SEABED MULTIPURPOSE COOPERATIVE SOCIETY LTD

1. INTRODUCTION

Welcome to Seabed Multipurpose Cooperative Society Ltd ("Seabed," "we," "our," or "us"). We operate the Seabed mobile application and provide financial services to our members.

We are committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and financial services.

By using our services, you consent to the data practices described in this policy.

2. INFORMATION WE COLLECT

2.1 Personal Identification Information

• Full legal name and date of birth
• Phone number and email address
• Residential address and proof of address
• National Identification Number (NIN)
• Bank Verification Number (BVN)
• Bank account details
• Government-issued ID documents
• Photograph for identity verification

2.2 Financial Information

• Transaction history and records
• Savings and investment data
• Income verification documents
• Credit history and reports
• Tax identification information

2.3 Technical Information

• Device information (model, OS, unique device identifiers)
• IP address and general location data
• App usage statistics and analytics
• Crash reports and error logs
• Cookies and similar technologies

2.4 Biometric Information (Optional)

Only with your explicit consent:

• Facial recognition data for app authentication
• Fingerprint data (where supported and enabled)

3. HOW WE COLLECT INFORMATION

• Direct from you: During account registration, KYC verification, and app usage
• Automatically: Through app functionality and technical processes
• From third parties: Banks, credit bureaus, identity verification services
• Service interactions: Customer support communications and service requests

4. HOW WE USE YOUR INFORMATION

4.1 To Provide Our Services

• Create and manage your membership account
• Process savings, investments, and financial transactions
• Calculate and distribute returns and dividends
• Provide account statements and financial reports
• Send service-related notifications and updates

4.2 For Legal and Regulatory Compliance

• Verify your identity (KYC requirements)
• Prevent money laundering, fraud, and financial crimes
• Comply with Central Bank of Nigeria (CBN) regulations
• Meet tax reporting and compliance obligations
• Respond to lawful legal requests and court orders

4.3 For Business Operations

• Improve our services and develop new features
• Conduct risk assessment and credit evaluation
• Provide customer support and resolve issues
• Ensure security and prevent unauthorized access
• Analyze usage patterns for service optimization

4.4 For Marketing (With Your Consent)

• Send promotional materials and offers
• Inform you about new products and services
• Conduct market research and surveys

5. DATA SHARING AND DISCLOSURE

5.1 When We Share Your Information

5.2 Data Sharing Limitations

• We only share information necessary for the specific purpose
• All third parties are contractually bound to protect your data
• We conduct due diligence on all service providers
• We comply with data minimization principles

5.3 What We Do NOT Do

• We do NOT sell your personal information to third parties
• We do NOT share your information for marketing without explicit consent
• We do NOT disclose sensitive financial data unnecessarily
• We do NOT use your data for purposes unrelated to our services

6. DATA SECURITY

We implement comprehensive security measures including:

• End-to-end encryption for data in transit and at rest
• Multi-factor authentication and access controls
• Regular security audits and penetration testing
• Secure data centers with 24/7 monitoring
• Employee background checks and privacy training
• Incident response and data breach procedures

7. DATA RETENTION

We retain your information only as long as necessary:

• Active accounts: Duration of membership plus regulatory requirements
• Financial records: 10 years after account closure (CBN requirement)
• KYC documents: 10 years after relationship ends
• Technical logs: 12 months maximum
• Marketing data: Until consent withdrawal or 2 years inactivity

8. YOUR RIGHTS

You have the right to:

• Access: Request copies of your personal information
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your data (subject to legal requirements)
• Portability: Receive your data in a machine-readable format
• Withdraw Consent: Opt-out of marketing and non-essential processing
• Object to Processing: Object to certain data processing activities
• Complaint: File complaints with regulatory authorities

To exercise these rights, contact us at seabed@seabedcooperative.org

9. INTERNATIONAL DATA TRANSFERS

Your information may be processed outside Nigeria. We ensure protection through:

• Adequacy decisions by relevant authorities
• Standard contractual clauses with data processors
• Appropriate security safeguards and encryption
• Compliance with international data protection standards

10. THIRD-PARTY SERVICES

Our app may integrate with or link to third-party services. These services have their own privacy policies, and we encourage you to review them.

We are not responsible for the privacy practices of third-party services.

11. CHANGES TO THIS POLICY

We may update this Privacy Policy. We will:

• Notify you of material changes via app notification or email
• Post the updated policy with a new "Last Updated" date
• Obtain your consent for significant changes where required by law
• Provide a summary of changes for your review

12. CONTACT INFORMATION

13. COMPLAINTS AND DISPUTE RESOLUTION

For privacy-related concerns:

1. Contact our Privacy Officer first
2. Escalate to our Data Protection Officer if unresolved
3. File a complaint with the Nigerian Data Protection Commission (NDPC)

We commit to responding to all legitimate requests within 30 days.