Where processing is necessary for the performance of a task or function carried out in the interest of the public.
(f) Legitimate Interest: means the interest of our business in conducting and managing our business to enable us to give you the best services and most secure experience.
Whom we Disclose Your Personal Data
We generally disclose your Personal Data to professional advisors and third parties that provide services to us (such as lenders, banks, IT systems providers, platform providers, financial advisors, consultants including lawyers and accountants) and other goods and services providers (such as providers of marketing services where we are permitted to disclose your personal information to them); competent authorities (including any national and/or international regulatory or enforcement body or court or other forms of tribunal, where we are required to do so by applicable law or regulation at their request); a potential buyer, transferee, merger partner or seller and their advisers in connection with any actual or potential transfer or merger of part or all of Menopays business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it; credit reference agencies or other organizations that help us detect criminal activity and incidence of fraud; and any federal, state or local government departments and other statutory or public bodies.
How we Protect your Personal Data
We use a range of physical, electronic and managerial measures to ensure that we keep your Personal Data secure, accurate and up to date. These measures include:
- education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal information as well as training around social engineering, phishing, spear phishing, and password risks;
- administrative and technical controls to restrict access to personal information on a ‘need to know’ basis;
- technological security measures, including firewalls, encryption and anti-virus software;
- physical security measures, such as staff security passes to access our premises;
- external technical assessments, security audits and vendor due diligence;
- endpoint security: Anti-virus, portable storage device lockdown, restricted administrative privileges;
- real-time monitoring of data leakage controls;
- layered and comprehensive cybersecurity defences; and
- security incident reporting and management.
Although we use appropriate security measures once we have received your Personal Data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavour to protect personal information, but we cannot guarantee the security of data transmitted to us or by us.
Your Rights in Relation to Your Personal Data
You have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances. These rights are to:
- request rectification of your Personal Data;
- request the erasure of your Personal Data;
- request the restriction of processing of your Personal Data;
- lodge a complaint about the handling of your Personal Data with the National Information Technology Development Agency (“NITDA”);
- ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your Personal Data for such purposes or if we intend to disclose your Personal Data to any third party for such purposes;
- be informed about the existence of automated decision-making processes, including profiling as well as meaningful information about the logic involved, the significance and the envisaged consequences of such processing;
- a copy of the Personal Data we hold about you, as well as the information about what we do with it, who we share it with and how long we hold it for;
- freely transfer your Personal Data received from us to any other person.
NITDA’s website (https://nitda.gov.ng/nit/) has a wealth of useful information in respect of your rights over your Personal Data. Where we do not act on your request to exercise any of your rights, we shall inform you within one month of the receipt of your request, of the reasons for not taking action and on the possibility of lodging a complaint with NITDA. We may however withhold Personal Data that you request to the extent permitted by law as well as where it is deemed unlawful as directed by a court order.
Retaining of Your Personal Data
We will retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such Personal Data in our records. This will normally include any period during which we are dealing or expect to deal with you and what we consider to be a suitable period thereafter, for our internal record-keeping purposes.
What are Cookies?
Cookies are small text files. They are commonly downloaded to your computer or mobile device by websites that you visit. They enable the website to tag your device and recognize it as you move around the site (and potentially when you return at a later date) so that, for example, you do not have to re-enter your password each time you move between pages of the website.
Can I turn off Cookies?
If you do not wish to receive cookies, you can set your web browser to disable cookies. As explained above, cookies help you to get the most out of our Website. If you decide to disable cookies, you may find that certain aspects of our Website do not work as expected.