Privacy Policy

Secure Deletion and Data Archiving

When your personal data is no longer needed, has exceeded its retention period, or where no legal requirement mandates continued storage, Oxygen Finance will:

• Permanently delete or destroy the data from its systems and records.
• Securely archive data that must be retained for legal purposes, ensuring privacy protections remain in place.

ARTICLE 7: MANDATORY DATA COLLECTION

At Oxygen X Finance Company Limited, certain types of personal data are mandatory for us to fulfil:

• Contractual obligations – Ensuring seamless financial services
• Legal and regulatory requirements – Compliance with financial laws.
• Security and fraud prevention – Protecting your transactions and identity.

Without providing this mandatory information, we may be unable to offer you certain services or meet legal obligations.

Why We Collect Mandatory Data

• Identity Verification – Required for account opening, loans, and financial services.
• Transaction Processing – Needed for loan repayments and investments.
• Regulatory Compliance – To meet CBN, NDPC, and financial reporting requirements.
• Security & Fraud Prevention – For risk assessment, fraud detection, and compliance with anti-money laundering (AML) laws.

Examples of Mandatory Data

Mandatory data may include, but is not limited to:

• Identification details (e.g., full name, date of birth, BVN, and NIN)
• Contact details (e.g., phone number, email address, and residential address).
• Financial details (e.g., bank account details, tax identification number, and transaction history).
• Employment or business details (e.g., employer information, income details, and source of funds).
• Security data (e.g., biometric verification, CCTV recordings for safety)

Your Responsibility

When required, you must provide accurate and up-to-date mandatory information. Failure to do so may result in:

• Service limitations or denial
• Delays in transaction processing.
• Non-compliance with legal obligations, which may prevent us from serving you.

Contact for Further Clarification

For more details on our data processing practices, please contact our Data Protection Officer (DPO): dpo@oxygenx.africa

For an overview of how we collect, store, and use your data, refer to Article 16 (Data Protection Help Desk).

ARTICLE 8: TRANSFER OF DATA TO A THIRD PARTY

In today’s interconnected financial ecosystem, Oxygen X Finance Company Limited may need to share personal data with trusted third parties to:

• Facilitate loan disbursements and repayments.
• Comply with legal and regulatory requirements.
• Ensure operational efficiency and fraud prevention

This includes various financial intermediaries such as:

• Switching Companies & Payment Processors – To process card transactions.
• Acquirers & Merchants – To facilitate transactions.
• Regulatory Bodies & Law Enforcement – For compliance with financial laws.

Your personal data will only be shared where necessary and will always be protected with adequate security measures to ensure confidentiality and integrity.

Third-Party Services Offered Through Our Platform

To enhance our financial services, Oxygen X Finance Company Limited may partner with third-party service providers who offer valuable services to you.

• These service providers operate independently and may rely on their own lawful basis for processing your personal data.
• The types of data shared may include your contact details, transaction details, or other relevant information required for service delivery.

Examples of third-party services may include:

• Payment Gateways – For seamless online transactions.
• Loan & Credit Scoring Agencies – To assess creditworthiness.
• Cloud Service Providers – To securely store and process financial data.
• Insurance & Investment Partners – If you opt for financial products through us

Your Right to Control Your Data

At Oxygen X Finance Company Limited, we value your right to privacy and ensure you remain in control of your personal data.

If any service requires your consent, you have the right to:

• Decline participation and restrict processing of your personal data.
• Opt-out of promotional communications related to optional services by unsubscribing.

We ensure that all third-party engagements comply with the Nigeria Data Protection Act (NDPA) 2023 and international data protection standards.

For further inquiries about third-party data transfers, please contact our Data Protection Officer (DPO) at: dpo@oxygenx.africa

ARTICLE 9: TECHNICAL INFORMATION AND COOKIES

At Oxygen X Finance Company Limited, we use technical tools and cookies to improve our website performance, security, and user experience. Our data collection practices comply with the Nigeria Data Protection Act (NDPA) 2023, ensuring your privacy and security.

Website Data Collection and Cookies

When you visit our website, we automatically collect certain technical data such as:

• IP Address – To identify geographical access points for security and fraud prevention.
• Device Information – Browser type, operating system, and version
• Browsing Data – Pages visited, time spent on the website, and interaction patterns.
• Referrer Information – The website you visited before landing on our page.

This data helps us:

• Understand user behaviour to enhance website functionality.
• Detect and prevent fraud or security threats.
• Improve website performance and personalize your experience

Cookies and Your Preferences

Cookies are small text files stored on your computer or mobile device when you visit our website. They help:

• Remember your preferences (e.g., login details, language settings).
• Enhance website functionality (e.g., faster page loading, better navigation).
• Personalize content based on your previous interactions.

However, we understand that not all websites use cookies responsibly. You have full control over your cookie preferences and can:

• Disable or delete cookies via your browser settings.
• Opt-out of tracking cookies for personalized marketing

Our Commitment to Privacy

We ensure that all automatic data collection methods on our website:

• Do not compromise your privacy rights.
• Comply with the NDPA 2023 and global data security standard.
• Use robust security protocols to prevent misuse or unauthorized access.

For any concerns regarding technical data collection or cookie usage, please contact our Data Protection Officer (DPO) at: dpo@oxygenx.africa

ARTICLE 10: PERSONAL DATA SECURITY AND INTEGRITY

At Oxygen X Finance Company Limited, we prioritize the security, integrity, and confidentiality of your personal data. We employ advanced security technologies and strict protocols to prevent:

• Cyberattacks.
• Unauthorized access.
• Data loss or corruption.

Our multi-layered security approach aligns with the Nigeria Data Protection Act (NDPA) 2023, GDPR (where applicable), and global best practices.

Data Security and Regulatory Compliance

We ensure robust data protection by:

• Implementing industry-standard encryption and security protocols.
• Conducting regular security assessments to prevent threats.
• Ensuring access control mechanisms to limit unauthorized data usage.

Meeting Legal Requirements

We actively fulfil our legal obligations under the NDPA 2023 and GDPR through:

• Compliance with the Nigeria Data Protection Act 2023 – Ensuring all data processing activities align with NDPA standards.
• Compliance with GDPR – For Nigerian data subjects in the EU, we ensure that our data processing practices comply with GDPR requirements, including data minimization, lawful processing, and data subject rights
• Conducting Data Privacy Assessments – Identifying risks and enhancing data protection strategies.
• Employee Training on Data Protection – Ensuring staff understand data security responsibilities.
• Vendor Data Security Agreements – Requiring strict data security warranties from third-party service providers.

Measures to Ensure Data Integrity & Confidentiality

To protect the reliability and security of your personal data, Oxygen X Finance Company Limited follows these strict security measures:

• Access Controls – Only authorized personnel can access or modify personal data.
• Unauthorized Access Prevention – Data is protected from unauthorized viewing, processing, or sharing.
• Employee Data Privacy Responsibilities – Employees are strictly prohibited from using personal data for:
  • Private or commercial purposes.
  • Disclosure to unauthorized individuals.
• Ongoing Compliance Training – Employees are informed at the start of their employment about data privacy obligations, which remain in effect even after employment ends.

Data Breach Notification

In the event of a data breach that poses a high risk to your rights and freedoms, Oxygen X Finance Company Limited is legally required to:

• Report the breach to the Nigerian Data Protection Commission (NDPC) within 72 hours of becoming aware of the data breach.
• Take immediate action to investigate, contain, and rectify the breach.
• Notify affected data subjects if their rights are significantly impacted.

For more details on data breach requirements, refer to Sections 28, 39, and 40 of the NDPA 2023.

For questions or concerns about data security, contact our Data Protection Officer (DPO): dpo@oxygenx.africa

ARTICLE 11: JOB APPLICANTS

At Oxygen X Finance Company Limited, we collect and process personal data from job applicants to facilitate recruitment and hiring processes. This ensures that all applications are properly assessed while maintaining data protection compliance under the Nigeria Data Protection Act (NDPA) 2023.

Application Information

When you apply for a position at Oxygen X Finance Company Limited, you will be required to provide:

• Personal details – Name, contact details, date of birth.
• Educational background & work history – Academic qualifications, past employment records.
• Referees, next of kin, and guarantor details – Information required for background checks.
• Other relevant information – Certifications, professional memberships, and additional supporting documents.

Providing this information is essential for us to process your application.

Data Usage for Recruitment

We collect your personal data for legitimate recruitment purposes, including:

• Candidate Assessment – Evaluating your skills and experience against job requirements.
• Interview & Feedback Tracking – Managing interactions throughout the hiring process
• Recruitment Process Optimization – Improving our recruitment models through data analysis.

We may also use your anonymized data to:

• Identify effective recruitment sources.
• Enhance training and onboarding programs.
• Refine our interview models for better hiring decisions.

Optional Communications and Data Sharing

With your explicit consent, we may:

• Send you relevant job opportunities, recruitment updates, and career events hosted by Oxygen Finance.

Share your application data with

• Affiliated companies (for group-wide recruitment opportunities).
• Third-party service providers such as:
• Recruitment agencies.
• Background check providers.
• IT system providers (for digital recruitment platforms).

Your data may be transferred outside Nigeria, but we will ensure appropriate safeguards are in place, as required under the NDPA 2023.

Data Retention

We retain your application data for a maximum period of six (6) months, unless

• Your application is successful – Your data will be retained as part of your employment records.
• You request early deletion – Subject to legal and regulatory obligations.

Data Subject Rights and Contact

If you wish to:

• Access, update, or correct your recruitment data.
• Withdraw consent for data processing.
• Request deletion of your personal information

You may contact our Data Protection Officer (DPO) at: dpo@oxygenx.africa

For further details on your rights under NDPA 2023, refer to Article 5 (Data Subject Rights).

ARTICLE 12: MAINTAINING ACCURATE INFORMATION

At Oxygen X Finance Company Limited, we are committed to ensuring that your personal data remains accurate, complete, and up to date. Maintaining correct records is essential for providing efficient financial services and complying with regulatory requirements.

Your Responsibility to Update Information

To help us maintain data accuracy, please notify us promptly if any of the following personal details change:

• Contact information – Phone number, email address, or residential address.
• Employment details – Job position, employer, or income status.
• Financial details – Bank account or tax identification number (TIN).
• Identification documents – Updates to your BVN, NIN, etc.

Providing up-to-date information helps us:

• Deliver personalized financial services without disruptions
• Ensure compliance with regulatory and security requirements.
• Prevent issues related to identity verification or fraud prevention.

How to Update Your Information

You can update your personal data by:

• Contacting our customer support team via email or phone.
• Sending an update request to our Data Protection Officer (DPO). Email: dpo@oxygenx.africa

Your Right to Rectification

Under the Nigeria Data Protection Act (NDPA) 2023, you have the right to request corrections if your personal data is inaccurate or incomplete. To exercise your right to rectification, contact our Data Protection Officer (DPO) at: Email: dpo@oxygenx.africa

For further details on data subject rights, refer to Article 5 (Your Data Subject Rights).

ARTICLE 13: CHILDREN'S PRIVACY

At Oxygen X Finance Company Limited, we are committed to protecting children's privacy and personal data. We recognize the importance of safeguarding minors' information; therefore, our platforms are not designed for or directed at individuals under the age of 18. In line with our policy, we do not knowingly collect or retain any personal information from children under 18, and our services are strictly intended for adults.

ARTICLE 14: CAVEAT ON WEBSITE LINKS

At Oxygen X Finance Company Limited, we may provide links to third-party websites for your convenience and informational purposes. However, it is important to understand that:

• These links do not constitute an endorsement of the content, products, or services offered by third-party sites
• We do not control and are not responsible for how third-party websites collect, process, or use your personal data
• Our privacy policy applies exclusively to our website and does not cover external websites.

Your Responsibility as a User

Before interacting with any third-party website, we strongly recommend that you:

• Review their privacy policies to understand how they handle your personal data.
• Exercise caution when sharing personal or financial information on external platforms.
• Be aware that third-party sites may have different data security measures than ours.

No Liability for Third-Party Practices

Oxygen X Finance Company Limited will not be liable for:

• Data breaches, unauthorized use, or privacy violations that occur on external websites.
• Misinformation or deceptive content found on third-party links.
• Financial or reputational losses incurred from interactions with linked sites.

Protecting Your Data Online

To enhance your online security, we recommend that you:

• Use strong passwords and enable two-factor authentication where possible.
• Avoid entering sensitive information on websites that do not have HTTPS encryption.
• Regularly update your passwords and monitor financial transactions for any unauthorized activity.

For any concerns regarding website security and privacy, please contact our Data Protection Officer (DPO): dpo@oxygenx.africa

ARTICLE 15: TRANSFER TO THIRD PARTIES AND COUNTRIES (CROSSBORDER TRANSFERS)

At Oxygen X Finance Company Limited, we may engage third-party service providers to support our financial operations and technology infrastructure. Some of these providers may be located outside Nigeria.

To ensure your personal data remains secure, we implement strict data transfer safeguards in compliance with the Nigeria Data Protection Act (NDPA) 2023, GDPR (where applicable), and other relevant data protection laws.

Conditions for Transferring Data to Third Parties

Before transferring your personal data to any third party, we ensure:

• A Data Processing Agreement (DPA) is in place to enforce data protection measures.
• Your explicit consent is obtained if the purpose of processing was not initially stated at data collection.
• The third party meets international data protection standards, preventing unauthorized access, use, disclosure, loss, or destruction.

Cross-Border Data Transfers

When transferring data outside Nigeria, Oxygen X Finance Company Limited ensures that:

• The recipient country has adequate data protection laws – We transfer data only to countries with established data protection regulations (or where a legal framework exists for data security).
• A legally binding contract is in place – If the recipient country lacks an NDPC adequacy decision, we enter an approved contract containing strong data protection clauses.
• Binding Corporate Rules (BCRs) apply – If a third party operates under BCRs, we ensure compliance with the NDPA and GDPR requirements for global data transfers.
• GDPR Compliance for Nigerian Data Subjects in the EU: For Nigerian data subjects residing in the EU, we ensure that cross-border data transfers comply with Chapter V of the GDPR, which governs international data transfers.

Examples of Third-Party Services Involving Data Transfers

Your personal data may be securely transferred to third-party providers for:

• Internet Connectivity – Ensuring seamless access to financial services.
• Cloud Storage – Secure data storage and management.
• Data Analytics – Enhancing service efficiency and fraud detection
• Data Security Services – Protecting against cyber threats and data breaches.
• Software Development & IT Support – Maintaining digital banking and financial platforms.

Compliance with the NDPA 2023

We strictly follow Part VIII of the Nigeria Data Protection Act (NDPA) 2023, ensuring:

• Legal oversight of all data transfers.
• Regulatory approval for high-risk cross-border transactions.
• Secure encryption protocols for transmitted data.

For more details on how we handle international data transfers, or to request information about a specific third-party transfer, please contact our Data Protection Officer (DPO): dpo@oxygenx.africa

ARTICLE 16: DATA PROTECTION HELP DESK

At Oxygen X Finance Company Limited, we have established a dedicated Data Protection Help Desk to promptly address inquiries, complaints, and requests regarding your personal data.

Our Data Protection Officer (DPO) is responsible for ensuring data privacy compliance and protecting your rights under the Nigeria Data Protection Act (NDPA) 2023.

How to Contact the Data Protection Help Desk

Email: dpo@oxygenx.africa

Office Hours: Monday – Friday, [08:00 am – 05:00 pm]

Location: 4th Floor, Plot 1665, Oyin Jolayemi Street, Victoria Island, Lagos, Nigeria.

Services Offered by Our Data Protection Help Desk

Our DPO and support team are responsible for:

• Compliance with Data Protection Regulations & Breach Handling – Ensuring full compliance with NDPA 2023 and addressing any data breaches.
• Data Protection & Privacy Advisory Services – Providing guidance on how we handle your personal data and explaining your privacy rights.
• Data Protection Capacity Building – Training employees, vendors, and partners on data security best practices.
• Data Protection Regulations & Contract Advisory – Assisting with contract drafting and compliance assessments for third-party data processing.
• Privacy Breach Remediation & Support – Responding to data breaches, identifying risks, and mitigating any privacy violations.
• Information Privacy Audits – Regularly auditing our internal data processes to ensure compliance with global best practices.
• Data Privacy Breach Impact Assessment – Assessing risks associated with privacy breaches and implementing corrective measures.
• Data Protection & Due Diligence Investigations – Conducting background checks and ensuring legal compliance in all data-related activities.

Your Rights & Assistance

If you need assistance or clarification regarding your data privacy rights, you can:

• Request access to your personal data (See Article 5: Your Data Subject Rights).
• Report concerns about a data breach or misuse of your personal data.
• Request corrections, deletions, or updates to your personal data.

For all inquiries or complaints, please contact our Data Protection Officer (DPO) at: dpo@oxygenx.africa

ARTICLE 17: DATA DELETION

At Oxygen X Finance Company Limited, we respect your right to request the deletion of your personal data. We follow a secure and transparent data deletion process while complying with legal and regulatory requirements under the Nigeria Data Protection Act (NDPA) 2023.

When Can You Request Data Deletion?

You can request the deletion of your personal data if:

• It exceeds its designated retention period.
• It is no longer necessary for business or legal purposes.
• You withdraw consent where processing was based on your consent.
• You exercise your right to be forgotten, as outlined in Article 5.

We will take all reasonable steps to delete your data upon request, except where legal or regulatory obligations require retention.

Secure Data Deletion Process

We have established procedures to ensure complete and irreversible destruction of personal data while maintaining data security.

• Identification – Regularly reviewing data storage systems to identify data that has reached its retention limit or is no longer needed.
• Scheduling – Placing identified data on a scheduled deletion list, ensuring compliance with legal requirements and risk assessments.
• Overwriting – Applying data sanitization techniques, replacing original data with randomized characters to make it unrecoverable.
• Verification – Confirming that deleted data cannot be retrieved or restored.
• Audit Trail – Maintaining a detailed log of all data deletion activities, including:
  • Type of data deleted.
  • Date of deletion.
  • Responsible personnel handling the deletion

Exceptions: When Data Cannot Be Deleted

In certain circumstances, Oxygen X Finance Company Limited may be unable to delete your data if:

• Legal or Regulatory Obligations Apply – We are required by law to retain certain data for a specified period.
• Data is Needed for Legal Disputes – If the data is relevant to an ongoing dispute, enforcement of terms, or legal claim
• Data Has Been Anonymized – If your data has been permanently anonymized, making it no longer personally identifiable

In such cases, we will limit processing and ensure your data is not used for unintended purposes.

Requesting Data Deletion

To request deletion of your personal data, submit a Data Subject Access Request (DSAR) by:

• Filling out the DSAR form (available upon request).
• Emailing our Data Protection Officer (DPO): dpo@oxygenx.africa

We will respond to your request within a commercially reasonable timeframe, typically within 30 days, unless a legal obligation prevents immediate deletion. For further details on your data rights, see Article 5 (Your Data Subject Rights).

ARTICLE 18: DATA SUBJECT ACCESS REQUEST (DSAR)

Under the Nigeria Data Protection Act (NDPA) 2023, you have the right to request access to your personal data held by Oxygen X Finance Company Limited. A Data Subject Access Request (DSAR) allows you to obtain information about how we process your personal data and to verify its accuracy and lawfulness.

What You Can Request in a DSAR

A Data Subject Access Request (DSAR) allows you to access personal data such as:

• Basic Information – Your name, contact details, and demographic information.
• Account Information – Your financial transactions, service history, and usage data.
• Marketing Preferences – Data about your communication and marketing preferences.
• Third-Party Sharing Details – Information on whether your data has been shared with third parties.

How to Submit a DSAR

You can request access to your personal data in two ways:

• Email Submission – Send an email to our Data Protection Officer (DPO) clearly specifying: The type of data you want access to. Any specific concerns regarding data processing. Email: dpo@oxygenx.africa
• DSAR Form Submission – Request, complete, and submit the DSAR form to our DPO via email.

Verification Process

To protect your privacy and ensure we provide data only to the correct person; we may request additional information for identity verification.

• Verification Methods

  We may ask you to provide:

  • A valid identification document (e.g., driver’s license, passport, or National Identity Number (NIN) slip).
  • Additional security checks to match details associated with your account.
• Response Timeline

  We strive to respond within 30 days of confirming your identity.

  Our response will include:

  • Confirmation of your request
  • The requested personal data in a clear, concise, and electronic format
  • Explanation of any withheld data, if applicable.

Reasons for Denial

In rare cases, we may be unable to fulfil your request due to:

• Legal restrictions – If your data is subject to ongoing legal or regulatory requirements.
• Excessive or repetitive requests – If requests are unreasonably frequent.
• Security concerns – If disclosure may compromise someone else’s privacy rights.

If we deny a request, we will provide a clear explanation of the reason for refusal.

Fees for DSARs

Submitting a DSAR is free of charge. However, a reasonable fee may apply if:

The request is manifestly excessive, repetitive, or unreasonable.

Multiple requests for the same information are made within a short period

Contact for DSAR Requests

To submit a Data Subject Access Request (DSAR) or for further inquiries, contact our Data Protection Officer (DPO): dpo@oxygenx.africa

For more details on your privacy rights, refer to Article 5 (Your Data Subject Rights)

ARTICLE 19: REMEDIATION

At Oxygen X Finance Company Limited, we are committed to promptly addressing and resolving any concerns regarding your data privacy. Our goal is to ensure that your rights under the Nigeria Data Protection Act (NDPA) 2023 are protected at all times.

Reporting a Data Privacy Concern

If you have any complaints, inquiries, or concerns about how your personal data is collected, used, or stored, please report them to our Data Protection Officer (DPO).

You can file a complaint via:

Email: Send a detailed description of your concern. DSAR Request: Use our Data Subject Access Request (DSAR) Form.

Resolution Timeline

• Upon receiving your complaint, we wil
• Acknowledge receipt within 48 hours.
• Investigate the concern and provide a resolution within 7 business days
• Notify you promptly if the issue is complex and requires additional time
• If further investigation is needed, we will take all necessary steps to protect your privacy rights and keep you informed throughout the process.

Escalation of Complaints

If you are not satisfied with our response, you may:

• Request an internal review of the decision
• Escalate your complaint to the Nigeria Data Protection Commission (NDPC), the regulatory authority overseeing data protection compliance in Nigeria via the NDPC Contact Details: info@ndpc.gov.ng

Our Commitment to You

We will always strive to resolve your privacy concerns promptly while ensuring:

• Transparency in our remediation process.
• Fairness in investigating and addressing complaints.
• Strict compliance with the NDPA 2023 and global data protection best practices.

For further inquiries, please contact our Data Protection Officer (DPO): dpo@oxygenx.africa

ARTICLE 20: ALTERATION OF PRIVACY POLICY

At Oxygen X Finance Company Limited, we reserve the right to update, amend, or modify this Privacy Policy periodically to reflect:

• Enhanced data privacy rights for our users.
• Evolving regulatory and compliance requirements.
• Public interest considerations and industry best practices.
• New directives from the Federal Government of Nigeria.

Compliance with Legal Safeguards

All revisions to this Privacy Policy will be made in accordance with

• The Nigeria Data Protection Act (NDPA) 2023.
• The 1999 Constitution of the Federal Republic of Nigeria (as amended).
• Regulations and Guidance Notices from the Nigeria Data Protection Commission (NDPC).

We will ensure that any changes:

• Do not weaken user privacy rights
• Maintain transparency and fairness in data processing.
• Reflect our commitment to responsible data handling.

Your continued use of our services after an update constitutes acceptance of the revised Privacy Policy.

Your Right to Review Updates

You have the right to review and understand any changes to this Privacy Policy. If you disagree with any modifications, you may:

• Contact our Data Protection Officer (DPO) for clarification
• Exercise your rights under the NDPA, including data deletion or processing restrictions.

For further inquiries, please contact our DPO: dpo@oxygenx.africa

ARTICLE 21: DEFINITIONS AND KEY TERMS

To ensure clarity and consistency throughout this Privacy Policy, the following key terms are defined:

General Terms

• Cookie: A small piece of data stored by your web browser when you visit a website. It helps websites remember your preferences, login information, and browsing activity.
• Consent: The freely given, specific, informed, and unambiguous indication of a Data Subject’s wishes, expressed through a clear affirmative action, signifying agreement to the processing of personal data.
• Oxygen X Finance Company Limited ("we", "our", "OXYGEN FINANCE", "The Company") – A licensed financial institution located at: 4th Floor, Plot 1665, Oyin Jolayemi Street, Victoria Island, Lagos, Nigeria. We are your Data Controller, responsible for collecting, processing, and securing your personal data under this Privacy Policy
• Country: Nigeria, where Oxygen X Finance and its founders/owners operate. v. Customer: Any individual, organization, or company that uses our services to manage their financial transactions, investments, or business relationships.
• Data Protection Officer (DPO): The appointed officer responsible for:
  • Advising Oxygen X Finance employees on their data protection responsibilities.
  • Monitoring compliance with NDPA 2023 and global data protection laws
  • Handling data protection inquiries, complaints, and access requests.
• Device: Any internet-connected gadget (e.g., smartphone, tablet, computer) used to access our website or digital services.
• Internet Protocol (IP) Address: A unique identifier assigned to every device connected to the internet. It can sometimes reveal the general geographic location of a device.
• Closed-Circuit Television (CCTV): Oxygen Finance uses CCTV cameras at its physical locations to enhance security and deter fraud.
• Personnel: Employees, contractors, or third-party service providers authorized to perform tasks on behalf of Oxygen Finance.

Data & Privacy-Related Terms

• Data: Any characters, symbols, numbers, or digital information that can be stored, processed, or transmitted electronically.
• Personal Data: Any information relating to an identified or identifiable natural person (Data Subject). This includes:
  • Name, address, phone number, email address.
  • Bank account details, financial history, and biometric data
  • Online identifiers (IP address, MAC address, IMEI number, IMSI number, SIM number).
  • Sensitive data (medical records, national identity number, tax information).
• Service: The financial products and services provided by Oxygen X Finance Company Limited, as outlined in our terms and conditions.
• Third-Party Service: Any external entity that provides:
  • Marketing and advertising services.
  • Fraud prevention and data analytics.
  • Payment processing and financial technology solutions.
• Data Subject ("You"): An individual or entity registered with Oxygen X Finance Company Limited to use our financial services.

Data & Privacy-Related Terms

For more details on your privacy rights, refer to:

• Article 5: Your Data Subject Rights.
• Article 18: Data Subject Access Requests (DSARs).

For inquiries, contact our Data Protection Officer (DPO): dpo@oxygenx.africa

ARTICLE 22: CONTACT

If you have any questions, comments, or requests regarding your privacy rights, data security, or this Privacy Policy, please contact us using the details below.

Data Controller

Oxygen X Finance Company Limited 4th Floor, Plot 1665, Oyin Jolayemi Street, Victoria Island, Lagos, Nigeria.

General Inquiries: info@oxygenx.africa

We are responsible for determining the purposes and methods of personal data processing in compliance with the Nigeria Data Protection Act (NDPA) 2023.

Contacting the Data Protection Officer (DPO)

For privacy-related inquiries, data access requests, or complaints, please reach out to our Data Protection Officer (DPO):

DPO Contact:

Email: dpo@oxygenx.africa

Phone: 0812-855-2432

Our DPO is available to assist you with:

• Data protection regulations compliance.
• Data access, corrections, and deletion requests.
• Privacy complaints and security breach reporting.
• General inquiries about how we handle your data.

Policy Review & Updates

At Oxygen X Finance Company Limited, we are committed to maintaining a robust and up-to-date Data Privacy Policy that reflects current legal requirements, industry best practices, and our business operations.

Frequency of policy review

• Changes in applicable laws and regulations, including the Nigeria Data Protection Act (NDPA) 2023, General Data Protection Regulation (GDPR), and other relevant data protection laws.
• Changes in our business operations, such as expansion into new jurisdictions or the introduction of new products and services.
• Feedback from stakeholders, including customers, employees, and regulatory authorities.

This Privacy Policy will be reviewed annually or as needed in response to:

Process for Policy Updates

When updates to this Privacy Policy are required, the following process will be followed:

• Assessment: The Data Protection Officer (DPO) will assess the need for updates based on changes in laws, regulations, or business operations.
• Drafting: The DPO, in collaboration with relevant departments (e.g., Legal, Compliance, and IT), will draft the updated policy.
• Approval: The updated policy will be reviewed and approved by the Executive Management Team and the Board of Directors.
• Communication: Once approved, the updated policy will be communicated to all stakeholders, including employees, customers, and third-party partners.
• Implementation: The updated policy will be implemented across all business operations, and employees will receive training on any significant changes.

Notification of Changes

Whenever this Privacy Policy is updated, we will:

• Publish the updated version on our official website.
• Notify users through email or platform notifications, where applicable.
• Provide a summary of key changes and their impact on your data.

Your continued use of our services after an update constitutes acceptance of the revised Privacy Policy