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Legal

Privacy Policy

Effective date: January 1, 2024  ·  Last updated: May 1, 2024

Payve Technologies Ltd ("Payve", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and safeguard information about you when you use our website, platform, and services.

1. Information We Collect

1.1 Account and Identity Information

When you register for a Payve account, we collect information to verify your identity and comply with applicable know-your-customer (KYC) and know-your-business (KYB) regulations. This includes:

  • Full legal name, date of birth, and nationality (for individual account holders)
  • Business name, registration number, registered address, and business type (for business accounts)
  • Government-issued identification documents (National ID, passport, driver's licence)
  • Proof of address (utility bills, bank statements)
  • Beneficial ownership information for corporate entities
  • Business activity descriptions and expected transaction volumes
  • Email address, phone number, and login credentials

1.2 Transaction and Financial Data

In the course of providing payment services, we collect and process:

  • Payment transaction details: amounts, currencies, timestamps, reference numbers
  • Sender and beneficiary information (name, bank account, mobile money number)
  • FX conversion rates, fees charged, and net amounts disbursed
  • Wallet balances and transaction history
  • Payout and collection records
  • API request logs associated with financial operations

1.3 Technical and Usage Data

When you access the Payve platform or use our API, we automatically collect:

  • IP address and approximate geographic location
  • Device identifiers, operating system, and browser type
  • API key identifiers (never the key secret itself)
  • Request and response logs (excluding sensitive financial data beyond metadata)
  • Error logs and performance data
  • Pages visited, features used, and session duration
  • Referral URLs and marketing attribution data

1.4 Communications Data

We retain records of communications you have with our support, compliance, and sales teams, including emails, chat transcripts, and call recordings (where permitted and disclosed).

2. How We Use Your Information

We use the information we collect for the following purposes:

Service provision and account management

To create and maintain your account, process transactions, generate reports, and provide the core Payve payment services you have contracted for.

Regulatory compliance and fraud prevention

To verify your identity, screen transactions against sanctions lists, monitor for suspicious activity, comply with AML (Anti-Money Laundering), CFT (Counter-Financing of Terrorism) obligations, and fulfil reporting requirements to regulators including the CBN, Bank of Ghana, and Central Bank of Kenya.

Security and integrity

To detect, investigate, and prevent fraud, unauthorized access, abuse of our platform, and other security threats. To audit API access and protect the integrity of the financial system.

Product improvement and analytics

To understand how merchants and developers use our platform, identify areas for improvement, prioritize features, and measure the performance of our services. We use aggregated and anonymized data wherever possible for analytics.

Communications and marketing

To send you transactional notifications (payment confirmations, webhook alerts, account alerts), product updates, and — where you have opted in — marketing communications about Payve products and services. You may opt out of marketing communications at any time.

Legal obligations

To comply with applicable laws and regulations, respond to lawful requests from courts and regulatory authorities, enforce our Terms of Service, and protect our legal rights.

3. Information Sharing

We do not sell your personal data. We share information only in the following limited circumstances:

  • Banking and payment partners

    We share transaction data with licensed banks, mobile money operators, and payment processors that are necessary to execute payments on your behalf. These parties are bound by confidentiality agreements and regulatory obligations.

  • Regulators and law enforcement

    We may disclose information to the Central Bank of Nigeria, Financial Intelligence Unit, or other regulators as required by law, and to law enforcement in response to valid legal process.

  • Identity verification providers

    We share KYC/KYB data with licensed identity verification providers (such as Smile ID or Dojah) to verify the identities of account holders as required by AML regulations.

  • Infrastructure and technology providers

    We use cloud infrastructure, monitoring, and operational tooling providers (e.g., AWS, Datadog) who process data on our behalf under data processing agreements that require them to protect your data.

  • Professional advisors

    We may share information with lawyers, auditors, and accountants under duties of confidentiality in the course of legitimate professional services.

  • Business transfers

    In the event of a merger, acquisition, or sale of all or part of Payve, your information may be transferred as part of that transaction, subject to the same privacy protections.

4. Data Security

We implement industry-leading security measures to protect your data:

  • AES-256 encryption for all data at rest
  • TLS 1.3 encryption for all data in transit
  • Role-based access control limiting internal access to only what is necessary
  • Multi-factor authentication required for all staff accessing production systems
  • Regular penetration testing conducted by third-party security firms
  • Continuous monitoring and anomaly detection
  • SOC 2 Type II audit (in progress)

Despite these measures, no system is completely secure. If you believe your account has been compromised, contact us immediately at security@payve.com.

5. Data Retention

We retain your data for as long as necessary to provide our services and comply with legal obligations:

  • Account and KYC data: Retained for a minimum of 7 years after account closure, as required by Nigerian AML regulations and CBN guidelines.
  • Transaction records: Retained for 7 years from the date of the transaction.
  • API and system logs: Retained for 90 days for operational purposes; summarized audit logs retained for 2 years.
  • Marketing data: Retained until you opt out or we determine the data is no longer needed for its original purpose.
  • Support records: Retained for 3 years after the last interaction.

6. Your Rights

Subject to applicable law — including the Nigeria Data Protection Act 2023 (NDPA) and, where applicable, the EU General Data Protection Regulation (GDPR) — you have the following rights:

Right of access

Request a copy of the personal data we hold about you.

Right to rectification

Request correction of inaccurate or incomplete data.

Right to erasure

Request deletion of your data, subject to legal retention obligations.

Right to restriction

Request that we restrict processing in certain circumstances.

Right to portability

Receive your data in a structured, machine-readable format.

Right to object

Object to processing based on legitimate interests or for direct marketing.

Right to withdraw consent

Withdraw consent for processing where consent was the legal basis.

Right to lodge a complaint

Complain to the Nigerian Data Protection Commission (NDPC) or relevant supervisory authority.

To exercise any of these rights, email privacy@payve.com. We will respond within 30 days. Note that certain rights may be limited where we are required to retain data by law or where deletion would impair our ability to comply with regulatory obligations.

7. Cookies

We use cookies and similar technologies on our website and dashboard for the following purposes:

  • Strictly necessary cookies

    Session management, authentication tokens, and CSRF protection. These cannot be disabled.

  • Analytics cookies

    We use privacy-preserving analytics (e.g., Plausible Analytics) to understand traffic patterns without tracking individuals across websites.

  • Preference cookies

    Remembering your settings such as language preference and dashboard layout.

8. International Data Transfers

Payve is headquartered in Nigeria and operates across multiple African countries. Where we transfer data outside Nigeria, we do so in compliance with the NDPA 2023 and applicable cross-border data transfer frameworks.

Where data is transferred to service providers in countries outside Africa (for example, cloud infrastructure in the EU or US), we ensure appropriate safeguards are in place, including standard contractual clauses, processor agreements, and where relevant, adequacy decisions. Data processed in the EU is subject to GDPR protections.

9. Contact Us

If you have questions about this Privacy Policy or how we handle your data, please contact our Data Protection Officer:

Payve Technologies Ltd — Data Protection Officer

14 Kofo Abayomi Street, Victoria Island, Lagos 101241, Nigeria

Email: privacy@payve.com

We may update this Privacy Policy from time to time. Material changes will be communicated by email to account holders and by posting a prominent notice on our website at least 30 days before the changes take effect.