Terms and Conditions that Apply to Okra's End-Users
Effective Date: January, 2020.
Okra seeks to provide innovators/businesses/government or its agencies with one-stop access to the financial systems/data. Okra’s proprietary software provides an easy way for End-User (“you”) to connect your bank account(s) and other financial accounts to fintech or any other financial service solutions that can help you do things like save for retirement, manage your spending, streamline credit applications, transfer money or provide easier access to KYC information required in order to be connected to the afore mentioned services etc.
These software applications/solutions are built and provided by our business customers (“Developers”), and powered by Okra. We have collected, translated and standardised high-quality, usable financial account data that enables our developers to focus on building experiences that benefit you.
Okra shall only access/collect/display/process your financial information from your Financial Account(s) within the Okra dashboard and transmits such information to an Application Provider (“Developer”) that you have expressly authorised to access your information through/using Okra service. Please refer to the End-User Agreement for more information.
Information We Process
Okra processes your information when you connect you financial accounts with a developer application or otherwise connect your financial accounts through Okra. Also, Okra collects login information required by the provider of your account, such as your username and password, answers to security questions, or a security token. In some cases, Okra also collects your phone number to help verify your identity before connecting your financial accounts. When providing this information, you give the developer and Okra the authority to act on your behalf to access and transmit your information from the relevant financial institution and other financial service providers.
The information Okra receives from the financial institutions and other financial service providers that maintain your financial accounts varies depending on the specific Okra tools developers use to run their applications, as well as the information made available by those institutions and providers. But, in general, we collect the following types of information from your financial institutions and other financial service providers:
- Account balance, including current and available balance;
- Credit accounts, including statement due dates and balances owed, payment amounts and dates, transaction history, and interest rate;
- Information about loan accounts, including due dates, moratorium periods, balances, payment amounts and dates, interest rate, loan type, payment plan, and terms;
- Information about investment accounts, including identifying details about assets, quantity, and cost basis;
- Information about the account owner(s), including name, email address, phone number, and address information; and
- Information about account transactions, including amount, date, type, quantity, price, involved securities, and a description of the transaction.
- The data collected from your financial accounts includes information from all your sub-accounts accessible through a single set of account credentials
How We Get Your Information
Okra collects information directly from your financial service provider and from other sources through the use of its API (Application Programming Interface) when an end-user connects its financial account through Okra or to other publicly available sources.
Our Legal Basis for Processing
Okra’s legal basis for processing your Information largely depends on the nature of the information and the context in which we collected or processed it. Okra will normally only collect and process your Information where:
- You have given your consent to do so.
- We need to fulfill our responsibilities and obligations in any contract or agreement with you (for example, to comply with our end-user services agreements);
- To comply with our legal obligations under applicable law;
- The processing is necessary for our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, to safeguard our services);
- To communicate with you, or to provide or update our services;
- To provide customer support to you or to our developers, including to help respond to your inquiries related to our service or our developers’ applications;
- To investigate any misuse of Okra’s service or our developers’ applications, including violations of our Developer Policy, criminal activity, or other unauthorised access to Okra services; and
- For all other purposes with your express or implied consent as lawfully permitted.
Please be informed that to the extent that we rely on your consent to collect and process your Information, you have the right to withdraw your consent at any time as instructed in this Policy or our End-User Agreement.
Where Okra intends to deploy your information for other purposes other than those stated in this statement, okra shall update this statement to reflect same and request your consent before proceeding with such use of your information.
Okra may help our Developer/Application provider that you have authorised, make automated operations on your financial accounts that you have connected through Okra.
Data Security and Safety
Okra shall deploy steps aimed at protecting your information in our possession. These steps include maintaining information safeguards such as data encryption, randomisation, anonymisation, firewalls, logical and physical access controls, and continuous monitoring. These controls shall be regularly evaluated for effectiveness against industry standards internally and by independent security auditors.
When Third-Parties may access your Information
Okra does not sell or rent your information to marketers or other third parties. We shall only share end-user information as follows:
With your consent;
With other Okra service providers, partners, or contractors in connection with the services they perform for Okra or our developers;
If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena);
In connection with a change in ownership or control of all or a part of our business (such as a merger, acquisition, reorganization, or bankruptcy);
Between and among Okra and our current and future assignees, affiliates, subsidiaries, and other companies under common control or ownership; or
As we believe reasonably appropriate to protect the rights, privacy, safety, or property of end-users, our developers, our partners, or Okra.
Okra may collect, use, and share information in an aggregated or anonymised manner for any purpose permitted under applicable law. This includes creating or using aggregated or anonymised data based on the collected information to develop new services and to facilitate research.
Okra may also retain your information for as long as necessary to fulfill the purposes stated in this Statement, our End-User Agreement and for other lawful purpose so closely connected, unless a longer retention period is required or permitted under applicable law. Okra assures that in accordance with applicable laws, end-users information shall only be processed, stored, and distributed in accordance with provisions of this statement and our End-User Agreement.
Other Data Considerations
International Transfer of your Information
The information we collect about you may be transferred, used, or stored in any country where we have operations or where we engage service providers. That means that your information may be transferred to a different country than where it was collected and which may not provide equivalent levels of data protection as stipulated by your country.
The level of data protection in such countries may be less than that offered in your country. Where this is the case, Okra will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws, guidelines, and standards in your country at the least.
Where Okra uses a third-party service provider to process personal data outside your country in the course of providing services, our written agreement with them will include appropriate measures, usually standard contractual clauses on data sharing under prevailing local and international standards.
Where a Developer/Application provider authorised by you collects any such information about you through Okra and then transfers your information to another country; such Developer/Application provider shall be responsible for complying with the requirements of relevant data privacy laws.
As stipulated by local and international data protection standards, you have certain right with respect to the use and processing of your personal information.
You are entitled to request details of the information we hold about you and how we process it. You also have a right under applicable data protection law to have it rectified or erased/deleted, to restrict our processing of that information, to stop transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organisation. You also have the right to lodge a complaint concerning Okra’s processing of your personal information with a regulatory authority. For any of such request in pursuance of such rights, please email us here at firstname.lastname@example.org
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. Please email us at email@example.com
Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, particularly in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.
You may wish to inform us of updates to any information you may have with us, you may also request that Okra provides information collected from you in a structured, commonly used and machine-readable format, where technically feasible. For any such requests or updates with respect to your information, please email us at firstname.lastname@example.org
Okra, in accordance with its obligation under relevant laws shall notify you of our compliance with all such requests that you may have made in accordance with your legal rights.
Changes to this Statement
Okra may change this Privacy Statement periodically. However, if we make changes, we will notify you by updating the effective date at the top of this Statement. Okra may also provide notice of any changes through other means, such as placing a notice on our homepage at https://okra.ng. Okra will also notify our developers of any material changes in accordance with our developer agreements, as they are generally best positioned to notify the end-users about such changes to this Policy, as appropriate.