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KROON APP TERMS & CONDITIONS

This Agreement contains the complete terms and conditions that apply to your use and interaction on the Velvet Technologies Nigeria Limited “Velvet Technologies”, Kroon Peer-To-Peer Digital Marketplace “Kroon App” “Kroon Platform” “Kroon Services” and supersedes all other agreements entered into between you and Velvet Technologies Nigeria Limited, RC 1790051. These terms and conditions take effect on the date of publication and a user’s first download and acceptance of the terms and conditions. These terms and conditions are deemed to be accepted by the continuous use of the Kroon Peer-To-Peer Digital Marketplace “Kroon App” “Kroon Platform” “Kroon Services”.

1. Definitions

1.1  “Account”means your Kroon Account, being the record maintained by us of the amount of Kroon Tokens from time to time held by you on the Kroon Platform.

1.2  “Cash”means the lawful currency of the Republic of Nigeria;

1.3  “Cashout”means the buy-back of Kroon Tokens of a Kroon User by the Velvet Technologies on the Kroon Platform when the Kroon User wish to redeem Kroon Tokens into fiat currency, a service fee will be charged for every Cashout requested from the platform;

1.4  “Kroon Agent”means an Access Bank Closa Agent appointed to offer Kroon Token purchases, buy-out “Cashout” of Kroon Tokens and includes participating Access Bank ATM networks and bank branches in Nigeria where possible;

1.5  “Kroon Merchant” means a person or entity involved in retail and wholesale trader of goods and or services;

1.6  “Kroon Network”means the ecosystem of fintech solutions inter linked for the benefit of the Kroon User accessed through the Peer-to-Peer network;

1.7  “Kroon Services” means the Peer-to-Peer services provided by Velvet Technologies including issuance, management and redemption of Kroon Tokens;

1.8  “Kroon System” or “Kroon App” or“Kroon Platform” means the system operated by Velvet Technologies providing the Kroon Services and the Kroon Network;

1.9  “Kroon Tokens”means the token value depicted in your Kroon Account representing the amount of Kroon Tokens held by you for use on the Kroon platform and which may be bought back by the Kroon platform for the same amount in fiat currency after the deduction of the buyout “Cashout” fee and VAT;

1.10  “Kroon User” means any person or entity that participates on the Kroon System by using the Kroon Services to send or receive Kroon Tokens and includes any person that facilitates the redemption of Kroon Tokens;

1.11  “Manager” means a person who is legally authorised to access Kroon Tokens in your Kroon Account in the event of your permanent disability;

1.12  “Password”means your personal identification number being the password you choose to access and operate your Account and includes the one-time 4-digit PIN sent to you on registration for the purpose of activating your Account;

1.13  “Registration Form”means the registration form completed during the sign-up process and containing registration details as well as your acceptance of these Terms and Conditions;

1.14  “SMS”means a short messaging service that enables the transmission of text messages from one mobile phone to another;

1.15  “Successor” means a person who is legally authorised to access Kroon Tokens in your Kroon Account in the event of your death;

1.16  “Transaction” means the movement of money into your Kroon Account for the purchase of Kroon Tokens and the transactions on the platform using Kroon Tokens purchased or received;

1.17  “You” or “your” means the Kroon User who has registered to use the Kroon Service.

2. Service Description

2.1  Velvet Technologies operates the Kroon Peer-To-Peer Digital Marketplace that allows you to purchase, send, receive, request and spend Kroon Tokens through your Kroon Account using the Kroon Mobile Application “Kroon App”.

2.2  Kroon is available to all people in Nigeria who signs up for a Kroon account to use the Kroon Services and your acceptance of  these Terms and Conditions.

2.3  You may register for a Kroon Account by downloading the Kroon Mobile Application on a mobile application store platform or the link found on our website at https://www.kroonapp.com

2.4  Velvet Technologies may in its absolute discretion restrict or limit the number of accounts you may operate at any one time.

2.5  By registering to use the Kroon Service you agree to these Terms and Conditions (the “Terms and Conditions”), which shall form a legally binding agreement between you and Velvet Technologies.

2.6  Velvet Technologies may in its absolute discretion refuse to register or revoke the registration of any person on the Kroon System.

2.7  You may acquire Kroon Tokens in your Kroon Account by purchasing Kroon Tokens with a credit or debit card on the mobile application or in Cash at a Kroon Agent. You can also receive a remittance of Kroon Tokens from another Kroon User, by requesting or receiving Kroon Tokens on the platform or through any other acceptable means that Velvet Technologies may provide.

2.8  All Transactions on the platform will only occur when Kroon Tokens are used. The Kroon Platform will only transact in fiat currency when Kroon Tokens are being purchased or bought back from the user by the Kroon Platform in the form of a Cashout.

2.9  Subject to any prescribed transaction limits and the provisions of these Terms and Conditions, the balance of your Kroon Account is redeemable at any time and shall be disposed of only in accordance with your instructions given via the Kroon Platform.

2.10  You acknowledge that Kroon is neither a bank nor a deposit-taking institution or financial services provider.

2.11  All charges applicable to the Kroon service are set forth in a separate fee schedule available on the Kroon website and are subject to change at any time at Velvet Technologies’ sole discretion.

3. Account Opening and Maintenance

3.1. The following conditions must be met before opening a Kroon Account in your name:

3.1.1. You must be at least 16 years old with capacity to enter into contracts.

3.1.2. You must provide sufficient proof of identification (ID). For the purpose of this agreement, sufficient proof of (ID) shall be an original national ID card if you are a Nigerian national; and original Alien Certificate, Valid Passport if you are a foreign national. Copies of the ID provided may be retained by Velvet Technologies for purposes of authentication.

3.1.3. You must not provide any false, inaccurate, incomplete or misleading information.

3.2. You are responsible for ensuring that your registration details are maintained and up to date.

3.3. Velvet Technologies may reject your application at its discretion if any of the account opening requirements are not met or if you fail to provide us with satisfactory proof of identification.

3.4. Velvet Technologies reserves the right to request further information pertaining to your account at any time failure to which may result in limitation on usage of the Kroon Service, suspension or termination of the account.

3.5. You must not maintain more than two Kroon Accounts.

3.6. No interest will be paid on any Kroon Tokens held in your Kroon Account.

3.7. For the avoidance of doubt Velvet Technologies shall not be obliged to adduce evidence in any civil or criminal court in relation to the contents of any transaction you have done on the Kroon Platform.

4. Privacy Policy

4.1. Velvet Technologies recognizes the importance of protecting the privacy of all information provided by users of the Kroon Platform. This statement is meant to affirm our utmost respect for your rights to privacy.

4.2. Velvet Technologies collects personally identifiable information that we use to profile Kroon Users and administer individual Kroon Accounts, update Kroon databases, and provide Kroon User support.

4.3. Save as provided hereunder, Velvet Technologies does not share your personal information with unauthorized persons and adequate safeguards have been put in place to prevent unauthorized access and to ensure confidentiality of your personal information.

4.4. You acknowledge that by using the Kroon Services, some of your personal information will be passed on to any person whom you receive Kroon Tokens from, or send Kroon Tokens to and will be available to any third party involved in the operation of the services including without limitation, Kroon Agents and our Bank (Access Bank PLC at the current time).

4.5. You acknowledge that Velvet Technologies may verify your identity information through publicly available and/or restricted government databases in order to comply with regulatory requirements.

4.6. You accept that Velvet Technologies shall have the right to monitor your account usage and may disclose personal information to local law enforcement or investigative agencies or any competent regulatory or governmental agencies to assist in the prevention, detection or prosecution of money laundering activities, fraud or other criminal activities.

4.7. Velvet Technologies employees who handle personal information are under an obligation to treat it confidentially and may not disclose it to unauthorised third parties. Velvet Technologies employees are also responsible for the internal security of the information. Employees who violate Velvet Technologies’ privacy policies are subject to a range of disciplinary actions.

4.8. Any person submitting any information to Velvet Technologies through the Kroon System may be granted access rights to that information. Velvet Technologies has developed systems that enable access and correction of information submitted to it.

5. Account Usage

5.1. After your account has been opened and activated, you will be able to initiate the following transactions:

5.1.1. load Kroon Tokens through a participating Kroon Agent outlet;

5.1.2. send Kroon Tokens to and receive Kroon Tokens from other Kroon Users;

5.1.3. Cashout Kroon Tokens from your Account through a participating Kroon Agent or to your Bank Account;

5.1.4. Cashout Kroon Tokens from your Account through participating ATM networks (if applicable in your region);

5.1.5. pay utility bills or make one-off or periodic payments or remittances to participating Kroon Merchants, financial institutions, charity organisations, etc.;

5.1.6. pay for goods purchased from participating Kroon Merchants;

5.1.7. manage your Account (e.g. check balance inquires, change PIN, etc.); and

5.1.8. any other transactions as may be introduced by Velvet Technologies or our financial institution partners from time to time.

5.2. Velvet Technologies does not warrant that all functionalities shall be available at all times and may withdraw any functionality or the Kroon Service in general as a direct result of new or amended legislation, statutory instrument, Government regulations or policy or any other compelling reason.

5.3. Velvet Technologies may provide additional functionality on the Kroon Network following integration with platforms of financial institutions and other entities providing you with specified services. Such functionality may give you limited access to platforms of the financial institutions or other entities. By using such functionality to gain access to other platforms, you hereby agree to indemnify Velvet Technologies against, and hold Velvet Technologies harmless from any losses arising from your access to such external platforms.

5.4. In the event of any review of our business planning, technical, public interest or operational reasons, changes within the industry, recommendations from regulatory bodies or similar events, Velvet Technologies may vary these Terms and Conditions or policies affecting usage and shall notify you of such changes through appropriate means. Your continued use of the Kroon Service shall be deemed to be your acceptance of all such varied terms and conditions or polices.

6. Kroon Access Responsibility

6.1. Access to the Kroon Services is password protected. You hereby agree to guard your password and not to disclose it to any third party including Kroon Agents, Velvet Technologies staff or any person purporting to have authority to ask for it.

6.2. You acknowledge that you shall be solely responsible for the security of your password. Velvet Technologies shall not be liable for any disclosure of your password to any third party and you hereby agree to hold Velvet Technologies harmless from any losses that result from any password disclosure.

6.3. You are responsible for all instructions given to Velvet Technologies in relation to your Kroon Account.

6.4. Velvet Technologies shall deem each correct password entry as being performed by the legitimate owner of the Kroon Account and shall regard all subsequent Transactions as validly performed by you.

7. Loading Kroon Tokens

7.1. You may load Kroon Tokens into your Kroon Account by purchasing tokens on the Kroon App using your debit/credit card or by purchasing Kroon Tokens at any of the Kroon Agents by making a direct deposit.

7.2. In order to load Kroon Tokens, you must complete the information requested, including passing the identity and security validation and verification procedures to ascertain that you are the owner of the account.

7.3. Velvet Technologies reserves the right to prescribe Transaction limits and may allocate some Kroon Accounts with higher or lower limits.

8. Transferring Kroon Tokens

8.1. Transaction limits and charges as prescribed by Velvet Technologies shall apply each time you use the “Transfer”, “Pay Now”, “Cashout” or other functionalities that effect the transfer of Kroon Tokens from your Kroon Account.

8.2. Your Transaction request will not be completed:

8.2.1. If you have insufficient Kroon Tokens in your Kroon Account to complete a transaction or to cover the fee charges for a transaction;

8.2.2. If you have reached the maximum Account balance limit prescribed by Velvet Technologies where applicable;

8.2.3. If you have reached the daily limit prescribed by Velvet Technologies where applicable;

8.2.4. If your Account has been temporarily suspended or permanently frozen on valid grounds;

8.2.5. If there is any other compelling reasons such as temporary system delay or outage.

8.3. You may send Kroon Tokens to any user on the Kroon System.

8.4. You will be charged a fee for any purchase of Kroon Tokens or Cashout transactions you undertake. The fees will be made available on the Kroon website and will be updated from time to time.

8.5. If the Kroon Tokens in your Kroon Account is not sufficient to carry out your transaction (including covering the transaction cost) request in full, the transaction will not be completed and no Kroon Tokens will be debited from your Kroon Account.

8.6. Upon the successful completion of your transaction to another Kroon User, Velvet Technologies will immediately cause the transfer of the Kroon Tokens to the other user’s Kroon Account. You and the recipient will both be notified as to the completed status of your transaction.

8.7. Where Velvet Technologies is unable to complete a transaction, you will be notified to the reasons for not completing the transaction.

8.8. Each Transaction you undertake will be accompanied by a unique receipt number that will appear in the confirmation sent to your Kroon Account balance will be updated. This receipt number may be used to track and identify the Transactions carried out on your Account.

8.9. Upon the successful transmission of Kroon Tokens from your Account to registered user’s Kroon account, title to the Kroon Tokens will pass to the recipient.

8.10. A Transaction once completed is final and irrevocable. As such, Velvet Technologies shall not be under any compulsion to reverse any Transaction.

8.11. Notwithstanding the import of clause 8.10, Velvet Technologies reserves the right, at its sole discretion, to cancel or reverse a Transaction if reasonable grounds such as manifest error or fraud are shown and PROVIDED that the recipient has not redeemed the Kroon Tokens and the reversal claim is made within one (1) month of the erroneous Transaction date.

8.12. Velvet Technologies will not be compelled to refund or compensate the sender if the Kroon Tokens is sent to a recipient mistakenly or in error or fraudulently or under duress and subsequently redeemed for Cash or otherwise spent by the recipient of the mistaken, erroneous or fraudulent Transaction and you hereby agree to hold Velvet Technologies harmless for any losses arising from a mistaken, erroneous or fraudulent transfer of Kroon Tokens or any transfer of Kroon Tokens from your account effected under duress or under coercion or criminal force.

9. Receiving Kroon Tokens

9.1. If you are registered on the Kroon Platform and you receive a notification informing you that you have received Kroon Tokens from another Kroon user, the Kroon Tokens shall be loaded to your Kroon Account immediately and you may redeem the Kroon Tokens at any Kroon Agent or directly to you Bank Account or transfer the Kroon Tokens to another Kroon user.

9.2. If you receive Kroon Tokens in error you acknowledge that you shall be obliged to return the Kroon Tokens to the sender failing which Velvet Technologies may reverse the transaction to the sender.

9.3. You may be liable to face prosecution for consuming or utilizing Kroon Tokens sent to you in error.

10. Withdrawal (Redemption/Cashout) of Kroon Tokens

10.1. Kroon Agents: Upon passing the vetting requirements conducted by a Kroon Agent, you may withdraw your Kroon Tokens at participating Kroon Agents by accessing your profile on the Kroon platform and transferring Kroon using the Agent Cashout option. Kroon Agent Cashouts will only be successful if requested at the Kroon Agent premises and successfully passing the vetting process on the Kroon Platform. The Vetting process will require the participation of both the user and the Kroon Agent through the Kroon Application.

10.2. Velvet Technologies shall, subject to Transaction limits on the Kroon System, process the requests you make immediately after being satisfied that the person making the Cashout has passed all identity and security validation and verification procedures. In the event of a dispute over the redemption of the Kroon Tokens, it shall be sufficient for Velvet Technologies to show a logical association between the Transaction and the verification of identity and/or security procedures conducted to ascertain identity of the person entitled to the Kroon Token proceeds.

10.3. Subject to any other provisions to the contrary, you will be charged a Cashout service fee each time you Cashout Kroon Tokens from your Kroon account.

11. Intellectual Property

 11.1. All intellectual property rights in the Kroon Service including the Kroon App, KroonMan and Kroon Tokens trademarks are the property of Velvet Technologies and/or its affiliates. Any unauthorized reproduction, modification, distribution or republication of Kroon materials or intellectual property, without the express prior written consent of Velvet Technologies and/or its affiliates is strictly prohibited.

12. Fees

12.1. You are responsible for the payment of all applicable fees. Velvet Technologies publishes fees payable on the Kroon website.

12.2. All fees are deducted at source and are subject to change at any time at Velvet Technologies’ sole discretion.

12.3. Fees payable on each Transaction will be deducted from your Kroon Account at the completion of each Transaction. Your new balance on completion of the Transaction shall be updated accordingly.

12.4. Except as may otherwise be notified, fees are exclusive of all applicable taxes including Value Added Tax “VAT” at the prevailing rate.

13. Suspension, Termination & Freezing

13.1. Velvet Technologies reserves the right at its sole discretion to suspend or terminate the agreement if you use the Kroon account for unauthorized purposes.

13.2. You acknowledge that Velvet Technologies may be compelled by law to suspend and/or freeze your Account or decline to execute your Transaction requests if there are reasonable grounds to suspect that an Account has been or is being used in connection with any criminal or fraudulent activity.

13.3. You may request your Account to be closed at any time by giving written notice to Velvet Technologies addressed to: Kroon App, Velvet Technologies Nigeria Limited, using the email address closeaccountng@Kroonapp.com. Velvet Technologies shall act on such instructions if, and only if, your account balance reads zero (0).

13.4. Velvet Technologies may, at its discretion, close your Account at any time for any reason upon giving one (1) week’s notice to you and making reasonable attempts to reach you. In such circumstances, you shall be entitled to the balance of any Kroon Tokens remaining in your Kroon Account after the deduction of Cashout fees and VAT.

13.5. Velvet Technologies may send notices to you at any postal address provided by you or electronically by SMS or email which you registered on the Kroon System.

13.6. This agreement terminates automatically upon the death of the Kroon User who has signed up for the Kroon Services.

14. Warranties, and Limitation of Liability

 14.1. Velvet Technologies will report any suspicious account activity to its Money Laundering Reporting Officer (MLRO). The MLRO may escalate the suspicious activity to the relevant law enforcement authority.

14.2. Velvet Technologies shall use all reasonable efforts to ensure that all Transaction requests are processed in a timely manner. However, Velvet Technologies makes no representations or warranties as to continuous, uninterrupted, or secure access to the Kroon service, which may be affected by factors outside Velvet Technologies’ control, or may be subject to periodic testing, repair, maintenance, or upgrades. 14.3. Velvet Technologies will not be responsible for any claim unless caused by wilful default attributable to Velvet Technologies. Velvet Technologies specifically disclaims all liability for any damages or losses, including, without limitation, direct, indirect, consequential, special, incidental or punitive damages deemed or alleged to have resulted from or caused by but not limited to:

14.3.1. transactions made to unintended recipients or payments made in incorrect Kroon Tokens due to the input of incorrect information by you;

14.3.2. transactions made from your account by an unauthorised third party who passes all identity and verification checks;

14.3.3. any fraud, deception or misrepresentations by any Kroon user, whether or not the user has been verified;

14.3.4. any damages resulting from a recipient’s decision not to accept a Transaction made by you through the Kroon System;

14.3.5. failure of any other telecommunications or data transmission system other than the Kroon System;

14.3.6. any result of any acts of government or authority, any act of God or force majeure.

14.4. The limit of Velvet Technologies’ liability shall not exceed the maximum Account balance limit for the time being in force for any single event or series of events.

14.5. You agree to indemnify and hold Velvet Technologies harmless against any claim brought against Velvet Technologies by a third party resulting from your breach of these Terms and Conditions.

15. Dispute Resolution and Governing Law

 15.1. You may contact Velvet Technologies Customer Care (customercare@Kroonapp.com) for any disputes, claims or to report Account discrepancies. Velvet Technologies Customer Care shall handle the report in accordance with Velvet Technologies’ standard complaint handling procedures.

15.2. In certain circumstances Velvet Technologies in conjunction with participating merchants or agents may provide for dispute resolution mechanisms. You agree to abide by such mechanisms as may be advised by Velvet Technologies or the participating merchants/agents from time to time.

15.3. Any dispute arising out of or in connection with this Agreement that is not resolved by Velvet Technologies Customer Care may be brought to the attention of the Velvet Technologies Manager responsible for the operations of the Kroon Services for resolution.

15.4. Any dispute arising out of or in connection with this Agreement that is not resolved by the Velvet Technologies Manager responsible for the operations of the Kroon Services shall be referred to arbitration by a single arbitrator to be appointed by agreement between the parties or in default of such agreement within 60 days of the notification of a dispute, upon the application of either party, by the Chairman for the time being of the Chartered Institute of Arbitrators (Nigerian Branch). Such arbitration shall be conducted in the English language in Lagos in accordance with the Rules of Arbitration of the said Institute and subject to and in accordance with the provisions of the Arbitration and Conciliation Act (Chapter 18, Laws of the Federation of Nigeria 2004) (the “ACA”).

15.5. To the extent permissible by Law, the determination of the Arbitrator shall be final, conclusive and binding upon the parties hereto.

15.6. Nothing in this section shall be deemed to exclude any legally recognised dispute resolution body from receiving, hearing and determining the dispute.

15.7. This Agreement shall be governed by and construed in accordance with the laws of Nigeria.

16. Disclosure & Data Retention

16.1. You hereby expressly consent and authorize Velvet Technologies to disclose any Transaction data or information pertaining to your Kroon Account to any law enforcement, investigative or regulatory authority including without limitation the Nigerian Police, Central Bank of Nigeria, or any competent Anti-Money Laundering authority for the purposes of any genuine enquiry or investigation or to any third party to which you have separately, either in writing or electronically through the Kroon System or otherwise, authorised Velvet Technologies to disclose Transaction data or information pertaining to you or your usage of Velvet Technologies Products and Services, including your Kroon account provided that any consent given to Velvet Technologies to disclose information to any third party (not being a law enforcement, investigative or regulatory authority) pursuant to this clause may be withdrawn at any time.

16.2. You acknowledge that where your Account is determined by a competent judicial authority as containing proceeds of any criminal or money laundering activities, Velvet Technologies may be required by law to surrender Kroon Tokens in your account to any statutory fund created for the purpose of recovering the proceeds of crime.

16.3. You acknowledge that Velvet Technologies may retain your Transaction data for a period of up to seven (7) years or as may be required by any law or regulation.

17. Force Majeure

17.1. Neither Party shall be liable to the other Party for any delay or failure to perform its obligations under these Terms and Conditions as a result of revolution or other civil disorders; belligerent aggression by an enemy; strikes; lack of available resources from persons other than parties to this Agreement; labour disputes; electrical equipment or system availability delay or failure; fires; floods; acts of God; government or regulatory intervention; or, without limiting the foregoing, any other causes not within its control, and which by the exercise of reasonable diligence it is unable to prevent, whether of the class of causes hereinbefore enumerated or not. If such delay or failure continues for at least thirty (30) days then either Party may terminate their engagement by notice in writing to the other. Upon such termination all Kroon Tokens held in account for you in the Kroon System shall be made good to you after the necessary service fees and tax deductions.

18. General

18.1. Using your personal Kroon account to carry out Kroon transactions on behalf of another person is prohibited and may expose you to criminal liability. You may not use, or permit the use of your Kroon account to carry out any transactions on behalf of any other person.

18.2. You acknowledge that these Terms and Conditions are subject to amendment, modification or variation from time to time if required by, or found to be in conflict with, applicable law or regulation or otherwise without affecting the validity or enforceability of the remaining provisions.

18.3. These Terms and Conditions constitute the entire agreement between the parties with respect to the subject matter hereof and supersede and replace any and all prior terms. In the event of inconsistency between these Terms and Conditions and previous editions, this version will prevail.

18.4. These Terms and Conditions may be amended by Velvet Technologies from time to time as Velvet Technologies introduces new Kroon functionalities. Such amended Terms and Conditions may be published in posters or pamphlets available at Kroon Agent Outlets, in the daily newspapers and/or on the Velvet Technologies/Kroon website from time to time and shall take effect immediately upon publication.

18.5. Velvet Technologies’ failure to exercise or enforce any right under these Terms and Conditions shall not be deemed to be a waiver of any such right nor shall it prevent Velvet Technologies from exercising or enforcing the rights in question at any time.

18.6. You may not transfer any rights or obligations you may have under this Agreement without Velvet Technologies’ prior written consent.

18.7. You must not use the Kroon service for the receipt of or payment for goods or services that offend or circumvent any law including without limitation, narcotic drugs, firearms, obscene or pornographic material or services, participation in pyramid or ponzi schemes, infringement of third party intellectual rights, running illegal or unauthorised lotteries, gaming or gambling, as well as material that is morally repugnant; incites violence or desires to cause harm; induces an unacceptable sense of fear or anxiety; encourages or incites any person to engage in dangerous practices or to use harmful substances; induces or promotes tribal, religious or racial disharmony; causes grave or widespread offence; or debases, degrades or demeans others.

18.8. If the Courts appoint a Successor or Manager, as the case may be, Velvet Technologies shall rely on such appointment of Successor or Manager in its decision to transmit Kroon Tokens held to the credit of your account to the Successor or Manager upon the event of your death or permanent incapacity (as the case may be).

18.9. You acknowledge that Kroon Agents and Merchants are independent contractors and Velvet Technologies shall not be liable for the acts or omissions of Kroon Agents and Merchants.

Disclosure

3. Apart from where you have consented or disclosure is necessary to achieve the purpose for which it was submitted, personal information may be disclosed in special situations where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities. Also, we may disclose personal information when we believe in good faith that the law requires disclosure.


4. We may engage third parties to provide you with goods or services on our behalf. In that circumstance, we may disclose your personal information to those third parties in order to meet your request for goods or services.

Security

5. We strive to ensure the security, integrity and privacy of personal information submitted to our sites, and we review and update our security measures in light of current technologies. Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure.


6. However, we will endeavour to take all reasonable steps to protect the personal information you may transmit to us or from our online products and services. Once we do receive your transmission, we will also make our best efforts to ensure its security on our systems.


7. As part of our business operations your information is stored on servers located in Nigeria.


8. In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us. However, we will not be held responsible for events arising from unauthorised access to your personal information.

Collecting Information for Users

9. IP Addresses

Our web servers gather your IP address to assist with the diagnosis of problems or support issues with our services. Again, information is gathered in aggregate only and cannot be traced to an individual user.

 

10. Cookies and Applets

We use cookies to provide you with a better experience. These cookies and Applets allow us to increase your security by storing your session ID and are a way of monitoring single user access.
This aggregate, non-personal information is collated and provided to us to assist in analysing the usage of the site.

General Data Protection Regulation

11. We ensure we manage any data we collect from you in accordance with the GDPR where applicable.

Access to Information

12. We will endeavour to take all reasonable steps to keep secure any information which we hold about you, and to keep this information accurate and up to date. If, at any time, you wish to obtain a copy of, modify, or delete any information held about you, you may contact our Information Officer via email to siteprivacy@kroonapp.com to have this done.


13. In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us.

Problems or questions

14. If we become aware of any ongoing concerns or problems with our websites, we will take these issues seriously and work to address these concerns. If you have any further queries relating to our Privacy Policy, or you have a problem or complaint, please contact us.