PRIVACY POLICY

TapNaira Ltd

Effective Date: [Insert Date]
Company: TapNaira Ltd
Address: 10 Saleem Avenue, Asaba, Delta State, Nigeria
Contact Email: tapnaira01@gmail.com

1. Introduction

TapNaira Ltd (“TapNaira”, “we”, “our”, or “us”) respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you use the TapNaira mobile application, website, wallet, payment, bill payment, airtime, data, transfer, KYC, account tier upgrade, and other financial technology services.

By creating an account or using TapNaira, you agree to the collection and use of your information as described in this Privacy Policy.

2. Information We Collect

We may collect the following information from you:

Personal identification information: name, phone number, email address, date of birth, gender, residential address, occupation, and politically exposed person status.

KYC and verification information: BVN, NIN, government-issued ID, selfie/liveness image, proof of address, and other documents required for identity verification or tier upgrade.

Transaction information: wallet balance, deposits, withdrawals, transfers, bill payments, airtime/data purchases, transaction references, transaction status, beneficiaries, and payment history.

Device and security information: device type, IP address, device ID, login records, app activity, fraud-risk signals, and security logs.

Support and complaint information: messages, emails, call records, complaint details, dispute information, and documents you submit to our support team.

3. Why We Collect Your Information

We collect and process your information to:

1. Create and manage your TapNaira account.
2. Verify your identity and comply with KYC, AML, fraud prevention, and regulatory requirements.
3. Process wallet funding, transfers, withdrawals, airtime, data, bill payment, and other transactions.
4. Manage account tiers, transaction limits, and security checks.
5. Detect, prevent, and investigate fraud, unauthorized access, suspicious transactions, and misuse of our services.
6. Provide customer support and resolve complaints.
7. Improve our app, services, security, and user experience.
8. Send important service notices, security alerts, transaction notifications, and regulatory updates.
9. Comply with applicable Nigerian laws, CBN requirements, law enforcement requests, court orders, and obligations from our regulated banking/payment partners.

4. Legal Basis for Processing Your Data

We process your data based on one or more of the following:

1. Your consent.
2. Performance of our contract with you.
3. Compliance with legal and regulatory obligations.
4. Protection of your vital interests and security.
5. Our legitimate business interest, including fraud prevention, service improvement, and risk management.

You may withdraw consent where processing is based only on consent, but this may limit your ability to use some TapNaira services.

5. How We Share Your Information

We may share your information with:

1. Licensed banking, payment, KYC, identity verification, and financial service partners.
2. CBN-regulated service providers and payment processors.
3. NIBSS, BVN/NIN verification providers, billers, telcos, and transaction processors where needed.
4. Cloud hosting, SMS, email, analytics, fraud monitoring, and customer support providers.
5. Regulators, courts, law enforcement agencies, or government authorities where required by law.
6. Professional advisers, auditors, compliance consultants, and legal advisers.

We do not sell your personal data to advertisers or unauthorized third parties.

6. BVN, NIN, Government ID, and Liveness Data

BVN, NIN, government ID, selfie, and liveness information are collected only where required for identity verification, account security, compliance, fraud prevention, and account tier upgrades.

We may verify this information through approved verification providers or regulated financial service partners.

7. Data Security

We use reasonable administrative, technical, and organizational security measures to protect your personal information against unauthorized access, loss, misuse, alteration, or disclosure.

However, no electronic system is 100% secure. You are responsible for keeping your password, PIN, OTP, device, and login details confidential.

8. Data Retention

We keep your information for as long as necessary to provide our services, comply with legal, regulatory, accounting, audit, fraud prevention, and dispute resolution obligations.

Where your information is no longer required, we will delete, anonymize, or securely retain it as required by law.

9. Your Privacy Rights

Subject to applicable law, you may have the right to:

1. Request access to your personal data.
2. Request correction of inaccurate data.
3. Request deletion of your data where legally allowed.
4. Withdraw consent.
5. Object to certain processing.
6. Request restriction of processing.
7. Request data portability where applicable.
8. Lodge a complaint with the Nigeria Data Protection Commission or other relevant authority.

To exercise your rights, contact us at tapnaira01@gmail.com.

10. Marketing Messages

We may send you service-related messages, transaction alerts, security notices, and important updates.

We may send promotional messages only where allowed by law or where you have not opted out. You can opt out of marketing messages at any time, but you will still receive important account, security, and transaction notices.

11. Children’s Privacy

TapNaira is not intended for persons below 18 years old. By using TapNaira, you confirm that you are at least 18 years old and legally able to enter into this agreement.

12. Third-Party Services

TapNaira may contain links or integrations with third-party services such as payment processors, billers, telcos, identity verification providers, and banking partners.

We are not responsible for the privacy practices of third parties. Their own policies may apply when you use their services through TapNaira.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we make changes, we may notify you through the app, email, SMS, or other reasonable means.

Your continued use of TapNaira after an update means you accept the updated Privacy Policy.

14. Contact Us

For privacy questions, complaints, or data protection requests, contact:

TapNaira Ltd
10 Saleem Avenue, Asaba, Delta State, Nigeria
Email: tapnaira01@gmail.com