1. Introduction

Hello! This Privacy Policy (the “Policy”) has been created to describe your privacy rights regarding how we collect, use, process, disclose and protect your information, including any non-public, personal information (Personal Data). This Policy applies to the Personal Data collected by Ardilla when you use our website, mobile application, social media platforms, tools, and any other platform belonging to Ardilla (collectively, the "Services") or otherwise interact with us as described below. This Policy may be updated occasionally and at our sole discretion.

Where updates are made to the Policy, we will notify you of the 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 and ways to protect your privacy. By accessing or choosing to use any of our platforms, you agree to be bound by this Policy.

2. Consent

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, and social media, amongst other platforms which may be contemplated to be used by Ardilla.

3. Collection of Personal Data

You may be asked to provide your Data anytime you contact us or interact/access any of Ardilla’s platforms. We shall use your Data per this Policy, relevant laws, regulations, and implementation framework.

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 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 Ardilla and others, and provide news and information we think will interest 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. Ardilla is based in Nigeria, and the Personal Data we collect is governed by the Nigeria Data Protection Regulation (NDPR) 2019 and the Implementation Framework 2020. By accessing or using the Services or otherwise providing your Data to us, you consent to the processing and transfer of your Personal Data in and outside Nigeria.

Ardilla is based in Nigeria, and the Personal Data we collect is governed by the Nigeria Data Protection Regulation (NDPR) 2019 and the Implementation Framework 2020. By accessing or using the Services or otherwise providing your Data to us, 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 Data if we have a proper reason. We consider the lawful basis for using your Personal Data as set out in the Nigeria Data Protection Regulation (NDPR). This include:

1. To comply with our legal and regulatory obligations.

2. To perform a contract with you or take steps at your request before entering a contract.

3. To use your Personal Data as is necessary for our legitimate interests or the legitimate interests of others.

4. To protect your interest, the interest of another Data Subject, or for the performance of a task carried out in the public interest or the exercise of official public mandate vested in us.

6. Disclosure Of Personal Data

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

1. Financial service providers, including the financial institutions identified in your cardholder bank agreement, provide banking services in connection with your Ardilla account.

2. With another user, when you sign up for Ardilla's services via a referral link. The user that referred you may receive information indicating that you have enrolled with Ardilla. You may avoid this sharing by not using a referral link to enroll.

3.With non-financial companies, such as email service providers that perform marketing services on our behalf and fraud prevention service providers that use the information to provide services to Ardilla and other companies.

4.With a non-affiliated third party to access and transmit your personal and financial information from a relevant financial institution. You grant the third party the right, power, and authority to access and transmit this information according to the terms of their privacy policy. With other non-affiliated companies for our everyday business purposes, such as processing transactions, maintaining accounts, responding to court orders and legal investigations or reporting to credit bureaus. For example, in connection with our everyday business purposes, we may share Personal Data about you as follows:

In response to a request for Personal Data, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation, or legal process.

2. With relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud.

3. If we believe your actions are inconsistent with the spirit or language of our user agreements or policies or to protect the rights, property, and safety of (insert name of Company) or other

4. In connection with, or during negotiations of, any merger, sale of (insert name of Company)'s assets, financing or acquisition of all or a portion of our business to another company; and

5. With your consent or at your direction, including if we notify you that the Personal Data you provide will be shared in a particular manner and you provide such Personal Data.

We may also share aggregated or de-identified Personal Data, which cannot be used to identify you. For example, we may share transaction zip codes with third parties to improve our accuracy in geo-locating transactions and clarify transaction descriptions. We will usually not share your 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 to which the data is being transferred or the foreign institution receiving said Personal Data should have sufficient data protection laws. We will seek your consent when sending your data to a country without an adequate data protection law.

7. Your Choices

7.1 Account Information

You may edit your Data by logging into your account via our Services. If you wish to delete or deactivate your online account, please contact us, but note that we may retain certain Personal Data as required by law or for legitimate business purposes.

7.2 Promotional Communications

You may opt-out of receiving promotional emails and text messages from Ardilla by following the instructions in those messages. Please note that if you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.

7.3 Location Information

If you initially consent to the collection of location information by Ardilla or Google Maps within our mobile application, you may be able to subsequently stop this collection through your device operating system settings or your online account settings. If either of these opt-out options is not available to you, you may also disable location information by following the standard uninstall process to remove our mobile application from your device.

7.4 Cookies

Most web browsers are set to accept cookies by default. You can set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

7.5 Social Sharing Features

Our Services include social sharing features for common social networks to let users share content. These features are served by third-party services that may serve their cookies. Using such features enables sharing information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

7.6 Analytics and Advertising Services Provided by Others

We may allow others to provide analytics services on our behalf and serve advertisements across the Internet. These entities may use cookies, web beacons, and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. This Personal Data may be used by (insert name of Company) and others, to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising targeted to your interests, and better understand your online activity.

9. Where We Store Your Personal Data

The Personal Data we collect from you will be transferred to and stored at a destination outside Nigeria. You agree to transfer, storing, or processing by submitting your Personal Data. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy. All Personal Data you provide to us is stored on our secure cloud storage solution.

10. How Long do We Keep Your Personal Information

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

11. 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 knowing about the such breach, report the details of the breach to NITDA.

Furthermore, where we ascertain that such breach is detrimental to your rights and freedom in relation to your Personal Data, we shall, within 14 (Fourteen) working days of knowing the occurrence of such breach, take steps to inform you of the breach incident, the risk to your rights and freedom and any course of action to remedy said breach.