Privacy Policy

Effective date: September 18, 2019

Doubble is an automated investment platform (“the Platform”) developed by Sterling Bank Plc  ("us", "we", "our" or “the Bank”). The Bank operates the https://www.doubble.ng/ website and the doubble mobile application (the "Service").

Introduction

This page informs you of our policies regarding the collection, use, and disclosure of personal information when you use our Service and the choices you have associated with that data. We are committed to treating and using your personal information responsibly. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Information. 

By using the Service, you agree to the collection and use of personal information in accordance with this policy. 

Data Collection and Use

We collect different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Information submitted through our app or website

Personal data, or personal information means any information provided by you with which you can be identified. When you sign up to the app and provide details such as your name, ID (passport data page, national ID), biometric data/BVN, your photograph, house address, email address, phone number, voice recordings (when you call our helpline) and other details which would enhance your Service experience:

Details about your banking activities and transactions with us

This includes information on any bank accounts you use, debit card numbers, financial history, information you provide to deliver payment initiation services and account information services regarding accounts you hold with other providers.


Information on how you use your device/ Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Usage Data").

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit and the time spent on those pages amongst other diagnostic data.. When you access the Service by or through a mobile device or use the mobile app, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. You can also refuse permissions to read your phone data by the mobile application. However, if you do not accept cookies on your browser or allow permissions on your mobile device, our online service experience to you may be degraded and you may not be able to use some portions of our Service.

Examples of Cookies we use:

Session Cookies. We use Session Cookies to operate our Service. Session cookies will expire at the end of your browser session and allow us to link your actions during that particular browser session

Preference Cookies. We use Preference Cookies to remember your preferences and actions,  across multiple sites. .

Security Cookies. We use Security Cookies for security purposes.

Information from social networks or online accounts

Information from any social media profiles or any accounts that you share with us.


Other information

We may also process specific categories of information for specific and limited purposes, such as detecting and preventing financial crime or making our services available to customers. We will only treat particular types of information where we have obtained your explicit consent or are otherwise lawfully permitted to do so.

Use of collected Data

We use the collected data for various purposes such as to:

  • Verify your identity when you access your account information
  • Respond to your requests and communicate with you
  • Provide and maintain the Service
  • Process transactions, design products and profile customers
  • Notify you about changes to our Service
  • Allow you to participate in interactive features of our Service when you choose to do so
  • Provide customer care and support and for internal operations, including troubleshooting, data analysis, testing, research, security, fraud-detection, and account management
  • Provide analysis or valuable information so that we can improve the Service
  • Monitor the usage of the Service
  • Detect, prevent and address technical issues
  • Prevent fraud and enhance security of your account or our service platform.
  • Comply with and enforcing applicable legal and regulatory requirements, relevant industry standards, contractual obligations and our policies
  • Provide you with tailored content and marketing messages such as recommending services we believe you may be interested in

Disclosure of Data

Your information, including Personal Data, may only be accessed by employees that have a business reason to do so. We do not share your information with third parties for marketing purposes or any other purpose, unless otherwise stated here or you have given your consent

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to a third party or a country without notice to you and  adequate controls in place including the security of your data and other personal information.


We may disclose your Personal Data in the good faith and belief that such action is necessary and will not disclose your Personally Information to anyone except in any of the following circumstances:

  • We have your consent to share the information;  
  • To comply with a legal obligation;
  • bring you improved service across our array of products and services, when permissible under relevant laws and regulations, by disclosing your personal information with Sterling Bank’s affiliated websites and businesses;
  • To protect and defend the rights or property of the Bank;
  • To prevent or investigate possible wrongdoing in connection with the Service;
  • To protect the personal safety of users of the Service or the public;
  • To protect against legal liability;
  • We find that your actions on our web sites violate any part of our Privacy Policy; or
  • We provide same to trusted third parties who assist us in conducting our business. We require that these parties agree to process such information based on our instructions and in compliance with this privacy policy and any other appropriate confidentiality and security measures. 
Information from locations outside Nigeria 

If you are located outside Nigeria and choose to provide information to us, please note that the data, including Personal Data, will be processed in Nigeria. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

How long we will keep your information

We will keep your personal data for as long as we have a relationship with you, i.e. for as long as you use the app, remain validly subscribed to our newsletter or partake in surveys. Once that relationship with you has come to an end (e.g. following closure of your account) or cancellation of your subscription to the Service), we will not gather or collect any new information about you.

Once the relationship is over, we will only retain personal data for a period of time. This period will vary depending on the purpose for which we hold that information and subject to business or legal and regulatory requirements.

Security of Data

The security of your data is important to us, but be aware that no method of transmission over the Internet, or method of electronic storage can guarantee 100% security at all times. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security, you are responsible for securing and maintaining the privacy of your password and Account/profile registration information and verifying that the Personal Data we maintain about you is valid, accurate and up to date. If we receive instructions using your Doubble account login information, we will consider that you have authorized the instructions and process your instruction accordingly and without incurring any liability for doing so. We reserve the right, in our sole discretion, to refuse to provide our services, terminate Doubble accounts, and to remove or edit content.

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform specific Service-related roles  or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose outside of the service-specific need for which the data is required.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. You should note the privacy policy, terms of use and security practices of the linked third-party website before providing any information on that website.

Children's Privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have erroneously collected Personal Data from children without verification of parental consent, we will promptly remove that information from our servers.

Information Update

You must notify us of any change in your Personal Information by updating your account profile through our Services. Any changes will affect only future uses of your Personal Information. Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information. Otherwise, we will hold your Personal Information for as long as we believe it will help us achieve our objectives as detailed in this Privacy Policy.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We may let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

We are committed to resolving your privacy complaints and concerns as quickly as possible and have procedures in place to help resolve any problems or complaints efficiently. If you have any questions about this Privacy Policy, please contact us at doubble@sterling.ng 


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