Legal

Privacy Policy

Learn more about our privacy

Introduction

PEERLESS is committed to protecting your privacy and ensuring the security of personal data. We value and respect the privacy of the people we engage with and have developed this Privacy Policy to outline how we collect, hold, use and disclose your personal information, and the measures we take to maintain its quality and security.

This Privacy Policy applies to our website and all related platforms, services, and applications (collectively, the "Platform"). The reference to 'you' or 'your', mean any individual accessing the Platform, including website visitors, authorized users of our business customers, and any persons who engage with our products and services (altogether, our "Platform").

Definitions

"We," "Peerless," "Our," "us" refers to the relevant entity within our corporate group that provides The Platform or services to you, being either:

  • Peerless Software Global Services Limited (registered in Nigeria); or
  • Peerless Software Inc Ltd (registered in the United Arab Emirates (UAE)), as applicable based on your relationship with us.

"Personal Data" means any information relating to an identified or identifiable natural person (a "Data Subject"). This includes, but is not limited to, names, contact details, identification numbers (such as BVN or NIN), location data, and online identifiers (such as IP addresses and device identifiers).

"Sensitive Personal Data" means Personal Data revealing an individual's race, ethnic origin, religious or philosophical beliefs, genetic data, biometric data (for the purpose of uniquely identifying a natural person), health data, or data concerning an individual's sex life or criminal convictions. We only process Sensitive Personal Data where necessary for lawful purposes, including identity verification, fraud prevention, and security, and such processing is subject to enhanced safeguards in accordance with applicable law.

References to "you" or "your" mean any individual accessing the Platform, including website visitors, authorized users of our business customers, and any persons who engage with our products and services.

Governing Law and Jurisdiction

This Privacy Policy is governed by and shall be construed in accordance with the laws of the Federal Republic of Nigeria.

Regional Application

  • Nigeria: If you access our Platform or services from Nigeria, your personal data is processed in accordance with the Nigeria Data Protection Act 2023 (NDPA).
  • UAE: Where services are provided by our UAE-registered entity, we will also comply with applicable data protection laws in the UAE, to the extent such laws apply to the processing of your Personal Data.

Baseline Standards

While our Platform may be accessed globally, our baseline data protection standards are anchored to the NDPA. Any additional data protection requirements, specific jurisdictional obligations, or variations required by business customers operating outside the Federal Republic of Nigeria shall be governed exclusively by the terms of the relevant written agreement between Peerless and the business customer.

Acknowledgement

By accessing or using our Platform, you acknowledge that you acknowledge that you have read and understood this Privacy Policy and that your Personal Data will be processed under the standards set forth in this Privacy Policy.

Where you have entered into a separate written agreement with us, including any data processing or service agreement, the terms of that agreement shall govern to the extent of any inconsistency with this Privacy Policy. Any specific deviations from these standards required for international compliance must be explicitly agreed upon in a signed written agreement.

How we Collect Your Information

We collect your information when you:

  • Subscribe to, or purchase any products or offerings of Peerless;
  • Upload and integrate data into our Platform;
  • Create or administer your Peerless account;
  • Register for or attend a Peerless event whether onsite or virtual;
  • Configure your settings for, provide data access permissions for, or otherwise interact with Peerless' offerings;
  • Communicate with us by phone, email, letters or otherwise;
  • Complete a questionnaire, a support ticket, or other information request forms;
  • Engage on our websites, social media channels or participate in our community features.

To the extent that you upload, input, or integrate data into our Platform that contains Personal Data, you act as the Data Controller, and we act as the Data Processor. We process such data solely in accordance with your documented instructions (and where applicable, the terms of the relevant contract with you), this Privacy Policy, and as required to comply with applicable laws.

Our Role in Processing Your Personal Data

When We Act as a Data Controller

We act as a data controller where we determine the purposes and means of processing your Personal Data. This includes data collected directly from you for account management, billing, marketing, and business interactions.

When We Act as a Data Processor

In providing our products and services to our business customers (including financial institutions and other organizations), we process Personal Data on behalf of and according to the documented instructions of such customers. In such cases we act as a data processor and the relevant customer is the data controller responsible for determining the legal basis, purposes, and means of processing.

Data Subject Requests

If your Personal Data has been provided to us by or on behalf of one of our customers, any requests relating to your Personal Data (including the exercise of your rights under the relevant law) should be directed to that customer. We will assist our customers, as required by our contractual obligations and applicable law, in responding to such requests.

The information we Collect About You

Personal Data

While using our services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally, identifiable information may include, but is not limited to Name and Contact Data: We may collect your first, middle and last name, email address, bank verification number, postal address, phone number, signature, date of birth, an identification document such as a copy of driver's license, international passport, national identity card, Bank Verification Number (BVN), and other similar contact data.

Payment Data

If you subscribe to our subscription-based products, we may process your payment information to facilitate transactions. We do not store sensitive authentication data such as your Personal Identification Number (PIN) or Card Verification Value (CVV). All payment data is processed, transmitted, and stored securely in accordance with applicable payment security standards, including PCI DSS requirements, and may be handled by authorised third-party payment service providers.

Sensitive Personal Data

We may process Sensitive Personal Data in limited circumstances where necessary for our own legitimate business operations, such as security, recruitment, or event-related purposes, and in accordance with applicable law or your explicit consent. Additionally, where necessary for the provision of our products and services to our business customers, we may process Sensitive Personal Data on behalf of such customers. This may include, depending on the services provided, images (still, video, or 3D), voice recordings, biometric identifiers, and other Personal Data processed through our Platform.

Usage Data

Refers to information that your browser or device sends whenever you access our services. The Usage Data may include information such as your Internet Protocol (IP) address, browser type, browser version, pages of our service visited, time and date of visits, time spent on those pages, unique device identifiers, and other diagnostic data. When you access our services via a mobile device, the Usage Data may also include location data (where permission is granted), device type, operating system, and related technical information. You may manage location and device permissions through your device settings.

Mobile Device Access and Data

To enhance your experience, we may request access to certain features on your mobile device, including your device's camera, calendar, Bluetooth, contacts, storage, and other features. If you wish to change our access or permissions, you may do so through your device settings. We may also automatically collect device-related information such as device ID, model, manufacturer, operating system, version, IP address, and diagnostic data.

Analytics and Marketing Data

We may use third-party service providers to monitor and analyse the use of our services. We may also collect information about your marketing preferences to provide you with information about relevant services, products, and offers that we think may be of interest to you.

Information from Third-Party Platforms

We may collect information from social media platforms or other online accounts where you choose to interact with us or share such information.

Other Information You Provide

We may collect additional Personal Data that you provide to us directly, including image recordings such as CCTV footage at our offices, used solely for security, monitoring and auditing purposes to help prevent and detect crime.

Cookies and Tracking Technology

We use cookies and similar tracking technologies to track activity on our Platform and to store certain information. Cookies are small data files placed on your device when you visit a website. We also use other tracking technologies such as web beacons, tags, and scripts to collect, monitor and analyse information, and to improve the functionality and performance of our services.

These technologies may collect information such as your IP address, browser type and settings, device information, and other usage data, including information that may be used to estimate your general location.

You can instruct your browser to refuse all cookies or to notify you when a cookie is being sent. You may also manage permissions on your mobile device, including restricting access to certain device data. Please note that if you disable cookies or restrict permissions, some parts of our Platform may not function properly or may be unavailable.

Types of Cookies We Use

  • Session Cookies: These cookies are used to operate our services and are deleted once you close your browser. They enable us to link your actions during a particular browsing session.
  • Preference Cookies: These cookies allow us to remember your preferences and settings across sessions to enhance your experience.
  • Security Cookies: These cookies help us maintain the security of our Platform and detect potentially harmful activity.
  • Third-party cookies: Some cookies are placed by third-party service providers that support our Platform functionality and analytics. We do not control these cookies and recommend that you review the respective third parties' privacy policies for more information.

Analytics Tools including Google Analytics

We may use third-party analytics tools, such as Google Analytics, to collect and analyse information about how users interact with our Platform. These tools use cookies and similar technologies to collect information such as pages visited, time spent on pages, navigation paths, and other usage statistics.

The information generated by these tools may be transmitted to and stored by the relevant service providers on servers in different jurisdictions, in accordance with their privacy practices. This information helps us understand user behaviour, improve our services, and enhance user experience.

You can control the use of cookies through your browser settings and, in some cases, opt out of analytics tracking directly through the relevant service provider's tools or settings.

How we use Your Personal Information

To the extent permitted by applicable law, we may use your personal information for the following purposes:

  • To determine your eligibility for our products and services.
  • To verify your identity when you access your account or interact with our services.
  • To administer and manage your accounts, as well as any products or services provided by us or our affiliates.
  • To respond to your requests and communicate with you.
  • To understand your needs and preferences, including your financial needs.
  • To provide technical support and ensure the security of the financial data hosted on your behalf.
  • To provide customer support and carry out internal operations, including troubleshooting, data analysis, testing, research, security, fraud detection, and account management.
  • To monitor and analyse the use of our services and improve our business, products, and user experience.
  • To notify you about changes to our products and services.
  • To enable you to participate in interactive features of our services where you choose to do so.
  • To prevent and detect crime, fraud, money laundering, terrorism financing, and other illegal activities, and to manage our risks.
  • To monitor communications (including telephone conversations) for training, quality assurance, verification, fraud prevention, and service improvement purposes.
  • To carry out audits, statistical analysis, and research to better understand customer behaviour and improve our offerings.
  • To send you marketing and promotional communications through various channels (including email, telephone, text, mobile applications, and social media), where permitted. You may opt out of receiving marketing communications at any time; however, we may continue to send you important service-related communications.
  • To provide you with personalised content, recommendations, and marketing based on your use of our services.
  • To comply with applicable legal, regulatory, and contractual obligations, and to enforce our policies.
  • For any other purpose for which you provide your consent, or which is required or permitted by law.

How do we Share Your Personal Information

We may share your personal information in the following circumstances:

Affiliates and Group Companies

With our affiliates and subsidiaries to provide you with a more integrated and improved service offering and for purposes consistent with this Privacy Policy.

Service Providers

With third-party service providers who assist us in delivering our services, including payment processors, technology providers, analytics providers, and customer support services.

How we Secure Your Information

We implement appropriate technical and organisational measures, taking into account the nature, scope, context, and purposes of processing, as well as the risks to individuals, to protect Personal Data and maintain its confidentiality, integrity, and availability. These measures include, among others, encryption, access controls, system monitoring, and other security safeguards designed to prevent unauthorised access, disclosure, alteration, or destruction of personal data.

We require our employees, affiliates, and third-party service providers who process Personal Data on our behalf to adhere to applicable security standards, policies, and confidentiality obligations.

Where you are provided with, or create, a password or other authentication credentials to access any part of the Platform, you are responsible for maintaining the confidentiality of such credentials. You must not share your password or other authentication details (including one-time passcodes, tokens, or PINs) with any third party.

While we take reasonable and commercially acceptable steps to safeguard Personal Data, no method of transmission over the internet or method of electronic storage is completely secure. Accordingly, we cannot guarantee absolute security.

You are responsible for ensuring that your account information is accurate and up to date, and for maintaining the confidentiality of your account credentials. Where we receive instructions through your account or using your authentication credentials, we will treat such instructions as authorised by you and may act on them accordingly, to the extent permitted by applicable law.

In the event of a Personal Data breach that is likely to result in a risk to the rights and freedoms of individuals, we will notify the relevant data controller, applicable regulatory authority, and, where required, affected data subjects, within the timeframes prescribed under applicable law.

How Long do we Keep Your Information

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected. Thereafter, we will securely delete or anonymise the information, unless continued retention is required to comply with applicable legal, regulatory, accounting, or internal compliance obligations, or to protect our legitimate interests.

In determining appropriate retention periods, we consider the nature, sensitivity, and volume of the Personal Data, the potential risk of harm from unauthorized use or disclosure, the purposes for which it is processed, and applicable legal, tax, or regulatory requirements.

Where we process Personal Data solely as a data processor on behalf of our business customers, we retain such data in accordance with their documented instructions, the applicable contractual arrangements, and relevant legal or regulatory requirements.

Where Personal Data is no longer required for the purposes stated above, we will securely delete or anonymise it so that it can no longer be associated with an individual. Once anonymised, we may use such data for analytical and statistical purposes without further notice.

Transfer of Data

Transfers out of Nigeria and Other Jurisdictions

In the course of providing our services, we may share your Personal Data with affiliated companies within our corporate group and trusted third-party service providers, such as cloud infrastructure providers, payment processors, and identity verification services, who process data on our behalf. Your Personal Data may be transferred to, and stored in, jurisdictions outside of Nigeria and/or the country from which you access our services, including to our offices and servers in the UAE.

Where we transfer Personal Data across borders, we ensure that such transfers are carried out in compliance with the NDPA. Any additional data protection requirements or jurisdiction-specific obligations applicable to such transfers shall be governed exclusively by the terms of the relevant written agreement between Peerless and the business customer.

Your Rights

We process your Personal Data in accordance with the NDPA and applicable regulatory requirements. Depending on the nature of our relationship with you, your rights include:

  • A right to access your Personal Data.
  • A right to rectify or update your information in our possession.
  • A right to request the erasure of your Personal Data.
  • A right to withdraw your consent to the processing of your Personal Data. This will, however, not affect the legality of processing carried out prior to such withdrawal.
  • A right to object to the processing of your Personal Data, where there are no overriding legal or operational grounds.
  • A right to request that your Personal Data be made available to you in a common electronic format and/or request that such data be transmitted to a third party.
  • A right to request that your Personal Data be erased. We may retain such data if there are valid legal, regulatory or operational retention requirements.
  • A right to opt out of marketing communications.
  • A right to lodge a complaint with a competent data protection authority, and/or to seek redress under the relevant laws.

If we are relying on your consent to process your Personal Data, you have the right to withdraw your consent at any time. Please note, however, that this will not affect the lawfulness of processing carried out before its withdrawal.

When Peerless processes your data as a Data Processor on behalf of a business customer (the data controller), we do not act on requests regarding your data independently and will direct you, or notify the business customer, so your request is handled according to their policies and legal obligations.

Privacy of Minors

Our products and services are intended for general use; however, we do not knowingly collect personal information from children. Our Platform and services are only intended for individuals who are at least 18 years old or who have attained the age of majority in their respective jurisdictions.

If you are a parent or guardian and become aware that a child has provided us with personal information without appropriate consent, please contact us promptly so that we can take appropriate steps to delete such information.

Social Media Platforms

We operate and communicate through our official pages and accounts on various social media platforms to engage with our customers. We may monitor and review comments or posts made about us or our Platform for the purpose of improving our services.

Please note that any information you post on such platforms may be publicly accessible. Your interactions on these platforms are subject to the respective platform's terms of use and privacy policies, and we encourage you to review them carefully.

Our services may also enable you to connect with or share content through third-party websites, applications, or services. We do not control the privacy or security practices of such third parties and are not responsible for the information you choose to share on those platforms.

Career Platform

As part of our recruitment process, we may collect and process personal information relating to job applicants, including information contained in application forms, curriculum vitae (CVs), identity documents, and information obtained during interviews or assessments.

This information is used solely for recruitment-related purposes, including assessing suitability for current or prospective roles, verifying identity, and validating the accuracy of the information provided.

By submitting your application through our career platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal information for the purposes described above. We will ensure that such information is handled in accordance with applicable data protection requirements and is accessible only to authorised personnel.

Third-Party Websites

Our Platform may contain links to third-party websites or services that are not operated or controlled by us. We are not responsible for the content, security, or privacy practices of such third parties. We recommend that you review the privacy policies of any third-party websites you visit.

Third-Party Service Providers

We engage third-party service providers to support the delivery of our services, including for operational, technical, and analytical purposes. These service providers may have access to your personal data only to perform specific tasks on our behalf and are contractually obligated to maintain data protection standards equivalent to the NDPA.

Changes to this Policy

We may update this Privacy Policy to reflect changes in our legal obligations, data processing practices or business operations. If we make material changes, such as changes affecting how personal data is collected, used, or shared, we will notify you by email or through a prominent notice on our Platform at least 30 days before the changes become effective, where practicable. Your continued use of the services after the Effective Date constitutes your acknowledgement of the updated Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information and any updates that may affect you.

Contact Us

We are committed to addressing your privacy concerns promptly and have processes in place to handle complaints efficiently. If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

info@bepeerless.co.

Or send a letter addressed to:

The Data Protection Officer

Email: ademola.adesalu@bepeerless.co

Address: Unit IH-00-01-02-OF-01, Level 02
Innovation One, Dubai International Financial Centre
Dubai, United Arab Emirates