Our Privacy Policy explains our user’s privacy rights regarding:

• What information we collect.
• Why we collect such information.
• The use of such information.
• The storage, sharing and protection of such information.

For the purpose of this Policy:

“Personal Data/Information” means any information relating to you, including your name, phone number, date of birth, profile photo, school and course information, social media accounts, location data, online identifier address, photo, email address, pins, passwords, bank details, posts on our Platforms, nationality, religion, ethnicity, and other unique identifiers such as but not limited to MAC address, IP address, Bank Verification Number, and others. Or any other information which may be classified as personal data/information.

“Process/Processing” means any operation or set of operations which is performed on your Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Kura App means the mobile application, and website owned, trademarked, and operated by Kura under the parent company VPF Ventures.

“Services” means any form of services that Kura may offer you via the Kura app and website and which you may from time to time require.

“Kura”, “we” or “us” means Kura.

“You” or “User” means the person that intends to access the Kura app or website, subscribe to, and receive the Services inherent.

“Privacy Policy” means this Kura privacy policy in its entirety that establishes the basis on which any personal data we collect from you, or that you provide to us, will be used by us.

Consent

We kindly request that you carefully read through this Policy. If you proceed to use any of our platforms and services, it will be deemed that you have provided your express consent to the terms of this Policy.

Collection of Personal Data

In the course of your engagement with us or with third parties through our platforms, we may collect your Personal Data in the following ways:

Data you give us: We may collect and process your information when you open an account on our platform, and/or update your account on our platform. We may collect information such as your contact information, which includes your name, phone number, location, email and others. We may collect information such as your date of birth, school degree and course information, occupation, and social media account handles. We may also collect Information from data you provide to us through documents like Identification cards or through any other means by which you wilfully provide information to us.

Automatic Information collection: We may automatically collect Information upon your engagement with us or our Platforms through your computer, mobile phones, and other access devices. The information sent includes, User-ID known as account ID generated by us, to users who sign up on the platform, your geo-location information, geotagging, IP address, traffic to and from our platform.

Social Media: We also receive Information through your engagements with us on social media sites (e.g., Facebook, Twitter, Instagram, etc). This includes but is not limited to your replies to our posts, your comments, enquiries, messages to us, etc. We may also collect information from your public profile and updates on social media.

We also collect:

• In app messaging content such as sender, recipient, and contents of the message.
• Your email content sent to us for enquiries and complaints, Including subject line, sender’s email address, and contents of the email.
• Your photos or videos when you make posts on our platform (user logs and activities).
• Any other data collected to improve the app performance e.g., rate, statistics, surveys, and study data.

Accessing your Personal Information

When accessing our Platforms, we may collect information about you and your interactions with the Services to which we undertake to keep secure and confidential.

We may offer you the ability to connect with our Platforms using a mobile device, either through a mobile application (App), computer, mobile optimised website, or by any other means. The provisions of this Privacy Policy apply to all such mobile access and use of mobile devices.

When you download or use our mobile applications, or access one of our mobile optimised sites, we may 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 search results, nearby listings on Kura app and other personalised content. Most mobile devices allow you to control or disable location services in the device's setting's menu. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or the manufacturer of your particular device.

Using Your Personal Information

In the course of your engagements with us or through our Platforms, we collect personal information for various legal reasons, largely to enable us to personalise your experience and to provide a more efficient service to you.

Some of the reasons we collect Information are to:

• Provide services and customer support.
• To monitor your usage of our website, process your access to our services, Platform, or functions from time to time.
• To personalise your experience.
• To obtain a means by which we may contact you and communicate with you about your account or send you information or request feedback about features on our website and applications or changes to our policies.
• Send you periodic emails and updates pertaining to our products and services.
• Verify customers’ identity, including during account creation and password reset processes.
• Manage risks, or to detect, prevent, and/or remediate fraud, violation of policies and applicable user agreements or other potentially prohibited or illegal activities.
• Execute our contractual obligations to you.
• Improve our services and functionality by customising user experience.
• Conduct background checks, compare information for accuracy and verify “same with third parties.
• Comply with legal, contractual, and regulatory obligations.
• Execute your specific requests or use same for a specific purpose as you may instruct.
• Investigate and respond to your complaints or enquiries.

We do not have any control over the privacy practices of any external websites linked to our website and will not be liable for the content of such websites or use of information you allowed us to provide to them. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

If we intend to use any Personal Information in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the personal information is required and obtain your consent.

Storage and protection of your Data

We protect your personal Information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, unauthorised disclosure, and alteration. Some of our safeguards include firewall protection, encryption of data, authorization keys for authorised access, other servers and user data encryption, and strong passwords. Access to our various platforms is restricted to authorised users only. Your Information is also stored on our secure servers as well as cloud infrastructure. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your personal information for the length of time needed to fulfil the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law. In a case where you have deleted your account, we will retain your information for at least 3 months. To dispose of personal data, we may anonymize it, delete it or take other appropriate steps.

We will take all necessary measures to ensure that your personal data is safe, however, you are also required to ensure that passwords, usernames, and all other information or hints that may enable third party access to your accounts on our platforms are secure. We therefore strongly advise you to keep such information secure and confidential. If you use a third party’s device (laptops, phones, public internet, etc.) to access your account, kindly ensure that you always log out when finished. Kindly note however that certain devices are programmed to save passwords or usernames, as such, we advise that you use third party devices with extreme caution. If you believe that an unauthorised person has accessed your information, please reach us at immediately at [email protected].

Processing your Information

In order to execute our obligations to you, we may be required to process your Information, such as your name, contact details, or other information needed. 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 service providers; Regulatory or judicial authorities; or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Kura. Please note that the aforementioned parties may be within or outside Nigeria.

We may also process your Information without notice when we believe, in our sole discretion, that the disclosure of your Information 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 Information is properly and professionally managed and notify the receiving party of the confidential nature of your Information, particularly the need to maintain the confidentiality of same and prevent unlawful or unauthorised usage.

Your Rights

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

• Right to access your personal information being held by us. Requests for such information may be sent to [email protected].
• 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, unlawful, and likely to cause substantial cost to us or disruption of service standards. 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 information, 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 information, provided that such withdrawal shall not invalidate any processing hitherto done based on the consent previously given by you.
• Right to request that your personal data be deleted. We may however continue to retain the information where required under law, contract, regulatory authorities, or court of law.

Disclosures

We may share your personal information with:

1. Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Kura or one of its agents; when we need to do so to comply with law; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement.
2. Other unaffiliated third parties, for the following purposes.
3. Fraud Prevention and Risk Management: to help prevent fraud or assess and manage risk.
4. Customer Service: for customer service purposes, including to help service your accounts or resolve disputes.
5. Service Providers: to enable service providers under contract with us to support our business operations, such as fraud prevention, marketing, customer service and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.

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 in order to improve, enhance, and further develop the software. We may utilise your personal information to internally evaluate our software.

Period of Storage

We retain your information for as long as necessary for the purpose(s) for which it was collected. The period of data storage is also subject to legal, regulatory, contractual, administrative, and operational requirements.

Exceptions

Please note that this Policy does not apply to Information that is already in the public domain through no fault of ours.

Violation

If you violate the letter or spirit of this policy, or otherwise create risk or possible legal exposure for us or attempt to violate the privacy rights of Kura and/or its other users, we reserve the right to restrict your access to our Platforms. We will notify you in the event that we are constrained to take such a decision.

Dispute resolution

We are dedicated to ensuring that you are satisfied with our management of your Information. However, in the unlikely event that you have a complaint, please contact us via [email protected], stating your name and details of your complaint. Upon receipt of your complaint, we will endeavour to contact you to amicably resolve such complaint within the shortest possible time. The foregoing notwithstanding, all disputes arising from this policy shall first be resolved by negotiation. However, if parties fail to resolve the disputes amicably by such mutual consultations, parties shall further attempt to resolve the dispute by Arbitration in accordance with the Arbitration and Conciliation Act Cap A18 Laws of the Federation of Nigeria, 2004 for the time being in force, or any statutory re-enactment or modification thereof.