This Privacy Policy governs the manner in which Total Athlete Sportal Africa Limited ("TASA" "we," "us," and "our") collects, uses, stores, and discloses information collected from our users ("Users", "you" “your”). This policy describes what information we collect about you, how we collect and use the information you share with us, and with whom we share that information. You do not have to share any information with us, but to use our services, we will need verifiable information from you. This policy also contains information about when we share your personal information with Third parties (such as our service providers and partners).

TASA is a data controller and takes your privacy seriously and understands the importance of maintaining the confidentiality of your personal data and other information stored about you. TASA is committed, in the course of its activities and in compliance with applicable data protection laws, to ensure the confidentiality, integrity and availability of your personal data, as well as to respect your privacy. The commitments described in this privacy policy fulfil the principles of data collection and processing in compliance with applicable Nigerian laws.

This Privacy Policy applies to use of our websites, mobile applications, other online services and/or any related services, sales, marketing, promotional or events, and social media activities (collectively, our "Services"). For our Users, this Privacy Policy is part of our Terms of Use. This Privacy Policy applies to your use of (regardless of means of access) our Services. You may access or use our Services through a desktop, laptop, mobile phone, tablet, or other consumer electronic device (each, a "Device"). This Privacy Policy also applies to offline interactions with TASA. By accessing or using our Services, you agree to the terms of this Privacy Policy.

WHAT INFORMATION DO WE COLLECT

You shall be asked to provide your verified information including Personal Data when opening an account with us or subscribing to our platform, and we shall use your Personal Data in accordance with this Privacy Policy.

Personal Data About Your Transactions With Us

As you may use your TASA account to perform financial transactions, we collect Personal Data in connection with each transaction, including transaction time, amount, and merchant details. We may also collect photos, memos, certificates or other information that you attach to your transactions.

Personal Data From Third Parties

When you create a TASA account, we may collect information, including Personal Data about you from non-affiliated Third-party service providers in order to verify your identity and for fraud prevention, including your prior addresses and names. We also work closely with third parties (such as Security agencies, Data verification companies etc) and will notify you when we receive information about you from them and the purposes for which we intend to use that information. We also collect information related to your preferences in receiving marketing campaigns from us and our Third parties and your communication preferences.

Personal Data We Automatically Collect

We (or our service providers acting on our behalf) may collect information about your use of our Services. This information may include Personal Information as well as statistical information that does not identify you ("Analytics"). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy.

Information that we automatically collect in connection with your access or use of our Services may include:

Device Information: We may collect Device-specific information (such as hardware model, operating system version, unique Device identifiers, and mobile network Information, including your mobile phone number). We may associate your Device identifiers or mobile phone number with your TASA account.

Log Information: We may record or log information from your Devices, their software, and your activity accessing or using our Services. This information may include:

• The Device's Internet Protocol ("IP") address.
• Identification numbers associated with your Devices.
• Device event information, such as crashes, system activity, and hardware settings.
• Date and time stamps of transactions.
• System configuration information.
• Other interactions with our Service.

Location Preferences: We may collect your location information from your mobile device with your prior consent. Also, we have incorporated Google Maps into our Services, and you may consent to the collection of location information by Google Maps in connection with your use of this service. Any information collected via your use of Google Maps will be transmitted directly to Google and is not collected by us. Please refer to Google’s privacy policy here for details about their collection, use and sharing of this information.

Information Collected by Cookies and Other Tracking Technologies: We use cookies to personalize our Services for you and to collect aggregate information about the usage of our Services. A cookie is a text file or other local storage identifier provided by your browser or associated applications. We use cookies for record-keeping purposes and to enhance the quality of your use of our Services. The cookies assign random, unique numbers to your Devices to enable our systems to recognize your Devices and to allow us to see how you use our Services.

We use various technologies to collect information on our Services and other websites, and this may include sending cookies to your computer or mobile device. We may also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

Do Not Track Signals: Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.

We allow Do Not Track browser configurations. We use cookies and other tracking technologies, and Do Not Track status may alter the available services with certain browsers, when these tracking functionalities are used to provide services. We do not alter the information our applications attempt to collect based on your Do Not Track configuration.

USE OF PERSONAL DATA

We will only use your Personal Data if we have a proper reason for doing so. We consider the lawful basis for using your Personal Data as set out in the Nigeria Data Protection Regulation (NDPR). These include:

1. To perform a contract with you or to take steps at your request before entering into a contract.
2. Where you have expressly given your consent to the processing of your Personal Data;
3. To comply with our legal and regulatory obligations.
4. To use your Personal Data as is necessary for our legitimate interests or the legitimate interests of others.
5. To protect your interest, the interest of another Data Subject or for the performance of a task carried out in the public interest or in exercise of official public mandate vested in us.

The personal data we collect will be used in a number of ways as explained below. Under data protection laws we are required to have a lawful basis for the processing of your personal data. We have indicated the lawful basis we rely on below in the headings.

Where we rely on legitimate interest as this lawful basis, our legitimate interest is necessary for promoting our business, improving the services we offer to you and your experience when you interact with us, and ensuring effective operational management and internal administration of our business and the exercise of our rights.

To fulfil contracts:

If you enter into a contract with us (for example, open an account, purchase a product or to enter into a competition) we need to process personal data in order to fulfil the contract by providing the services, processing payments, and corresponding in relation to the same. If you do not provide the information to us, we may not be able fulfil the contract and provide the products or services to you.

Where we have your consent:

We ask for your consent to send you direct marketing communications relating to promotional campaigns, events, tournament information and other activities we run. You can choose to unsubscribe at any time. In some limited circumstances, we do not need to obtain your consent for marketing as explained in the legitimate interest section below.

Where we have a legal obligation:

To protect, investigate, deter, and report fraudulent, unauthorized, or illegal activity. We are also under legal obligations in respect of health and safety, ensuring that individuals who have criminal sanctions imposed on them or who have been banned from sporting events do not influence or participate in matters that may compromise the integrity of our services. This may involve the processing of personal data about you and the disclosure of information to the police, state authorities and other bodies where required by law.

Where we have a legitimate interest:

We may process your personal data where it is necessary for our legitimate interests as a business in the following situations:

• Provide, maintain, and improve our Services.
• Provide and deliver the products and services you request, and send you related information, including confirmations.
• Verify your identity and prevent fraud.
• Send you technical notices, updates, security alerts and support and administrative messages.
• Respond to your comments, questions and requests and provide customer service.
• Communicate with you about products, services, offers, promotions, rewards, and events offered by TASA and others, and provide news and information we think will be of interest to you.
• Monitor and analyse trends, usage, and activities in connection with our Services.
• Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests.
• Process and deliver contest or promotion entries and rewards.
• Link or combine with information we get from others to help understand your needs and provide you with better service.
• Carry out any other purpose for which the information was collected.

TASA is based in Nigeria and the Personal Data we collect is governed by the Nigeria Data Protection Regulation (NDPR). By accessing or using the Services or otherwise providing your Personal Data to us, you consent to the processing and transfer of your Personal Data in and to Nigeria and other countries.

DISCLOSURE OF PERSONAL DATA

We may disclose any information we collect about current and former users, including Personal Data, to affiliates and non-affiliated Third parties as follows:

• If you request or authorize it;
• If the information is provided to help complete a transaction for you;
• If the information is required to:
1. comply with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas;
2. enforce our Terms of Use or other agreements; or
3. protect our rights, property, or safety or the rights, property, or safety of our users or others (e.g., to a consumer reporting agency for fraud protection, etc.);
• If the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets);
• If the information is provided to our third-party service providers to perform functions on our behalf (e.g., analysing data, providing marketing assistance, providing customer service, processing orders, etc.);
• For our everyday business purposes;
• For publication of our events on digital and print media.
• We share your Personal Information with delivery companies, educational institutions and may publish your image where you have won a gift in our competitions, giveaways and promotions or as permitted by applicable law or otherwise described in this Privacy Policy.

We will usually not share your Personal Data with other third parties without your consent. Where we need to transfer your Personal Data to another country, we shall ensure that such country to which the data is being transferred shall have adequate data protection laws. We will seek your consent where we need to send your data to a country without adequate data protection laws.

When you are no longer our User, we may continue to share your information as described in this Privacy Policy. We may disclose Analytics with third parties as described elsewhere in this Privacy Policy and for our commercial purposes.

We do not share your Personal Information with:

• Other companies for joint marketing purposes;
• Affiliated companies for their everyday business purposes; or
• Any third parties so they can market to you.