1. Introduction

This Data Processing Agreement ("DPA") governs the processing of personal data by Blomgram on behalf of its users, in accordance with applicable data protection laws, including those in Nigeria and the United Kingdom. This DPA forms part of the Terms of Use and is intended to ensure compliance with relevant data protection regulations.

2. Scope of Processing

Purpose of Processing: Blomgram processes personal data to provide its Services, including onboarding, sign-up & login, KYC verification, wallet management, and transactions such as deposits and withdrawals. Personal data is collected, stored, and used to facilitate these functions and to ensure compliance with legal obligations.

Types of Personal Data: The personal data processed includes, but is not limited to, user identification information (e.g., name, email address, phone number), financial data (e.g., transaction details), and KYC information.

3. Data Security

Security Measures: Blomgram implements appropriate technical and organizational measures to ensure the security of personal data. These measures include encryption, access controls, secure data storage, and regular security assessments to protect against unauthorized access, data breaches, and other security risks.

Incident Response: In the event of a data breach, Blomgram will promptly notify affected users and relevant authorities in accordance with applicable data protection laws. We will also take all reasonable steps to mitigate the impact of the breach.

4. Sub-processors

Use of Sub-processors: Blomgram may engage sub-processors to assist in the processing of personal data. Sub-processors are third-party vendors that provide services such as cloud storage, payment processing, and customer support.

Due Diligence: Blomgram ensures that any sub-processors engaged are bound by contractual obligations that provide at least the same level of data protection as set out in this DPA.

Notification: Users will be informed of any changes to the list of sub-processors, and they will have the opportunity to object to the use of new sub-processors if they believe it affects the security of their personal data.

5. Data Subject Rights

Access and Correction: Users have the right to access their personal data held by Blomgram and request corrections to inaccurate or incomplete data. Requests can be made through the user account settings or by contacting our support team.

Deletion and Restriction: Users may request the deletion or restriction of their personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected or if the data subject withdraws consent.

Objection: Users have the right to object to the processing of their personal data for specific purposes, including direct marketing. Blomgram will consider such objections and respond in accordance with applicable data protection laws.

6. Data Retention

Retention Period: Blomgram will retain personal data only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal obligations, and to enforce our agreements. Retention periods vary depending on the type of data and the applicable legal requirements.

Deletion: Once the retention period expires, personal data will be securely deleted or anonymized. Users can request the deletion of their data at any time, subject to legal and contractual obligations that may require data retention.

BLOMGRAM

CONTACT

Colchester Essex, England

+44 789 936 5494

hello@blomgram.com

Blomgram is a subset of Drumbell technology. Blomgram offers its products and services in partnership with licensed transmitters in their respective jurisdictions. All trademarks and brand names belong to their respective owners. Use of these trademarks and brand names do not represent endorsement by or association with Blomgram

IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT: To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an Account. What this means for you: When you open an Account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see a copy of your driver's license.

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