1. Introduction

Transport Payment Solutions Nigeria Limited ("TPS”, “we", "us", or "our"), is a company that specializes in providing transportation services. TPS’ Privacy Policy gives you a clear view of how we use personal information that you provide, our dedication to protecting it and your rights and the options you have to control your personal information and protect your privacy. It also outlines what personal information we collect about you when you visit our website, when you use our mobile apps, speak to our Contact Centre, and how we use your personal information. It also sets out how to contact us if you have any questions about this Privacy Policy or want to make a complaint to us about how we handle your personal information.    

2. What information do we collect about you?
 

(a) User information: When you use our Service, we may collect personal        information such as your name, email address, phone number, and billing         information, national identification number.

(b) Travel Information: We may collect information about the journey and tickets you browse, purchase, or reserve through the Service, including journey details and ticket types.

(c) Log Data: We automatically collect information about your device, such as your IP address, browser type, browser version, and operating system, as well as your interaction with the Service. In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this.  

3. How we protect your personal Information
We are committed to protecting your personal information and implementing appropriate      technical and organizational security measures to protect it against any unauthorized or unlawful processing and against any accidental loss, destruction or damage.    

4. How we use your Personal information
We will only use your personal information if and to the extent that applicable local laws.  

4.1      Processing your transaction: We use relevant personal information described above to process and deliver your transaction, to process ticket purchases and reservations and to notify you of the status of your transactions.  

4.2      To engage with you in relation to our products and services: We will use your personal information to provide you with the products and services you have requested from us. We will process your personal information in this way if it is necessary for the performance of the contract with us.  

4.3 To do all things necessary to comply with our customers’ instructions and our legal obligations to our customers and in compliance with privacy legislations such as the Nigerian Data Protection Act 2023, NDPR 2019. We will therefore only process your personal information if:  

4.4     You have given your consent (where necessary) to such use or  

4.6        If we have a legitimate interest which is not overridden by your interests or your rights and  freedoms; to prevent and detect any misuse of the Website or Service, or any fraudulent activities carried out through the Website or in the use of our Services; to monitor, prevent and detect fraud, enhance security, monitor and verify identity or access, and combat spam or other malware or security risks; direct marketing or improve customer services where there is a legitimate interest to do so  

4.7       To contract with you and administer the delivery of the Services through any of our products you opt to use or to fulfil a specific request and provide customer support, such as responding to inquiries and handling complaints; enforce our terms of service and any terms and conditions of any other agreements for our Services; share personal data with third parties and service providers that provide services on our behalf.  

4.8        If the processing of your data is necessary where there is a statutory/legal obligation on us, for example, to interact with regulatory authorities or other public authorities concerning you. If you have given us your express consent, we may process your personal data for additional purposes. Please note that you may withdraw your consent at any time, you may so wish.  

5. If you fail to provide personal data?
 
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

6. How is your personal data collected?
We use different methods to collect data from and about you including through:  

6.1    Direct interactions: You may give us your Identity, Contact and Financial Data by filling in  forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:  
           6.1.1.  apply for our products or services;
           6.1.2. create an account on our website;
           6.1.3.  subscribe to our service or publications;
           6.1.4.  request marketing to be sent to you; or
           6.1.5.  enter a competition, promotion or survey; or
           6.1.6.  give us feedback or contact us.  

6.2.   Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies [server logs] and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies].          

7. Retaining your personal data/Data Retention

We will only retain your personal information for as long as is necessary for the purpose for which it was collected, including for the purposes of complying with any legal, regulatory, accounting or reporting requirements. We will delete your personal data when it is no longer reasonably required for the Authorized Uses or you withdraw your consent (whichever is applicable), provided that we are not legally required or otherwise authorized to continue to hold such data.

8. Cookies and Tracking Technologies
We may use cookies and similar tracking technologies to collect information about your browsing behavior and preferences. You can adjust your browser settings to refuse cookies or to be notified when cookies are being used. For more details, see our Cookie Notice.        

9. Your Rights as a Data Subject
               
The law vests you with certain rights as a data subject. They include the right to:

(a) access personal data we hold about you by requesting a copy of the personal data we hold about you;
(b) rectify such information where you believe it to be inaccurate;
(c) restrict the processing of your data in certain circumstances;
(d) object to the processing of your data where we intend to process such data for marketing purposes;
(e) where feasible, receive all personal data you have provided to us—in a structured, commonly used, and machine-readable format—and transmit the information to another data controller;
(f) request the erasure of your data (also known as the right to be forgotten);
(g) withdraw your consent to the processing of your data; and  
(h) lodge a complaint with a relevant authority where you have reason to believe that we have violated the term(s) of this Notice. (You may complain or seek redress from us within 30 days from when you first detect the alleged violation.)  

You may seek to exercise any of the above rights at any time by sending us an email at dpo@secureidltd.com  

The supervisory authority is the Nigerian Data Protection Commission (NDPC), and you can send your complaint via email to info@ndpc.gov.ng.

10. Children's data
Our Services are not intended for, directed at or marketed to persons below the age of 18. We do not knowingly collect personal information from anyone under the age of 18.

11. International transfers
Data will be processed within Nigeria. Should this change in the future and we will need to transfer your personal data out of Nigeria, we ensure a similar degree of protection is afforded to it by ensuring the safeguards as mandated by the NDPR are in place.

12. Marketing and communications
We only send marketing communications to you with your consent or while relying on a legitimate interest to do so. You can opt out of our marketing or object to further processing You may contact us via email at dpo@secureidltd.com and request to discontinue receiving marketing messages

13.      Complaints
If you have any inquiries or complaints, please reach out to our Data Protection Officer (DPO) at dpo@secureidltd.com. Our DPO will examine your concerns and update you on the resolution process. Also, you may complain to the regulatory authority (NDPC) at info@ndpc.gov.ng
f your complaints are not satisfactorily addressedour website may contain links to other websites. This Privacy Policy only applies to this website so when you link to other websites, you should read their own privacy policies.  
14.    Other websites


ur website may contain links to other websites. This Privacy Policy only applies to this website so when you link to other websites, you should read their own privacy policies.  

15.        Changes to this Notice
We update our privacy notice from time to time. We will notify our users when we make a change, and visitors will know this by checking the last date of the update on this page whenever they visit.   

16.       Contact Us If you have any questions relating to this Notice, your rights under this Notice, or are not satisfied with how we manage your personal data, kindly reach out to our Data Protection Officer at dpo@secureidltd.com.  

Last updated –January 2025