Introduction

At Omits Financial & Technology Inc. ("Omits," "Company," "us," or "we"), we respect and protect the privacy of visitors to our website, http://myomits.com, and our customers who use our products and related services (the "Platform"). These Services are provided by Omits and are intended for use as is.

We take the privilege of accessing your information very seriously. The privacy of our Users is important to us as entrusted. We are also diligent to ensure that there is strict compliance to applicable data protection laws, regulations, rules, and principles. We know that you care about how your personal information is shared and used. This Global Privacy Policy is to inform visitors regarding our policies on the collection, use, and disclosure of Personal Information for anyone intending to use our Service.

This Global Privacy Policy ("Privacy Policy") explains how we collect, use, disclose, and protect visitors' and users' information as part of the Platform in accordance with global data protection laws in Canada, Nigeria, the UK, EU, and EEA (collectively the "Data Protection Laws"). Any discussion of your use of the Platform in this Policy is meant to include your visits and other interactions with the Platform, whether you are a user of our products or not.

Capitalized terms that are not defined in this Privacy Policy have their meaning given to them in our Terms and Conditions of Use, which are accessible on our website or in the Omits App. This includes any relevant agreement, policy, or addendum incorporated therein and any amendments or modifications thereto.

By accessing and using our Platform, you signify your acceptance of the terms of this Privacy Policy. If you do not agree with or are uncomfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Platform.

We're constantly trying to improve our Services, so we may need to change this Policy from time to time as well, but we will alert you of any changes by placing a notice on our website, by sending you an email, newsletter, and/or by some other means. Please note that if you have opted out of receiving legal notice emails from us, or if you have not provided an email address, you are still subject to the terms of those legal notices. It remains your responsibility to read and understand them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

Your personal information will not be disclosed to third parties, unless such disclosure is necessary for processing of your request, such as creating an account on the Platform (the "Account"), effecting transactions on your Account or to carry out verification procedures.

Application of the Global Privacy Policy

We use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person.

This Privacy Policy applies to all information we collect through our Services from current and former Omits users, including you. "Services" means any products, services, content, features, technologies, or functions, and all related websites, applications, and services offered to you by Omits. This policy only applies to the Services and does not apply to the practices of any other Omits service.

This privacy policy also describes how we use Personal Data, with whom we share it, your rights and choices, and how you can contact us about our privacy practices. This privacy policy does not apply to third-party websites, products, or services, even if they link to our Services or Sites, and you should consider the privacy practices of those third parties carefully.

Information Collection

For a better experience, while using our Services, we may require you to provide us with certain personal information for identification, including but not limited to your full name, home address, email address, mobile number, and password. Other information we would require include your date of birth, BVN, valid identification, profile picture, support details, bank account number, and bank name etc.

Required information is identified by an asterisk (*).

These are generally categorized into:

Identity and Contact Information:

These include but are not limited to: Your full name(s), business address, email address, telephone number, your government-issued form of identification, bank verification number (BVN), date of birth. This data is to enable us to verify your identity and to reach you as deemed necessary for business operations.

Identification Documents and Data:

These include, but are not limited to, any Government-issued identity card, Social Insurance Number (SIN), Social Security Number (SSN), or other national ID numbers; a photograph (as applicable); and other necessary registration information required to confirm eligibility for the use of our services under applicable regulations.

Log Information:

Our servers will automatically record information from your interaction with our channels, including log information, location, and device data, links clicked, length of stay on the site, UDI (Unique Device Identifier), etc.

Financial Data:

We will also require financial information such as your account details, payment card information, transaction history, Tax Identification Numbers, tax residency, and necessary transaction details to effect a payment transaction.

Transactional Data:

This is information relating to a payment generated from you as a customer using our products or services.

Customer Service Records:

Upon every contact between us, conversations will be recorded for tracking and reconciliation purposes.

Geolocation Information:

Information that identifies your location obtained through GPS, Wi-Fi, or cell site triangulation. We will collect this data for fraud and risk purposes. In addition, some of our Services may ask you for permission to share your current location within your device settings to enhance the Service.

Employment & Professional Information:

We will also require professional/employment related information including but not limited to your occupation, employer details, business ownership or corporate affiliations and income details.

Biometric & other Authentication Data (if applicable):

Our servers will also collect biometric and other authentication data, including but not limited to identity verification selfies or videos.

Compliance-Specific Data:

We will also require information necessary to ensure compliance with applicable laws and regulations. This includes but is not limited to; politically exposed person (PEP) status, sanctions list screening results, risk ratings, monitoring flags, and adverse media screening results.

How We Get Your Information and Why We Have It

The Information we have about you is directly made available to us when you:

Sign up for an Omits Account;
Use any of our services;
Contact our customer support team;
Fill our online forms;
Contact us;
Mandate any of your employees to transact with us.

We may collect additional information from or about you in other ways not specifically outlined above. For example, we may store information when you respond to a survey. We may also obtain information about you from third parties for functions such as identity verification, fraud prevention, and such required services.

Under Data Protection Laws, we are required to notify you about the lawful basis for processing your Personal Information. The lawful basis we rely on for processing your Personal Information are:

Your Consent: Where you agree to us collecting your Information by using our Services.
Contractual Obligation: Without your Information, we cannot provide our Services to you.
Legal Obligation: To ensure we are fully compliant with all applicable financial legislations such as Anti-Money Laundering and Counter-Terrorist Financing Laws, we must collect and store your Personal Information. We protect against fraud by conducting standard KYC activities with your business information, in line with applicable regulations and laws.
Legitimate Interests: We process your Information to personalize your experience and implement your feedback or requested preferences. For example, you may share certain social media account details with us for authentication purposes. Without this processing, we may not be able to provide you with full access to or enjoyment of our Platform's features.

How We Use Your Information

Under Data Protection Laws, we are required to notify you about our purposes of processing your Personal Information. We use your information for the following purposes:

To serve application content to you.
To create and manage any accounts you may have with us, verify your identity, provide our services, and respond to your inquiries.
To process payments, and refunds.
To provide, administer and communicate with you about products, services, offers, programs, and promotions of Omits, financial institutions, merchants, and partners.
To evaluate and improve our business, including developing new products and services.
For our statistical or survey purposes to improve our website, application and its services to you.
For risk profiling for our application.
To prevent or detect fraud or abuses of our site and enable third parties to carry out technical, logistical, or other necessary functions on our behalf.
As necessary to establish, exercise, and defend legal rights.
As may be required by applicable laws and regulations, including for compliance with Know Your Customers and risk assessment, Anti-Money Laundering, anti-corruption and sanctions screening requirements, or as requested by any judicial process, law enforcement or governmental agency having or claiming jurisdiction over Omits or its affiliates.
If you consent, to notify you of products or special offers that may be of interest to you.
If you contact us, we may keep a record of that correspondence and your contact details.
For other purposes for which we provide specific notice at the time of collection.

Omits collects, uses, and discloses your personal information only with your express consent, which we obtain at the time of account creation or when you use our Services. Your consent is specific to the purposes described in this Privacy Policy.

We will not use or disclose your personal information for any purpose not described in this Policy without obtaining your additional consent, unless required or permitted by law.

In certain circumstances, Omits may collect, use, or disclose personal information without your consent, as permitted by law. These situations include, but are not limited to:

Compliance with legal or regulatory obligations (e.g., AML/CFT reporting, sanctions screening, tax reporting).
Investigating or preventing fraud, money laundering, or other illegal activities.
Responding to a court order, subpoena, or lawful request from a law enforcement or regulatory authority.
Collecting a debt or enforcing a legal claim.
Where the information is publicly available and the collection is consistent with the purpose for which it was made public.

We will limit such collection, use, or disclosure to what is strictly necessary and permitted under applicable law.

Access to Your Contact List

If you consent, Our Website and App may access the contact list stored on your mobile device. This allows you to easily identify and connect with other Omits users so that you can send money to your family and friends by searching for their phone number, email address, or username.

Please note:

We will not send messages to your contacts.
We will not use or share your contact data for any purpose other than enabling you to locate and identify other Omits users.
You may revoke access to your contact list at any time through your device settings.
Our Website and App may use third-party services that may collect information used to identify you. The information that we request will be retained by us and used as described in this Privacy Policy or for compatible purposes.

Omits will not share your personal information with third parties for their promotional or marketing purposes.

We may share your personal information with:

Omits affiliates and subsidiaries, to provide our Services and for internal administration purposes. If your personal information could be used contrary to this policy, you will receive prior notice and the opportunity to communicate preferences you may have.
Law enforcement, government officials, or other third parties, if Omits is compelled to do so by a subpoena, court order, or similar legal procedure, when it is necessary to comply with the law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Omits Terms and Conditions of Use, or as otherwise required by law.
Third-party service providers who assist us in providing services to you or who provide fraud detection or similar services on our behalf. Examples of third parties to whom we may disclose Personal Data for this purpose are banks and payment method providers.
Service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, information technology, and related infrastructure, customer service, email delivery, and auditing services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their benefit.
Other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform.

If you connect your Omits account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the third party about you and your use of the third-party's service. For example, if you connect your Omits account to a social media account, we will receive personal information from the social media provider via the account connection. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this privacy policy.

Information that we share with a third-party based on an account connection will be used and disclosed following the third-party's privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your personal information as part of the account connection. For example, personal information that Omits shares with a third-party account such as a social media account may, in turn, be shared with certain other parties, including the general public, depending on the account's or platform's privacy practices.

Omits will not send your personal information to third-party social networks unless you have specifically provided authorization. In such cases, information is no longer under the control of Omits and is subject to the terms of use and privacy policies of such third parties.

If we wish to share your Personal Information with third parties that are not described in this Policy, we may request your permission as required by Data Protection Law.

You may opt out of having your Personal Information shared with third parties, or from allowing us to use your Personal Information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. However, if you limit the way we use your Personal Information, certain features or the Platform may not be available to you.

Log Data

We want to inform you that whenever you use our Services, in the case of an error in the app, we collect data and information (through third-party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol ("IP") address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.

Cookies

Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device's internal memory.

To make your visit to the Website user-friendly, to keep track of visits and to improve the service, we collect Cookies. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of our services. We utilize cookies to help manage User logins, to protect against security issues, and to remember User preferences. We do not set a persistent cookie to store your passwords, as we do not want anyone to be able to access your account, other than you. We will take all reasonable steps to ensure that your information and data is treated securely and in accordance with this Privacy Policy.

Service Providers

We may employ third-party companies and individuals for the following reasons:

to facilitate our Services;
to provide the Service on our behalf;
to perform Service-related services; or
to assist us in analyzing how our Service is used.

We want to inform users of this Service that these third parties have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

Data Security

The security of your Personal Information is important to Omits. We value your trust in providing us with your Personal Information; thus, we strive to use commercially acceptable means of protecting it. We maintain appropriate internal, technical, and physical controls to ensure that your data is kept safe at Omits. Other security measures include, but are not limited to:

Secure servers and firewalls
Data encryption (in transit and at rest)
Multi-factor authentication
Periodic security testing
Strict access controls for designated employees only

While we implement these commercially acceptable measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, and we encourage you to protect your account credentials (passwords and PINs) at all times.

Data Transfer & Storage

Your personal information may be transferred to, and stored at, a destination outside of Canada, including in countries where our service providers are located. While we take appropriate safeguards to protect your data, please be aware that foreign law enforcement, regulatory, or government authorities may have access to your information in accordance with the laws of those jurisdictions.

We will take all steps reasonably necessary to ensure that your business information is treated securely and in accordance with this Privacy Policy. No separate consent is required for this disclosure, as it is a regulatory and operational disclosure required under applicable privacy laws.

Notice to Quebec Users

If you are a resident of Quebec, please be aware that your personal information may be stored and processed outside of Quebec, including in other Canadian provinces and in other countries where our service providers are located. We have implemented appropriate security safeguards to protect your data in accordance with applicable Quebec privacy laws. These safeguards include encryption, access controls, and contractual protections with our service providers.

Automated Decision-Making & Profiling

Omits uses automated systems to assist in risk assessment, fraud detection, and compliance screening (including KYC and AML/CFT checks). These systems help us make decisions about account approvals, transaction limits, and security flags. The decisions are based on criteria such as transaction history, location data, identity verification results, and sanctions screening outcomes.

Automated decisions are reviewed regularly to ensure they are fair, accurate, and consistent with applicable laws. You may request a manual review of any automated decision that significantly affects you by contacting our Privacy Officer at compliance@myomits.com.

Retention & Destruction of Personal Information

Omits retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, including to meet legal, regulatory, and accounting requirements. Retention periods vary by jurisdiction and data type, but generally include:

KYC records: minimum 5 years (or longer where required by law).
Transaction records: 5–7 years for accounting, tax, and audit purposes.
Logs and usage data: up to 7 years for security, fraud prevention, and research.

Once your personal information is no longer required for these purposes, it will be securely destroyed, anonymized, or disposed of in accordance with applicable laws and industry best practices. Destruction methods may include permanent deletion from our systems, cryptographic erasure, or physical destruction of media.

We will securely destroy or anonymize your personal information once it is no longer required for the purposes outlined in this Policy, unless we are legally required to retain it for a longer period.

Direct Marketing

Direct marketing refers to any communication intended solely to advertise or promote products and services. However, transactional messages related to your account or our Platform are not considered direct marketing.

We contact customers via electronic means (such as email) only under the following conditions:

Based on our legitimate interests, where we provide information about our Platform that is similar to a product or service you previously purchased or inquired about.
With your consent, where required by law.

If you prefer not to receive direct marketing communications or do not want us to share your Personal Information with third parties for marketing purposes, you can:

Click the unsubscribe link in any marketing email.
Contact us at support@myomits.com

You have the right to opt out of direct marketing at any time and at no cost.

Your Privacy Rights

You have rights to your Personal Information, which are described below. You can exercise your rights by contacting us at compliance@myomits.com, so that we may consider your request under applicable law. When we receive an individual rights request via email, we may take steps to verify your identity before complying with the request to protect your privacy and security.

Right to withdraw consent: If we process your Personal Information based on your consent, you may withdraw your consent at any time. However, withdrawing consent will not affect the lawfulness of any processing conducted before your withdrawal.
Right to erasure (or "the right to be forgotten"): You have the right to request erasure of your Personal Information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing that you previously consented to, but no longer consent to; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. Your right to erasure is subject to limitations by relevant Data Protection Laws.
Right of access to and rectification of your Personal Information: You have a right to request a copy of your Personal Information stored with Omits. We will provide a copy to you without undue delay, subject to some fee associated with gathering of the information (as permitted by law). We may limit access if providing this information could affect the rights and freedoms of others. You may also request us to correct or update any inaccurate Personal Information stored by us, subject to certain limitations under applicable law.
Right to data portability: If we process your Personal Information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your Personal Information in a structured, commonly used, and machine-readable format, and to have us transfer your Personal Information directly to another data controller, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.
Right to restriction of processing: You have the right to restrict our processing of your Personal Information where one of the following applies:
- You contest the accuracy of your Personal Information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your Personal Information.
- The processing is unlawful and you oppose the erasure of your Personal Information and request the restriction of its use instead.
- We no longer need your Personal Information for the purposes of the processing, but it is required by you to establish, exercise, or defend legal claims.
- You have objected to processing, pending the verification of whether the legitimate grounds of Omits' processing override your rights.
Right to object to processing: Where the processing of your Personal Information is based on consent, contract, or legitimate interests, you may restrict or object, at any time, to the processing of your Personal Information as permitted by applicable law. We can continue to process your Personal Information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
Automated Decision-Making & Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, if it produces legal or similarly significant effects on you. Some exceptions may apply under Data Protection Laws.

Limitations to Your Rights

Your rights to your Personal Information are not without limits. Access may be denied when:

Denial of access is required or authorized by law
Granting access would have a negative impact on others' privacy
Doing so protects our rights and properties, or
Where the request is frivolous or vexatious

Designated Contact for Privacy Matters & Escalation

Omits has appointed a Privacy Officer who is responsible for overseeing our compliance with this Privacy Policy and applicable data protection laws. All privacy-related inquiries, concerns, or complaints should be directed to:

Privacy Officer

Omits Financial & Technology Inc.

Email: compliance@myomits.com

Department: Risk & Compliance

If you are not satisfied with our response, you may escalate your concern to the Office of the Privacy Commissioner of Canada (OPC) at:

Office of the Privacy Commissioner of Canada

30 Victoria Street, Gatineau, Quebec K1A 1H3

Website: https://www.priv.gc.ca/en/

Toll‑free: 1‑800‑282‑1376

Changes to This Privacy Policy

We reserve the right to modify, update, or change this Policy as needed in the normal course of business, so we encourage you to review this page periodically. However, if we make material changes to this Policy, we will update the effective date at the top of this page and provide you with reasonable notice before the changes take effect. Omits may notify you via email, written notice, hard copy notice, or by posting a notice on the Platform. We determine the form and method of providing such notifications. You may be required to click-to-accept or otherwise agree to the updated Policy, but your continued use or access of the Platform after the updated Policy's effective date will constitute your acceptance of the changes. The Policy will take effect on the date specified at the top of this page and will apply to your use of the Platform from that point forward. For non-material updates, we will simply update the "last modified" date at the top of this page. If you do not agree to this Policy or any future updates, you may not use or access (and must stop using or accessing) the Platform. Omits is not responsible for any automatic filtering that you or your network provider may apply to email notifications sent to the email address you provide.

Contacting Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us by email at compliance@myomits.com or at: