VIVEST PRIVACY POLICY
Your money is personal. So is the information that helps us protect it.
This Privacy Policy explains how VIVEST LTD (“Vivest”, “we”, “us” or “our”) collects, uses, stores, shares and protects personal information when you use Vivest, our website, applications, products and related services.
By using Vivest, you acknowledge that you have read and understood this Policy, subject to any consent or other lawful basis required by applicable law.
WHO WE ARE VIVEST LTD (RC 7165154) operates a digital financial platform designed to help users save, manage and grow money and, as our products develop, access additional financial opportunities such as global investments and related services. For privacy purposes, Vivest may act as a data controller where we determine the purposes and means of processing, and may use carefully selected third-party processors where necessary to operate our services.
INFORMATION WE COLLECT Depending on the services you use, we may collect identity information; contact information; financial and transaction information; KYC and compliance information; account and security information; device and technical information; communications and support records; marketing preferences; and information lawfully received from payment, identity, fraud-prevention, analytics and other service providers.
HOW WE USE YOUR INFORMATION To create and secure accounts; provide savings, payment, investment and educational services; process transactions; perform KYC/AML and sanctions checks; prevent fraud and financial crime; secure systems; provide customer support; improve products; personalise experiences where lawful; send essential service communications; send permitted marketing; enforce our agreements; comply with legal and regulatory duties; and support legitimate corporate transactions.
LAWFUL BASES FOR PROCESSING Where applicable, Vivest relies on lawful bases recognised under the Nigeria Data Protection Act, 2023 and other applicable privacy laws, including consent, contract, legal obligation, protection of vital interests, public interest and legitimate interests, depending on the purpose and circumstances. Where processing is based on consent, you may withdraw consent where permitted. Withdrawal does not make earlier lawful processing unlawful, and some services may require continued processing under another lawful basis.
KYC, AML, FRAUD & FINANCIAL CRIME CONTROLS Vivest may conduct identity verification, sanctions screening, fraud monitoring, transaction monitoring, source-of-funds checks and other compliance procedures, including through specialist providers and automated tools. We may restrict, suspend, delay or refuse transactions, access or accounts where reasonably necessary to protect users, comply with law, investigate suspected fraud or financial crime, or protect Vivest and its providers. Where law permits, we may withhold investigation-sensitive information.
WHEN WE SHARE INFORMATION We do not sell personal information as a business model. We may disclose information where reasonably necessary to operate Vivest, protect users, comply with law or perform a transaction. Recipients may include banks and payment processors; custodians and financial partners; KYC, AML, sanctions and fraud providers; cloud, cybersecurity, analytics and support providers; auditors and professional advisers; regulators and law enforcement where legally permitted or required; and parties involved in a merger, financing, acquisition or similar corporate transaction.
INTERNATIONAL DATA TRANSFERS Vivest or its service providers may process or store information outside Nigeria. Where information is transferred across borders, we will seek to apply safeguards required by applicable law, including appropriate contractual or other lawful transfer mechanisms.
COOKIES & ANALYTICS Our website and applications may use cookies, SDKs, pixels, logs and similar technologies to maintain security, remember preferences, understand usage, measure performance and improve our services. Third-party technologies may have their own privacy practices. Where required, we will request consent or provide appropriate controls.
DATA RETENTION We retain information for as long as reasonably necessary to provide services, maintain records, prevent fraud, resolve disputes, enforce agreements and meet legal, regulatory, tax, accounting and compliance obligations. When information is no longer required, we may securely delete, anonymise or otherwise dispose of it, subject to lawful retention requirements.
SECURITY We use reasonable technical, organisational and administrative safeguards designed to protect information against unauthorised access, loss, misuse, alteration or disclosure. No internet-connected system can be guaranteed completely secure. You are responsible for protecting passwords, authentication codes, devices, recovery information and other credentials. Vivest will not ask you to disclose your password or one-time authentication code through an unsolicited message.
YOUR DATA PROTECTION RIGHTS Subject to applicable law, you may have rights to access, correct, erase, restrict or object to certain processing, withdraw consent, obtain portability where applicable, and exercise rights relating to certain automated decisions. You may also have the right to complain to the Nigeria Data Protection Commission or another competent authority. Requests may require reasonable identity verification. We may decline or limit a request where permitted or required by law, including where disclosure would affect another person's rights, compromise security or interfere with legal or regulatory obligations.
CHILDREN & MINORS Vivest is not intended for persons who are not legally permitted to use our financial services. We may apply age and eligibility checks. Where a product is lawfully offered to a minor, additional safeguards required by applicable law will apply.
YOUR RESPONSIBILITIES You must provide accurate, current and non-misleading information and cooperate with reasonable identity and compliance checks. You must not use Vivest for fraud, money laundering, sanctions evasion, impersonation, unlawful activity, system interference or abuse of other users. You are responsible for protecting your account credentials, except to the extent a loss results from Vivest's own failure or as otherwise required by law.
AUTOMATED DECISION-MAKING & RISK SYSTEMS Vivest and its providers may use automated systems for identity verification, fraud detection, transaction monitoring, security, risk assessment, personalisation and compliance. These systems may generate alerts or cause a transaction, account or feature to be reviewed, delayed or restricted. Where applicable law provides rights concerning solely automated decisions with significant effects, we will provide the applicable process for review, explanation or objection.
AUTOMATED DECISION-MAKING & RISK SYSTEMS Vivest and its providers may use automated systems for identity verification, fraud detection, transaction monitoring, security, risk assessment, personalisation and compliance. These systems may generate alerts or cause a transaction, account or feature to be reviewed, delayed or restricted. Where applicable law provides rights concerning solely automated decisions with significant effects, we will provide the applicable process for review, explanation or objection.
THIRD-PARTY SERVICES & LINKS Vivest may integrate or link to third-party services. Those providers may have their own privacy notices and terms. We encourage you to review them before using third-party services.
MARKETING & COMMUNICATIONS We may send essential service, security and transaction communications. Where permitted, we may also send product updates, educational material and marketing. You may opt out of non-essential marketing using available controls; essential service messages may continue.
DATA INCIDENTS & BREACH RESPONSE Vivest maintains processes intended to identify, assess, contain, investigate and remediate personal-data incidents. Where an incident triggers a legal notification obligation, Vivest will make required notifications within applicable timelines and may take protective measures such as credential resets, account restrictions or additional verification.
CHANGES TO THIS POLICY We may update this Policy to reflect changes in services, technology, legal requirements, regulatory expectations or business practices. We will publish an updated version and effective date and, where required, provide additional notice or obtain consent.
PRIVACY REQUESTS & COMPLAINTS For privacy questions, requests or complaints, contact Vivest through the official support or privacy contact details published in the Vivest application or on www.vivest.app. Do not send passwords, authentication codes, private keys or other highly sensitive credentials through ordinary email or support channels. You may also have the right to lodge a complaint with the Nigeria Data Protection Commission.
GOVERNING LAW This Policy is intended to operate in accordance with the laws of the Federal Republic of Nigeria, including the Nigeria Data Protection Act, 2023, and other applicable privacy, financial, consumer-protection, cybersecurity and regulatory requirements. Additional local requirements may apply where Vivest provides services in another jurisdiction.
IMPORTANT NOTICE This Policy explains Vivest's privacy practices and is intended to establish clear rules for handling personal information. It does not remove rights that cannot lawfully be excluded, and nothing here is intended to limit Vivest's obligations under applicable law. Vivest may maintain separate Terms of Service, Financial Services Terms, Cookie Notice, AML/KYC Policy, Information Security Policy and other product-specific policies. Where applicable, those documents should be read together with this Policy.
VIVEST LTD RC 7165154 Website: www.vivest.app
