Verificio.com ("The Platform", "The Site", or "The App") was designed and is owned by Verificio Technologies Inc. ("Verificio","we", "us", "our" " the Company") to serve as a web-based Referencing and Verification database for the use of employers who desire to verify the work history of their existing and prospective employees. In the course of providing these services, we collect and hold Personal and Company Information. As the term suggests, "Personal Information" is information which can be associated with a specific individual or entity, for example, name, address, telephone number, e-mail address, photograph, identification information, any other identifier that permits the physical or online contacting of a specific individual, and information about a user that is collected and maintained in personally identifiable form in combination with other Personal Information. Company information include Company name, address, registration number, certificate of incorporation and any other corporate details collected at the point of registration. Verificio has identified this policy as a necessary tool for ensuring that privacy rights are protected in the collection and management of information as guaranteed under the 1999 Constitution of the Federal Republic of Nigeria, the Nigerian Data Protection Regulation 2019 (NDPR) issued by the National Information Technology Development Agency (NITDA), and other relevant laws applicable both in Nigeria and the USA. This Privacy Policy applies to all Personal Information provided by you via use of this Platform and/or the online services provided via the Platform (the "Services") and explains our privacy practices with respect to how we process your Personal Data and describes your rights as a user on the Platform and our Services. Verificio is committed to safe-guarding the privacy of all registered users by ensuring that all data and information collected and held in the database are kept secure, and guarding against unauthorized use by ensuring that usage of such information or data is limited to only those with authorized access. Verificio reserves the right to change or amend this policy at any time by notifying users of the existence of a new privacy statement.

Consent

You are hereby advised to carefully read through this Privacy Policy before you proceed to use our Platform. Should you proceed to use the Platform and our services, it will be deemed that you have read, understood and granted your express consent to the terms of this Policy.

Eligibility and Age

You must be a registered entity or person of at least 18 years of age to use our services or any of our Platforms.

Information we collect about you

We collect your personal information directly from you as you register on our Platform and in the course of your other engagements with us or through third parties who use the Platform. The data we collect may include User-Reported Information as well as Information collected from our various platforms. The types of Personal Information collected may include:

• Name
• Address
• Email address
• Phone number
• Other information which is required to complete your registration or while using the Services, which may include personal identification information such as social security number, driver's license number and similar information.
• Other information as agreed upon through separate Terms of Use/Terms and Conditions specified to the application, where applicable.

These details may be collected in the following manner:

• Automatically: Your data may be collected automatically as you use our Platforms through your mobile phones, computers, and other digital platforms. We also collect some information anonymously through the use of cookies. Please note that declining to accept the use of cookies may affect your use of our Platform.
• Digitally: We may obtain your data when you download items from our platform or run activities on the digital Platform. When you visit our platform, we may also receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertisements, search results, and other personalized content. We may collect and process your information when you register or update your account on our Platform as well as when you complete forms, questionnaires, surveys etc. We may also collect Data from the data you provide to us through API, documents, letters, e-mail, agreements, correspondence, Identity cards, certificates, passports, or through any other means.
• Social Media: We also receive Data through your engagements with us on any of our social media platforms (Facebook, Instagram, LinkedIn, Twitter, WhatsApp, etc.). This includes but are not limited to your replies to our posts, your comments, enquiries, messages to us, etc.

Using Your Personal Data

As a policy, we use your Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual.

Some of the reasons we collect your Personal Information as described in this Privacy Policy are to:

• Enable, support, personalize and customize your use of the Site and/or our products, applications or services in a more efficient way;
• provide you with updates and information about our platform and services;
• conduct analysis for our business purposes; support development and marketing of our services; and
• create de-identified information and then use and disclose this information in any way permitted by law, including to third parties in connection with their commercial and marketing efforts.
• assess the performance of our platform and services for improvement purposes;
• provide a means by which we can contact you, either via telephone, text messaging, email messaging, social media, etc;
• fulfil our contractual obligation to you;
• Perform other functions or serve other purposes, as disclosed to you at the point of collection or as required or permitted by law.

If there are any changes to use of personal information, you will be notified via email and/or via a notice on our Platform of any change in uses of your Personal Information.

How we Processing your Information

Verificio will rely on the following lawful bases for processing personal data and special category personal data:

• Legal obligation
• Consent
• For the performance of a contract ("Contractual")

In the course of fulfilling our obligations to you, we may require to process your Data, such as your name, contact information, ID information and other relevant information that may be required to render service to you. Our third-part partners such as payment service providers, financial institutions, vendors may also require to process your information in the normal course of our partnership. For completeness, in the course of your engagement with us or use of our services and Platforms, we may share your information with different stakeholders, including but not limited to financial institutions, service providers, affiliates of Verificio; regulatory or judicial authorities; or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Verificio. Please note that the parties mentioned above may be within or outside Nigeria.

We may also process your Data when we believe, in our sole discretion, that the disclosure of your Data is necessary to comply with applicable laws and judicial/regulatory orders; conduct investigations; manage existing or imminent risks, prevent fraud, crime or financial loss, or for public safety or to report suspected illegal activity or to investigate violations of our Terms and Conditions.

In all cases, we will ensure that your Data is safe and strictly processed only when necessary, and we will notify the receiving party of the confidential nature of your Data, particularly the need to maintain the confidentiality of same and prevent unlawful and unauthorized usage.

Your Rights

You have the following rights regarding your personal information collected by us:

• Right to access your personal Data being held by us.
• Right to request that your personal data be made available to you in an electronic format or that it should be sent to a third party (Kindly note that we have the right to decline such request if it is too frequent, unreasonable, and likely to cause substantial cost to us. In any event, we will communicate the reason for our refusal);
• Right to rectify any inaccurate, incomplete information. As such, if you discover any inaccuracy in your personal Data, kindly notify us promptly and provide us with documentary evidence to enable us to update the requisite changes;
• Right to withdraw consent for the processing of your Data, provided that such withdrawal shall not invalidate any processing previously done based on the consent previously given by you;
• Right to restrict or object to the processing of your personal Data. Kindly note that this right will not apply if we are compelled to process your data where required by any law, regulatory authorities, or court of law;
• Right to request that your personal Data be deleted. We may however continue to retain the Data where required by law, contract, regulatory authorities, or court of law.
• Right to Data portability;
• Right to lodge complaints with relevant authorities;
• Right to information regarding the existence of automated decision-making, including profiling and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing;

Software

If you download or use our software, such as a stand-alone software product, an app, or a browser plugin, you agree that from time to time, the software may download and install upgrades, updates and additional features from us to improve, enhance, and further develop the software

Cross Border Data Transfer Policy

While providing our services and in a bid to serve you better, we may be required to transfer your Data/Data (electronically or otherwise) across the borders of Nigeria. Nonetheless, we have an unwavering commitment to ethical and responsible practices in ensuring that your Personal Data is adequately protected regardless of where the Data is transferred or hosted.

This Policy defines our global standards for management and protection of Data/Data by or on behalf of Verificio regardless of the country from which it originates or to which Data may be transferred. This Policy will apply to any transfer of information which is undergoing processing or is intended for processing after transfer to a foreign country or to an international organisation.

We will only transfer Data or allow it to be processed by third parties in a different jurisdiction if such country has an adequate level of data protection as determined by the appropriate regulatory authority (that includes the National Data Technology Development Agency, Honourable Attorney General of the Federation, etc.) in accordance with the provisions of the Nigeria Data Protection Regulation or any other privacy laws in force.

In the absence of any decision by the appropriate regulatory authority as to the adequacy of safeguards in a foreign country to which your Data may be transferred, we will only transfer your Data to a foreign country or an international organisation only if any of the following requirements have been met:

• Your explicit consent has been obtained (Please note that such foreign country or international organisation may have privacy laws or policies less stringent that Nigerian privacy regulation or laws. However, we will ensure that the recipient of such Data undertakes to protect your Data and handle it with utmost confidentiality and in accordance with the standards imposed by the NDPR);
• The transfer is necessary for the performance of a contract between you and the Verificio or the implementation of pre-contractual measures taken at your request;
• The transfer is necessary for the conclusion or performance of a contract concluded in your interest;
• The transfer is necessary for public interest;
• The transfer is necessary for the establishment, exercise or defence of legal claims; and
• The transfer is necessary in order to protect your vital interests or of other persons, where you are physically or legally incapable of giving consent.

In order to ensure that any cross-border transfer of your Data is adequately protected, we may

• conduct privacy due diligence to evaluate the privacy practices and risks associated with third parties in a foreign country.
1. they will process your Data pursuant only to Verificio's instructions, and in accordance with our Privacy Policy;
2. obtain contractual assurances from those third parties that:
3. that they will notify Verificio promptly of any data breach, including any inability to comply with the standards set forth in this Policy and applicable laws; and
4. they will not engage another organisation to process your Data without putting in place an agreement imposing equivalent data protection standards.
• ensure that in providing your Data, that we will, where necessary, ensure that it is anonymized, and we will obtain written assurances from any third parties that they will only use the Data for the legal purpose for which it was provided, and in accordance with applicable laws;
• ensure that in providing your Data, that we will, where necessary, ensure that it is anonymized, and we will obtain written assurances from any third parties that they will only use the Data for the legal purpose for which it was provided, and in accordance with applicable laws;
• limit data retention periods for your Data;
• disclose your Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

The confidentiality obligation does not however apply to information which:

• Has already been permitted by Verificio to be disclosed; or
• Which was already in the public domain through no fault of yours; or
• Was already known and freely available to you before receipt from Verificio; or
• Was received from an independent third-party without a duty of confidentiality; or
• is demanded by a governmental, judicial or regulatory order, provided that such written notification of demand is first given to Verificio before such disclosures; or
• is independently developed without using any of Verificio's confidential information.

Cookie Policy

Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when websites are loaded in a browser, and which collects information about user actions on a site.

When you access our Platforms, we may place small data files on your computer or other device. These data files may be cookies, pixel tags, flash cookies, or other local storage provided by your browser or associated applications (collectively referred to as "cookies"). These technologies are used to recognize users as customers; customize services, content, and advertising; measure promotional effectiveness; help ensure that account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety on our Platform. We also use cookies to collect and use Data as part of our services, recognize your browser or device, learn more about your interests, and provide you with essential features and services.

This Policy applies to our websites and Platforms alone. We do not exercise control over the sites displayed or linked from within our various services. These other sites may place their own cookies or other files on your computer, collect Data or solicit personal Data from you.

What type of cookies do we use?

Temporary cookies: This is also known as 'session cookies'; it helps our sites and platforms to recognize users, temporary memorize their online activities and the information provided when they navigate through a website. Session cookies only retain information about your activities for as long as you are on the website. Once the web browser is closed, the cookies are automatically deleted.

Permanent cookies: This is also known as 'persistent cookies' or 'first-party cookies'; they remain in operation even after the web browser has closed. It helps our sites or Platforms remember your information, preferences and settings such as language selection and internal bookmarks for when you revisit in the future.

Why we use cookies?

Cookies store helpful information to enhance users' experiences on our Platforms, and possibly to improve our ability to reconnect with you later. They are used to remember you and your preferences such as your preferred language, device settings, browsing activities and other useful information, help you navigate between pages efficiently, and generally improve your experience in using our services.

These cookies may be used as follows:

• Authentication: We use cookies and similar technologies to recognize you when you visit our site. If you are signed into our website or mobile app, it helps us show you the right information and personalize your experience in line with your settings. Cookies also enables us to identify you and verify your account.
• Security: We use cookies to make your interactions with our services and Platforms faster and more secure. For example, we use cookies to enable and support our security features, keep your account safe and to help us detect malicious activity and violations of our terms and conditions of use.
• Preferences, features and services: We use cookies to enable the functionality of our Services, such as helping you to fill out forms on our Services easily and providing you with features, insights and customized content. We also use it to remember information about your activities on our Platforms, and your preferences.
• Performance, Analytics and Research: Cookies help us learn more about how well our services perform in different locations. We use cookies to determine and measure performance and to learn whether you have interacted with our websites, content or emails and provide analytics based on those interactions.

Where We Place Cookies

We set cookies in a number of different locations across our services. These locations may include:

• Our verificio.com and other services or Platforms;
• Our mobile applications;
• E-mails (We may use cookies in some of our emails to enable us to understand how you interact with our emails. It also helps us to improve our future email communications with you. Depending on your email or browser settings, cookies in our emails may be automatically accepted.)

Controlling Cookies

We will always ask for your consent to accept the use of cookies on your device. You can freely decline our cookies when you see our "accept cookies" request or through your browser settings. Cookies are optional unless they are required to prevent fraud or ensure the security of Platforms we control. You may also configure your specific browser or email settings to automatically reject cookies. You may also erase cookies stored on your device through your browser settings or by deleting the folder or file where they are stored on your device.

Declining our cookies may affect your ability to fully utilize of our Platform and services. Without cookies you may not have access to certain features on the site, including access to certain personalized content.

Verificio may revise this Cookies Policy to reflect changes in the law, our data collection and use practices, the features of our site, or advancements in technology. If we make any material changes, we will notify you by email or through a prominent notice on our sites/platforms prior to such change.

Contact Details

If you have questions regarding your data privacy rights or would like to submit a related data privacy right request, kindly contact us via the information below:
Verificio Technologies Inc.
1633 W Innovation Way, Suite 05-135
Lehi, UT 84043, USA
Email: [email protected]