PRIVACY
POLICY

1. Introduction

The Numoie platform ("Numoie", "we", "us"), is committed to protecting the personal data of its Users in accordance with the Nigeria Data Protection Act 2023 ("NDPA") and applicable regulations issued by the Nigeria Data Protection Commission ("NDPC"). This Privacy Policy explains what personal data we collect, why, how we use it, and the rights available to you.

2. Data Controller

Contact for data protection matters: dpo@numoie.com.

3. What Personal Data We Collect

• Identity data: full name, date of birth, national ID or passport number, where required for account tiering or KYC verification.
• Contact data: email address, phone number, residential or mailing address.
• Financial data: wallet transaction history, payment card or bank details processed via our payment gateway partners. Numoie does not itself store full card numbers.
• Usage data: device information, IP address, log in timestamps, session activity, and app usage patterns collected for security and service improvement.
• Communications data: support tickets, correspondence, and any information you provide when contacting Numoie.

4. How We Collect Personal Data

• Directly from you, when you register, complete KYC verification, make a purchase, or contact support.
• Automatically, through cookies, device identifiers, and similar technologies (see Section 11).
• From third parties, including identity verification providers, payment gateways, and (where legally permitted) fraud-prevention and sanctions-screening services.

5. Legal Basis for Processing

Under the NDPA, we process personal data on the basis of: (a) performance of a contract with you (providing the services you request); (b) compliance with a legal obligation (including AML/KYC requirements under the Money Laundering (Prevention and Prohibition) Act 2022 and CBN regulations); (c) legitimate interests (fraud prevention, service security, and improvement), balanced against your rights and interests; and (d) consent, where required, for optional features such as marketing communications.

6. How We Use Personal Data

• To create and administer your account, process transactions, and deliver purchased services.
• To verify your identity and comply with AML/KYC obligations, as set out in our AML/KYC Procedure.
• To detect, investigate, and prevent fraud, abuse, and unauthorised access.
• To communicate with you about your account, transactions, and (with consent, where required) promotional offers.
• To comply with legal and regulatory obligations, including responding to lawful requests from Nigerian authorities.

7. Data Sharing

• Payment processors: to process wallet funding and payments.
• API service providers: to the extent necessary to deliver virtual number and bill payment services.
• Regulatory and law enforcement authorities: where required by law, including under AML/KYC reporting obligations to the Nigerian Financial Intelligence Unit (NFIU).
• Professional advisers: including auditors and legal counsel, under confidentiality obligations.

Numoie does not sell personal data to third parties for their own marketing purposes.

8. Data Retention

• Account and transaction data is retained for as long as your account is active, and thereafter as required by Nigerian law, including a minimum 5 year retention period for KYC records following account closure, in line with AML/CFT record keeping obligations.
• Data no longer required for legal or operational purposes will be securely deleted or anonymised.

9. International Data Transfers

Where personal data of Nigerian residents is processed or stored outside Nigeria (for example, via cloud infrastructure providers), the NDPA requires that such transfers occur only to jurisdictions the NDPC has designated as providing adequate data protection, or subject to appropriate safeguards (such as standard contractual clauses) approved under NDPA guidance.

10. Data Security

Numoie applies technical and organisational measures appropriate to the sensitivity of the data processed, including encryption in transit, two-factor authentication, active session monitoring, and remote session revocation. No system is completely secure, and Numoie cannot guarantee absolute security of data transmitted over the internet.

11. Cookies & Tracking Technologies

The Platform uses cookies and similar technologies for authentication, security, and analytics purposes.

12. Your Rights Under the NDPA

• Right to be informed about how your data is processed.
• Right to access a copy of the personal data Numoie holds about you.
• Right to rectification of inaccurate or incomplete data.
• Right to erasure, subject to legal retention obligations (including AML/KYC record-keeping requirements).
• Right to restrict or object to certain processing, including direct marketing.
• Right to data portability, where technically feasible.
• Right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

Requests can be made to compliance@numoie.com. Numoie will respond within the timeframe prescribed by the NDPA and applicable NDPC guidance.

13. Children's Data

The Platform is not directed at, and Numoie does not knowingly collect personal data from, individuals under 18 years of age. If we become aware that we have inadvertently collected data from a minor, we will take steps to delete it.

14. Data Breach Notification

In the event of a personal data breach likely to result in a risk to your rights and freedoms, Numoie will notify the NDPC and affected Users within the timeframes required under the NDPA and applicable regulations.

15. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified to Users via email or in-app notification at least 7 days before taking effect.

16. Contact & Complaints

For privacy-related questions or to exercise your rights, contact compliance@numoie.com.