1. Introduction
This Privacy Policy explains the information we collect and process when you visit Asanya, create or use a Business or Partner account, participate in a Business programme, interact with other users through Asanya, use our services or otherwise communicate with us.
Depending on the particular activity and the relationship between the parties, Urhere Solutions Ltd may act as a data controller, processor or in another role recognised under applicable data-protection law.
This Privacy Policy should be read together with the applicable Asanya Business Terms, Partner Terms and any other privacy or data-processing terms that apply to a particular service or relationship.
1.1 Who We Are
Asanya is a product of Urhere Solutions Ltd (RC – 7171523), a company incorporated under the laws of the Federal Republic of Nigeria.
Asanya is relationship-led growth infrastructure that helps Businesses organise and manage relationships with Partners, attribute relevant commercial activity, track milestones and Qualifying Outcomes and, where applicable, manage commission and settlement information.
Data Protection Officer (DPO) Contact:
Direct formal inquiries, compliance notices, and subject rights requests.
hello@useasanya.com
2. How We Use Your Information
2.1 When You Visit Our Website
When you use our website to browse our products and services or view information we make available, cookies and similar technologies may be used by us and relevant third parties to allow the website to function, collect useful information about visitors and improve your experience.
We may use:
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Strictly necessary cookies: These are essential to provide services available through our website and enable certain features.
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Functionality cookies: These enable technical functionality and may allow us to remember choices and preferences.
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Performance / Analytical cookies: These help us understand how users navigate and interact with Asanya so that we can improve our services.
Further information may be provided in the applicable Asanya Cookies Policy.
2.2 When You Create or Use a Business Account
When you create or use an Asanya Business account, we may collect information including:
Registered name where applicable
Registration number where applicable (RC / BN)
Business email address and telephone number
Business address and location
Information about authorised Business users
Account, subscription and plan information
Other information reasonably required to establish and administer the Business account
We use this information to:
- Create and administer the Business account;
- Review Business Information where required;
- Provide Asanya functionality;
- Manage subscriptions;
- Provide support;
- Protect Asanya and its users;
- Comply with applicable legal or regulatory requirements; and
- Maintain relevant account and audit records.
2.3 When You Create or Use a Partner Account
When you create, activate or use an Asanya Partner account, we may collect information including:
Professional or Business information
Information relevant to your Partner profile
Partner Code and Asanya identifiers
Businesses or programmes with which you have relationships
Information relating to your eligibility, visibility or availability on Asanya
Other information reasonably required to establish and operate your Partner account
A Partner may join Asanya independently or following an invitation or onboarding initiated by a Business.
Where you join independently, Asanya may associate your account internally with an Urhere-designated network or administrative account for identification or platform-management purposes. Such association does not, by itself, create a commercial relationship between you and Urhere.
2.4 Partner Relationships, Attribution and Programme Activity
Where you participate in a Business programme or your commercial activity is managed through Asanya, we may process information relating to:
- Partner and Business relationships;
- Attributed customers, opportunities, accounts or other subjects;
- Partner Codes, links and other attribution identifiers;
- Attribution dates and periods;
- Milestones;
- Qualifying Outcomes;
- Relevant status information;
- Recurring attributed activity;
- Commission or reward information where applicable;
- Settlement information;
- Disputes, corrections or reversals;
- Activity and audit history; and
- Other information necessary to operate the relevant programme.
This information may be provided by a Business, Partner, customer or participant, or generated through Asanya or an authorised system connection.
Asanya may use this information to enable attribution, relationship management, programme administration, reporting, commission calculations where applicable and relevant commercial transparency.
2.5 Partner Visibility and Relationship Management
Asanya may enable Partners to see permitted information relating to activity attributed to them. Depending on the applicable programme, this may include:
- The status of an attributed customer or opportunity;
- Whether relevant milestones have been completed;
- Whether an action remains outstanding;
- Whether an action is awaiting the Business, customer or another participant;
- Whether a Qualifying Outcome has occurred;
- Commission or reward information where applicable; and
- Relevant activity history.
We seek to provide the status information reasonably necessary for commercial transparency and relationship management without unnecessarily disclosing underlying personal or confidential information.
Data Minimisation Example: Asanya may display: “KYC Submitted — Pending Business Review” without displaying the underlying KYC documentation to the Partner.
2.6 Partner Discoverability and Availability
Business-onboarded Partners are private to the relevant Business by default.
Where Partner-discovery or Partner-access functionality is made available, we may process information concerning:
- Whether a Partner has consented to wider visibility;
- Whether an originating Business has provided any required permission;
- Partner eligibility;
- Relevant availability settings;
- Applicable Business access rights; and
- Partner profile information permitted to be shown to other Businesses.
We do not make a Business's confidential information, customers, programme information, commission arrangements or other restricted information available to another Business merely because a Partner becomes discoverable.
A Partner may be given controls to accept, decline, modify or withdraw wider visibility, subject to applicable contractual obligations, existing engagements and information that must lawfully be retained.
2.7 Commission and Settlement Information
Where a Business programme provides for monetary commission, Asanya may process information concerning:
- Commission calculations;
- Amounts earned or payable;
- Commission status;
- Settlement requests;
- Settlement status;
- Payment confirmation;
- Failed or delayed settlement;
- Disputed commission;
- Reversals or corrections; and
- Related transaction or audit information.
Wallet Clarification: Unless expressly stated otherwise, Asanya does not hold Partner funds in an Asanya-funded wallet.
Where a licensed payment provider is used to facilitate payment or settlement, relevant information may be transmitted to or received from that provider as necessary to provide the applicable functionality.
2.8 APIs and Other Integrations
Businesses are not required to integrate their systems with Asanya.
Where a Business elects to use an API or another authorised integration, Asanya may receive information and events from that system concerning attribution, milestones, Qualifying Outcomes, commission or other supported activities.
We may process technical and event information including:
- Business and account identifiers;
- Partner identifiers;
- Attribution subject identifiers;
- Event types;
- Unique event identifiers;
- Timestamps;
- Transaction or activity status;
- Source-system information;
- Processing status; and
- Information reasonably required to authenticate, validate, reconcile or audit the event.
Asanya may use unique event identifiers and related information to detect duplicate, failed, reversed or corrected events and maintain reliable platform records.
2.9 When You Submit an Enquiry or Request Information
When you submit an enquiry, request information or request a demonstration of Asanya, we may ask for information such as your:
- Name;
- Telephone number;
- Business or organisation name;
- Role or title; and
- Email address.
We use this information to respond to your request and provide information about Asanya. We may also contact you after your enquiry to follow up on your interest and determine whether we have adequately responded to your request.
We may do this on the basis of our legitimate interests in responding to prospective users and developing our services, subject to applicable law.
3. Lawful Processing
We process personal data only where we have an appropriate lawful basis under applicable law. Depending on the relevant activity, this may include:
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Contractual Necessity: Performing a contract or taking steps connected with a contract;
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Legitimate Interests: Our legitimate interests or those of another person, where those interests are not overridden by the rights of the data subject;
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Legal Compliance: Compliance with a legal obligation;
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Consent: Consent, where consent is the appropriate lawful basis; or
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Other Lawful Grounds: Another lawful basis recognised under applicable data-protection law.
Where we rely on consent, you may withdraw your consent in accordance with applicable law. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
4. How We Protect Your Personal Data
We take appropriate technical and organisational measures designed to protect personal data against accidental or unlawful loss, misuse, alteration, unauthorised disclosure or access.
We seek to limit access to personal data to persons who have a genuine need to access it for authorised purposes. Persons processing personal information through Urhere are expected to act in an authorised manner and are subject to appropriate confidentiality obligations.
Further information may be provided through the Asanya Security & Trust Statement or Legal & Trust Centre.
5. How Long We Keep Personal Data
We retain personal data only for as long as reasonably necessary for the purpose for which it was collected or another lawful purpose. Relevant retention periods may depend on:
The type of account or relationship
Attribution or programme history
Commission and settlement records
Dispute or complaint history
Regulatory or legal obligations
The need to establish, exercise or defend legal claims
Where information is no longer required, it may be deleted, anonymised or securely archived in accordance with applicable retention requirements.
Further details may be provided in the Asanya Data Retention and Deletion Policy.
6. Sharing Personal Data
We may share personal information where reasonably necessary with:
- Businesses with which a Partner has an applicable relationship;
- Partners, to the extent information is appropriately made visible under a Business programme;
- Authorised users of a Business account;
- Technology and infrastructure providers;
- Payment or settlement providers where applicable;
- Integration Partners where access has been appropriately authorised;
- Professional advisers;
- Regulators, courts, law-enforcement authorities or other persons where disclosure is required or permitted by law; and
- Other service providers reasonably necessary to operate Asanya.
We seek to limit such disclosure to information reasonably necessary for the relevant purpose.
Where third parties process personal data on our behalf, appropriate contractual or other safeguards may be used where required.
7. International Transfers
Where personal data is transferred outside Nigeria, we will take steps required under applicable data-protection law to ensure that the transfer has an appropriate legal basis and relevant safeguards.
8. Your Rights as a Data Subject
Subject to applicable law, you may have rights concerning your personal data, including the right to:
- Ask what personal data we hold about you;
- Request access to your personal data;
- Request correction of inaccurate or incomplete information;
- Withdraw consent where processing is based on consent;
- Request deletion of personal data in appropriate circumstances;
- Request restriction of processing in appropriate circumstances;
- Object to certain processing;
- Receive certain personal data in a portable, machine-readable format where applicable; and
- Exercise other rights available under applicable data-protection law.
Some rights are subject to legal conditions and exceptions and may not apply in every circumstance. For example, we may need to preserve certain attribution, transaction, commission, audit, security, dispute or regulatory records even after an account relationship ends.
To exercise your rights, contact our Data Protection Officer using the contact information provided in this Policy: hello@useasanya.com.
9. Complaints
If you have a concern about how Asanya has handled your personal data, you may contact our Data Protection Officer so that we can attempt to address the matter.
Regulatory Protection: Nothing in this Policy removes any right you may have to make a complaint to the Nigeria Data Protection Commission (NDPC) or exercise another remedy available under applicable law.
10. Updates to This Privacy Policy
We regularly review this Privacy Policy and may update it from time to time as Asanya develops, our use of personal data changes or legal and regulatory requirements evolve.
Where we intend to use personal data for a materially different purpose, we will provide appropriate information and, where required, obtain consent.
The current Policy will display: Version | Effective Date | Last Updated. Where a change materially affects your rights or the way we process personal information, we will provide appropriate notice. Previous versions may be retained for audit and reference purposes.
Questions about your privacy?
Contact our designated Data Protection Officer for any queries or formal notices regarding your personal data.
Urhere Solutions Ltd (RC – 7171523)
100A Apapa-Oshodi Expressway Lagos, Nigeria