1. Introduction

This Privacy Policy (the “Policy”) applies to Brass Technologies Limited’s online interface (i.e., website or mobile application) and any Brassmoney affiliate, subsidiary or online interface that is linked to this Policy, (individually referred to as a “site”, and, collectively, “sites”). The term “the company” or "Brassmoney" or "we" or "us" or "our" in this Policy shall refer to Brassmoney, and any banking and non-banking affiliates or subsidiaries of Brassmoney that is linked to this Policy. This Policy describes how the Sites may collect, use, and share information from or about you, and explains how information may be collected and used for advertising purposes.

Brassmoney takes the privacy of your information very seriously. This Policy explains how and for what purposes we may use the information collected from you via the Site.

Additional information on our Privacy Policy may be found on our Sites and within Frequently Asked Questions (FAQs) as set out on the Sites.

Please read this Policy carefully. By using the Site and any services we offer via the Site, you are agreeing to be bound by this Policy with respect to the information collected about you via this Site.

You may use the Site only for lawful purposes. You may not use the Site:

• In any way that breaches any applicable local, national or international law or regulation.

• In any way that is unlawful or fraudulent or has any unlawful or fraudulent purpose or effect.

• For the purpose of harming or attempting to harm any person and in any way.

• To bully, insult, intimidate or humiliate any person.

• To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards.

• To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).

• To knowingly transmit any data, send or upload any material that contains viruses, trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

You also agree:

• Not to reproduce, duplicate, copy or re-sell any part of our Site as this is in contravention of the provisions of our terms of use.

• Not to access without authority, interfere with, damage or disrupt:

1. any part of our Site;

2. any equipment or network on which our Site is stored; or

3. any software used in the provision of our Site.

2. Personal information collected

We may collect the following information from you:

• name, username, gender, date of birth;

• email address, postal address, telephone number;

• your interests;

• account number, card number, and expiry date

• or any other information that may be required

Although it is not compulsory to give us this information if you do not, we may not be able to provide you with the full range of services that the Site has to offer.

3. Use of collected information

We will use this information in order to:

• administer your accounts with us;

• process transactions made by you

• send you information about our products and services;

• carry out marketing analysis and make general improvements to our Site;

• obtain your views or comments on the services we provide;

• to help us plan promotional activities;

• to respond to your inquiries and fulfil your requests;

• to inform you about important information regarding the Site, products or services for which you apply or may be interested in applying for, or in which you are already enrolled, changes to terms, conditions, and policies and/or other administrative information;

• to deliver marketing communications that we believe may be of interest to you, including, ads or offers tailored to you;

• to personalize your experience on the Site;

• to allow you to apply for products or services (e.g., to prequalify for a loan, apply for a credit/debit card, or to open an account, or other financial product) and evaluate your eligibility for such products or services;

• to verify your identity and/or location, in order to allow access to your accounts, conduct online transactions and to maintain measures aimed at preventing fraud and protecting the security of your account and Personal Information;

• to allow you to participate in surveys and other forms of market research, sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which may contain additional information about how Personal Information is used and shared;

• for business purposes, including data analysis, audits, developing and improving products and services, enhancing the Site, identifying usage trends and determining the effectiveness of promotional campaigns;

• for risk control, for fraud detection and prevention, to comply with laws and regulations, and to comply with other legal process and law enforcement requirements;

• to allow you to utilize features within our Sites by granting us access to information from your device such as contact lists, or geo-location when you request certain services.

4. Sharing collected information

Services available on this Site are offered in conjunction with some of our business partners, including Bancorp Bank Limited (the "business partners").

In order for services to be provided, we may share some necessary details about you with the Business Partners, and according to our business dynamics and the continued provision of efficient services to you, we may, from time to time, transfer such details to other Business Partners as we deem fit. However, under any circumstance, we will take steps to ensure that your privacy rights continue to be protected.

We may transfer your personal information to any other third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected.

In addition, we may pass your information onto one of our carefully selected business partners or to other carefully selected third parties to enable them to send you information which may be of interest to you but only if you have given us permission to do so. You can stop receiving such mail whenever you choose by unsubscribing via the link provided.

Other than as set out above, we will not disclose any of your personal information without your permission unless we are required by law to do so (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime).

5. Information automatically collected from your computer

We and our third-party service providers may collect and use other information in a variety of ways, including:

• Log files/IP addresses: When you visit the Site, our web server automatically records your IP address. This IP address is not linked to any of your personal information. We use IP addresses to help us administer the Site and to collect demographic information for aggregation purposes.

• Other technologies including pixel tags, web beacons, and clear gifs: These may be used in connection with some Site pages, downloadable mobile applications and HTML-formatted email messages to measure the effectiveness of our communications, the success of our marketing campaigns, to compile statistics about usage and response rates, to personalize/tailor your experience while engaging with us online and offline, for fraud detection and prevention, for security purposes, for advertising, and to assist us in resolving account holders’ questions regarding the use of our Site.

• Aggregated and de-identified data: Aggregated and De-identified Data is data that we may create or compile from various sources, including but not limited to accounts and transactions. This information, which does not identify individual account holders, may be used for our business purposes, which may include offering products or services, research, marketing or analysing market trends, and other purposes consistent with applicable laws.

• Through your browser or device: Certain information is collected by most browsers and/or through your devices, such as your Media Access Control (MAC) address, device type, screen resolution, operating system version and internet browser type and version. We use this information to ensure Sites function properly, for fraud detection and prevention, and security purposes.

We may also gather other non-personal information (from which we cannot identify you) such as the type of your internet browser which we use to provide you with a more effective service.

6. Cookies

When you visit the Site we may store some information (commonly known as a ) on your computer. Cookies are small files of information which use a unique identification tag and are stored on your device as a result of using the Site or other services we provide to you. A number of cookies we use last only for the duration of your session and expire when you close your browser. Other cookies are used to remember you when you return to the site and will last for longer. A cookie helps you get the best out of the Site and helps us to provide you with a more customised service. We use cookies:

• so that you will not have to re-enter your details each time you visit the Site to track how our Site is used and to improve and update our content

• store your preferences

• customise elements of the layout and/or content of the site for you

• collect statistical information about how you use the site so that we can improve the site

You can refuse to accept these cookies and most devices and browsers offer their own privacy settings for cookies. You will need to manage your cookie settings for each device and browser you use. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Site and some online products and services. For example, we will not be able to recognize your device and you will need to answer a challenge question each time you log on. You also may not receive tailored advertising or other offers from us that may be relevant to your interests and needs.

7. Advertisement and information about other products and services

From time to time we may send you information about other financial products and services offered by the Company that we think may be of interest to you.

Brassmoney advertises online (e.g., pages within our Sites and mobile apps, through the Company’s managed social media presence, and on other sites and mobile apps not affiliated with Brassmoney) and offline (e.g. in banking centres, through call centres, and direct marketing). In order to understand how our advertising performs, we may collect certain information on our Sites and other sites and mobile apps through our advertising service providers using cookies, IP addresses, and other technologies. The collected information may include the number of page visits, pages viewed on our Sites, search engine referrals, browsing activities over time and across other sites following your visit to one of our Sites or Apps, and responses to advertisements and promotions on the Sites and on sites and apps where we advertise.

Brassmoney uses the information described in this Policy to help advertise our products and services. We use such information to:

• Present tailored ads to you, including;

• Banner ads and splash ads that appear as you sign on or off of your online accounts on our Sites, within mobile banking and other mobility applications;

• E-mail, postal mail, and telemarketing;

• On other sites and mobile apps not affiliated with Brassmoney;

• Analyse the effectiveness of our ads; and

• Determine whether you might be interested in new products or services

You can tell us to stop this at any time by sending an email to help@brassmoney.com

Advertising on third-party sites and mobile apps: Brassmoney contracts with advertising companies to advertise our products and services on sites and mobile apps not affiliated with us. We may use Aggregated and De-identified Data and information provided by you to these third-party sites and mobile apps to select which of our advertisements or offers may appeal to you, display them to you and monitor your responses. Third-Party Sites and mobile apps are not subject to Brassmoney's Privacy Policy. Please visit the individual sites and mobile apps for additional information on their data and privacy practices and opt-out policies.

8. Changes to your details

Keeping your account information accurate and up to date is very important. If your account information is incomplete, inaccurate or not current, please use the Contact Us option on our Site, or call or write to us at the telephone numbers or appropriate address for changes listed on your account statements, records, online or other account materials. You can also speak to a customer representative from the Company.

9. Use of forums or chat rooms

The Site may from time to time include chat rooms, forums, message boards, and/ or news groups on which you can post information. Any information that you post in these areas becomes public information and you should always be careful when deciding to disclose your personal details as part of that information.

10. Security

To protect Personal Information from unauthorized access and use, we use security measures that comply with applicable federal laws. These measures may include device safeguards and secured files and buildings as well as oversight of our third-party service providers to ensure information remains confidential and secure.

We have implemented technology and policies to safeguard your privacy from unauthorised access and improper use. We use secure server software (SSL) to encrypt any financial information you need to input before it is sent to us.

11. Linking to third-party websites and other aggregation website

Linking to other sites: We may provide links to third-party sites, such as service providers or merchants. If you follow links to sites not affiliated or controlled by Brassmoney, you should review their privacy and security policies and other terms and conditions, as they may be different from those of our Sites. Brassmoney does not guarantee and is not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of their information.

We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our Site and recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.

Using Other Aggregation Websites: Other companies offer aggregation websites and services that allow you to consolidate your financial account information from different sources (such as your accounts with us or with other financial institutions) so that you can view all your account information at one online location. To do this, an aggregation provider may request access to personal information, such as financial information, usernames and passwords. You should use caution and ensure that the aggregator company has appropriate policies and practices to protect the privacy and security of any information you provide or to which they are gaining access. We are not responsible for the use or disclosure of any personal information accessed by any company or person to whom you provide your Site username and password.

If you provide your Site username, password or other information about your accounts with us to an aggregation website, we will consider that you have authorized all transactions or actions initiated by an aggregation website using access information you provide, whether or not you were aware of a specific transaction or action. If you decide to revoke the authority you have given to an aggregation website, we strongly recommend that you change your password for the Site to ensure that the aggregation website cannot continue to access your account.

12. Social media sites

Brassmoney provides experiences on social media platforms including, but not limited to, Facebook®, Twitter®, and LinkedIn® that enable online sharing and collaboration among users who have registered to use them. Any content you post on the official Brassmoney managed social media pages, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is subject to the Terms of Use and Privacy Policies of those respective platforms. Please refer to them to better understand your rights and obligations with regard to such content. In addition, please note that when visiting any official Brassmoney social media page, you are also subject to Brassn Privacy Policy.

13. Updates to this privacy policy

This privacy policy is subject to change. Please review it periodically. If we make changes to the Policy, we will revise the “Last Updated” date at the top of this Policy. Any changes to this Policy will become effective when we post the revised Policy on the Site. Your continued use of the Site following these changes means that you accept the revised Policy.

14. Contact us

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your personal information, you can do so by sending an email to us at help@brassmoney.com or writing to us at 21B Modupe Odulami Street, Oniru Lagos.