Personal data and privacy

Privacy
Policy.

This policy explains how Pintop Technologies Limited collects, uses, shares, protects and retains personal data through its website, business relationships, products, services and workforce activities.

Website
Clients
Products
People

Privacy depends on the relationship and processing context.

This policy applies to personal data collected directly by Pintop through its website, business communications, contracts, recruitment, workforce administration and other corporate activities.

It also explains Pintop’s role where its software or services process personal data on behalf of a client organisation.

Product-specific processing may also be governed by a client’s privacy information, the applicable service agreement, Data Processing Agreement and documented configuration or instructions.

Pintop may act as controller
or processor.

The role Pintop holds determines which organisation decides why and how personal data is processed.

Pintop as data controller

Pintop acts as controller where it determines the purpose and means of processing, including website enquiries, prospective-client relationships, supplier administration, recruitment and workforce information.

Pintop as data processor

Pintop may process personal data on behalf of a client through a product, implementation, support arrangement or connected service. In that relationship, the client determines the processing purpose and Pintop follows documented instructions and the applicable agreement.

The information Pintop may
process.

The categories collected depend on how a person interacts with Pintop and which product, service or relationship is involved.

Website and technical information

IP address, browser and device details, operating system, referral information, page activity, session data and other technical records generated through website use.

Contact and enquiry information

Name, email address, telephone number, organisation, role and information submitted through a form, email, telephone call or other business communication.

Client and commercial information

Business contacts, proposals, contracts, orders, invoices, billing records, communications, account information and support history.

Account and service information

User identifiers, login activity, permissions, audit records, feature usage, support requests and other information produced through use or administration of a service.

Applicant and workforce information

Applications, CVs, qualifications, employment records, payroll details, statutory information, performance, leave, training and other workforce-administration records.

Client-controlled product data

Personal data entered into or processed through a client implementation may include identity, account, transaction, business, employee or customer information, depending on the contracted product and configuration.

How information is obtained

Personal data may come directly, automatically or through another organisation.

Pintop limits collection to information reasonably connected to the relevant website, business, employment, product or service activity.

Direct interactions
Forms, emails, calls, meetings, applications, contracts, support requests and other direct communications.
Website technology
Cookies, server records, analytics and similar technologies used according to the Cookie Policy and stored preferences.
Clients and partners
Information supplied by a client, authorised representative, service provider, integration partner or other relevant organisation.
Public and professional sources
Business-contact information available through company websites, professional platforms, events or other legitimate public sources.

Why Pintop processes
personal data.

Each processing activity should have an appropriate purpose and lawful basis.

PurposeRelevant lawful basis
Responding to enquiries, demo requests and business communications.Legitimate interests, consent or steps connected to a possible contract.
Providing contracted products, implementation, support, maintenance and account services.Contractual necessity and legitimate interests.
Processing invoices, payments, tax records and commercial administration.Contractual necessity and legal obligations.
Operating, securing, monitoring and improving websites, products and services.Legitimate interests, legal obligations and consent where required for non-essential technology.
Sending relevant product, event or business communications.Consent or legitimate interests, depending on the relationship and communication.
Recruitment, workforce administration, payroll, performance and statutory employment records.Contractual necessity, legal obligations and legitimate interests.
Investigating incidents, preventing misuse and protecting legal rights.Legitimate interests, legal obligations and the establishment or defence of legal claims.
Processing personal data for a client through a contracted product or service.The client’s lawful basis and Pintop’s contractual processing obligations.

Product processing depends on the
implementation.

Product architecture, hosting, integrations, access and retention may differ according to the contracted solution and deployment model.

Core banking solutions

Financial, customer, account, transaction, lending, approval and related operational data may be processed according to the client’s service configuration, infrastructure and documented instructions.

Identity verification

Identity attributes and verification results may be processed through approved verification providers and service flows according to the applicable client agreement and product configuration.

Business management systems

Business, supplier, customer, employee, invoice, inventory, payroll and project information may be processed through the relevant client environment and configured modules.

How personal data is
protected.

Pintop applies technical and organisational safeguards appropriate to the relevant system, relationship, risk and deployment model.

Access management

Access is limited according to role, business need, account status and the controls available in the relevant product or environment.

Secure transmission and storage

Appropriate encryption, secure transport and platform-level protections may be used according to the system and processing context.

Controlled software delivery

Changes are handled through development, review, testing, approval and deployment processes appropriate to the product and service.

Logging and accountability

Relevant systems may maintain access, activity, support, change and security records for operational and accountability purposes.

People and process

Confidentiality, access responsibilities, awareness, escalation and appropriate workforce procedures support technical controls.

Incident response

Suspected incidents are reported, assessed, contained, investigated and reviewed through the applicable response process.

Sharing and recipients

Personal data is shared only where there is an appropriate reason.

Pintop does not sell personal data. Information may be disclosed where necessary for a service, relationship, legal obligation, investigation or other legitimate purpose.

Technology and hosting providers
Infrastructure, communications, analytics, identity, payment, support and related service providers.
Professional advisers
Legal, accounting, audit, tax, compliance and other professional advisers acting under appropriate obligations.
Client organisations
Information may be disclosed to the relevant client where Pintop processes data on that organisation’s behalf.
Authorities and legal recipients
Regulators, courts, law-enforcement bodies and other parties where disclosure is required or permitted.

Retention and processing
locations.

How long information is kept and where it is processed depend on the category, purpose, product, provider and contractual arrangement.

Data retention

Personal data is retained while it is reasonably required for the processing purpose, contractual relationship, legal obligations, security, accountability or legal claims.

International processing

Where personal data is processed outside Nigeria, Pintop applies the contractual, legal and organisational safeguards appropriate to the transfer and service involved.

Your data protection
rights.

Rights are subject to the conditions and limitations applying to the relevant information and processing activity.

Access

Ask whether personal data is being processed and request a copy of eligible information.

Rectification

Ask for inaccurate or incomplete personal data to be corrected.

Erasure

Ask for deletion where there is no continuing lawful or required reason to retain the information.

Restriction

Ask for processing to be limited in appropriate circumstances.

Portability

Request eligible data in a structured and machine-readable format.

Objection

Object to certain processing, including eligible direct marketing.

Withdraw consent

Withdraw consent where consent is the basis for the relevant processing.

Automated decisions

Exercise applicable rights concerning solely automated decisions that have significant effects.

Privacy enquiries

Questions about this policy or your personal data?

Include the relevant website interaction, account, product, client relationship, employment context or communication so the enquiry can be routed correctly.

Organisation
Pintop Technologies Limited
Contact
Data Protection Officer
Telephone
Address
St Finbarr’s College Rd, Akoka Yaba, Lagos
Changes to this policy

Privacy information may change as Pintop’s services evolve.

Pintop may update this policy when products, systems, processing activities, providers or applicable obligations change.

The Last Updated date identifies the current published version.
Material changes may be highlighted through the website or another appropriate communication channel.
Product- or client-specific agreements remain authoritative for the processing relationship they govern.