Privacy Policy

For relevant processing activities, Sentry Link Limited is the data controller responsible for deciding how and why personal data is processed. In some circumstances, your employer, a regulated financial institution or another partner may act as a separate or joint controller for its own processing activities.

Registered Address: 33 Oritse Street, Ikeja, Lagos, Nigeria

Privacy Contact: support@employeebenefitpro.com

Telephone: +234 700 776 84386

Website: www.employeebenefitpro.com

The personal data we collect depends on how you use ebPro and which services are provided to you. This may include identity and profile data, contact data, employment and benefit data, account, card and transaction data, technical and usage data, and communications data.

• Full name, date of birth, photograph, employee number, identification details and identity-verification results;
• Email address, telephone number, residential or postal address and other contact details;
• Employer, employment status, department, benefit eligibility, allocations and programme participation information;
• Account identifiers, card identifiers, transactions, balances, funding, refunds, reversals, disputes and support information;
• IP address, device identifiers, browser and device type, login records, cookies, security and diagnostic logs; and
• Messages, support requests, complaints, communication records and marketing preferences.

We may collect personal data directly from you, from your employer or participating organisation, from regulated financial institutions and payment partners, from identity-verification providers, from merchants and service providers, automatically when you use the platform, and from other lawful sources where permitted.

We process personal data only where we have a lawful basis and for specified purposes.

• Create and manage your ebPro account and verify identity and eligibility;
• Administer benefits, employer-funded programmes, cards and payment functionality;
• Authorise, process and reconcile transactions and provide balances, statements and notifications;
• Provide customer support and manage complaints, disputes, refunds and chargebacks;
• Prevent fraud, abuse, money laundering and other unlawful activity;
• Protect the platform and comply with legal, regulatory, audit and reporting obligations;
• Improve our products, services and user experience and communicate with you; and
• Establish, exercise or defend legal claims.

Depending on the activity, we may rely on performance of a contract, steps taken at your request before entering a contract, compliance with a legal obligation, legitimate interests, your consent, or another lawful basis available under Nigerian law.

Where we rely on legitimate interests, we consider whether those interests are proportionate and whether your rights override them. Where we rely on consent, you may withdraw it at any time without affecting processing already lawfully carried out.

If your employer enrols you in an ebPro programme, it may provide personal data needed to create your account, establish eligibility, allocate benefits or administer the programme. Your employer is responsible for ensuring it has an appropriate legal basis to provide that information.

We may share relevant programme information back with your employer where necessary to operate the benefit scheme, subject to applicable law and our arrangements with your employer.

We may disclose personal data where reasonably necessary to provide the service or comply with law.

• Your employer or sponsoring organisation;
• Banks, card issuers, payment processors and payment networks;
• Identity-verification, KYC, fraud-prevention and compliance providers;
• Card manufacturers, personalisation, fulfilment and delivery providers;
• Cloud-hosting, software, cybersecurity, analytics and communications providers;
• Professional advisers, auditors, insurers, regulators, courts or government authorities;
• A purchaser, investor or successor in connection with a corporate transaction; and
• Other parties where authorised by you or permitted by law.

Some providers or partners may process personal data outside Nigeria. Where data is transferred internationally, we take steps required by applicable law to ensure an appropriate level of protection or another lawful transfer mechanism applies.

We retain personal data only as long as reasonably necessary to provide the service, satisfy legal, regulatory, accounting, anti-money-laundering, fraud-prevention and reporting requirements, resolve disputes and enforce agreements. When information is no longer required, we delete, anonymise or securely dispose of it, subject to lawful retention requirements.

We use reasonable technical and organisational measures designed to protect personal data, including access controls, authentication, encryption or tokenisation where appropriate, monitoring, logging, staff controls and vendor-security requirements.

No online service can guarantee absolute security. You are responsible for keeping passwords, PINs and other credentials confidential and notifying us promptly of suspected unauthorised access.

Subject to applicable law and relevant exemptions, you may have rights in relation to your personal data.

• Request information about and access to personal data we hold about you;
• Request correction or deletion of personal data in appropriate circumstances;
• Object to or request restriction of certain processing;
• Withdraw consent where processing is based on consent;
• Request data portability where applicable and object to certain direct marketing;
• Raise concerns about solely automated decision-making where applicable; and
• Lodge a complaint with the Nigeria Data Protection Commission or another competent authority.

We may use automated rules or risk indicators to identify potentially fraudulent, suspicious or prohibited activity. Where a decision has legal or similarly significant effects and applicable law grants a right to human review or to contest it, we will provide an appropriate process.

Our website or application may use cookies and similar technologies to operate the service, maintain sessions, remember preferences, improve performance, understand usage and protect against fraud or abuse. Where required, we obtain consent before using non-essential cookies.

We may send necessary service-related messages and, where permitted by law, promotional communications. You can opt out of direct marketing using the unsubscribe method in the message or by contacting us. Opting out does not stop essential service, security or transactional communications.

ebPro is generally intended for adult employees and authorised programme participants. We do not knowingly collect personal data from children unless a specific service is lawfully designed to do so and appropriate consent or other legal requirements are satisfied.

The platform may contain links to third-party websites, merchant sites or services. Those parties process data under their own privacy notices, which we encourage you to review.

If a personal-data breach occurs, we will assess the risk and take appropriate containment and remediation steps. Where required by law, we will notify the Nigeria Data Protection Commission and/or affected individuals within the applicable timeframe.

We may update this Privacy Policy to reflect changes to our services, technology, legal obligations or practices. We will publish the updated version and, where a change is material, may provide additional notice through the platform, website or email.

For privacy questions, requests or complaints, contact Sentry Link Limited / ebPro.

Registered Address: 33 Oritse Street, Ikeja, Lagos, Nigeria

Email: support@employeebenefitpro.com

Telephone: +234 700 776 84386

Website: www.employeebenefitpro.com

You may also have the right to complain to the Nigeria Data Protection Commission (NDPC). We recommend contacting ebPro first so we can try to address your concern promptly.