Privacy Policy
1. Consent
You, as a user or visitor, accept this privacy policy when you give consent upon access to our platforms, or use the services offered on our website and/or application.
2. Which of your Personal Data do we collect?
We collect Personal Data about you when you use the services offered on our website and digital platform, including the following:
2.1 Sign-up and identity verification information
When you register as an agent, we collect the Personal Data needed to on-board you and to meet our know-your-customer (KYC) obligations. This includes your name, email address, mobile phone number, date of birth and gender; your Bank Verification Number (BVN) and/or National Identification Number (NIN); a selfie photo and short liveness check used to confirm you are physically present and match your ID; identity documents; your residential and business address together with proof of address (such as a utility bill, bank statement or tenancy agreement); and, for business accounts, business details such as your business name and RC number. We may ask for additional details as you use our services.
2.2 Transaction information
When you use our digital platform to send and receive money, on-board agents, pay bills, and deposit and withdraw cash, we collect information associated with the transaction such as the amount sent or received, amounts paid for products or services, agent information and, sometimes, information about your device and location.
2.3 Participant Personal Data
When you use our services, we collect Personal Data about the other participants associated with the transaction, such as the name and financial account information of the person receiving money from you or sending money to you.
2.4 Information from other sources
We may collect information from other sources, such as our social media platforms when you reach out to us to lodge a complaint about our services. We will only ask for information required to help us be of service to you. To verify your identity, we receive identity information linked to your BVN or NIN from licensed verification providers.
2.5 Other information related to your use of our services
We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.
3. App permissions and device data
The app asks for the following permissions only when a feature needs them. You can refuse or withdraw a permission in your device settings; the related feature may then be unavailable.
- Camera and microphone: to take your selfie and run the liveness check during identity verification, and to photograph documents you upload.
- Photos and files: to let you upload identity and proof-of-address documents you choose.
- Location: to check where transactions take place, for transaction security and fraud prevention.
- Contacts: to help you fill in a phone number. We do not upload your contact list.
- Fingerprint / Face ID: if you turn on biometric login, your fingerprint or face is checked by your phone's operating system. We never receive or store your biometric data. Your login details are kept in your device's secure storage (Keychain on iOS, Keystore on Android).
- Notifications: a push-notification token so we can send you transaction and account alerts.
- Device information: device identifiers, IP address and app version, used to secure your account, detect fraud and support POS terminals linked to your account.
4. How do we retain Personal Data?
We retain Personal Data in a recognisable format for business purposes and to fulfil our legal and regulatory obligations, including record-keeping requirements that apply to financial services in Nigeria. There are situations when we may retain Personal Data for longer periods if it is in our legitimate business interests and to comply with applicable laws. We will use and disclose such Personal Data in accordance with this Privacy Policy.
5. What do we do with your Personal Data?
Your Personal Data is collected to provide you with a quick and secure experience. We process your information to:
- make transactions: send or request money, or pay a bill;
- verify your identity and authenticate access to your account;
- communicate with you about your account;
- manage risk and protect you from fraud;
- comply with our legal and regulatory obligations and enforce the terms of our services;
- detect and remediate information breaches; and
- resolve disputes and troubleshoot problems.
With your consent, we may also market Payrail Agency products and services to you and send you product communications by SMS or email. You can withdraw your consent at any time, at no cost.
6. Sharing your Personal Data
We do not sell your Personal Data. We may share your Personal Data or other information about you for the following reasons:
6.1 With service providers
Payrail Agency may share Personal Data with third-party service providers that perform services on our behalf, such as identity verification and liveness checks, transaction and bill-payment processing, cloud hosting, push notifications and customer support.
6.2 With partner financial institutions
We may share Personal Data with financial institutions that partner with us to provide our services, including to open and operate your account, process transactions and keep your financial information up to date.
6.3 With other parties to your transactions
When you send or receive funds, we share the Personal Data and account information necessary to complete the transaction, and to help resolve disputes and detect and prevent fraud.
6.4 For legal and business purposes
- to comply with a law, legal process or regulation, including requests from law enforcement or regulators;
- where we believe disclosure is necessary to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity;
- with credit agencies and data processors for credit reference, anti-fraud and compliance checks;
- to investigate violations of or enforce our user agreement, and to protect our property, services and legal rights;
- in connection with a sale of all or part of Payrail Agency's business; and
- to support our audit, compliance and corporate governance functions.
6.5 With your consent
We will also share your Personal Data with your consent or at your direction.
7. Cookies
Our website uses encrypted session cookies to keep track of your activity for the duration of a session. They are erased after a set timeout or once you log out and close the browser. Some parts of the website may not work if you do not accept these cookies. The mobile app does not use advertising cookies.
8. Your rights
Subject to applicable law, you have the right to:
- Access the Personal Data we hold about you and receive a copy, together with information about how we use and share it;
- Rectify inaccurate or incomplete Personal Data;
- Erase your Personal Data where it is no longer needed, was unlawfully processed, or you withdraw consent, except where we must keep it to comply with the law or to establish, exercise or defend legal claims;
- Object to processing based on our legitimate interests, including profiling and direct marketing;
- Restrict processing while a dispute about your data is resolved;
- Portability: receive the Personal Data you provided to us in a structured, machine-readable format; and
- Object to automated decisions that significantly affect you, except where permitted by law or based on your explicit consent.
To exercise any of these rights, contact us using the details in section 13.
9. Deleting your account
You can delete your account at any time in the app: More → Security Settings → Delete Account. You can also ask us to delete your account and data by emailing us from the email address on your account (see section 13).
When your account is deleted we remove your Personal Data, except information we are legally required to keep, such as transaction and KYC records that financial regulations require us to retain for a set period. That information is kept securely and deleted when the retention period ends.
10. How do we protect your Personal Data?
We maintain technical, physical and administrative security measures designed to protect your Personal Data against loss, misuse, unauthorised access, disclosure and alteration. These include encryption of data in transit, encryption of sensitive payloads, firewalls, access controls and secure on-device storage. You are responsible for keeping your password, PIN and device secure. We will inform you of any breach that may affect your Personal Data.
11. Children
Our services are intended for adults aged 18 and over. We do not knowingly collect Personal Data from children.
12. Remedies, governing law and review
If this policy is violated, our Data Protection Officer will redress the violation within a week. Where the violation involves disclosure of your Personal Data without your consent, the information will be retracted immediately and confirmation sent to you within 48 hours of the redress.
This Privacy Policy is made in accordance with the Nigeria Data Protection Act 2023, the Nigeria Data Protection Regulation and other applicable Nigerian laws. We review it at least once a year, and whenever our services or regulatory requirements change, and will communicate updates through our website, social media and the app.
13. Contact us
For questions about this Privacy Policy, how your Personal Data is used, or to exercise your rights or request deletion, contact:
Payrail Agency Limited
Layi Yusuf Crescent, Lekki Phase 1, Lagos, Nigeria
Email: support@payrail.com