Privacy Policy

1. Overview

Folaa Technologies Ltd ("Folaa," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you use our website, mobile application, and related services (collectively, the "Services").

By accessing or using our Services, you agree to the collection and use of information in accordance with this policy. If you do not agree with this policy, please do not use our Services.

This policy is designed to comply with the Nigeria Data Protection Regulation (NDPR), the Nigeria Data Protection Act 2023, and other applicable data protection laws.

2. Information We Collect

We collect several types of information to provide and improve our Services:

2.1 Personal Information

When you register for an account or use our Services, we may collect:

• Identity Data: Full name, date of birth, gender, nationality, and government-issued ID (NIN, driver's license, or international passport).
• Contact Data: Email address, phone number, residential address, and emergency contact information.
• Financial Data: Bank account details, BVN (Bank Verification Number), transaction history, wallet balances, and payment card information.
• Biometric Data: Facial recognition data and fingerprints used for authentication and liveness detection (with your explicit consent).
• KYC Documents: Selfie photographs, utility bills, and other documents required for identity verification.

2.2 Technical Information

When you access our Services, we automatically collect:

• Device Information: Device type, operating system, unique device identifiers, IP address, browser type, and mobile network information.
• Usage Data: Pages visited, time spent on pages, click patterns, features used, and error logs.
• Location Data: Approximate geographic location derived from your IP address or GPS (with your permission).

2.3 Transaction Information

For every transaction you conduct, we collect:

• Transaction amount, date, time, and type (airtime, data, bill payment, crypto swap, etc.).
• Recipient details (phone numbers, meter numbers, bank accounts, crypto wallet addresses).
• Blockchain transaction hashes for cryptocurrency transfers.
• Transaction status, failure reasons, and refund records.

3. How We Use Your Information

We use the information we collect for the following purposes:

• 1Service Provision: To process your transactions, maintain your wallet, enable VTU services, process bill payments, and execute cryptocurrency swaps.
• 2Identity Verification: To verify your identity, comply with KYC/AML regulations, prevent fraud, and ensure regulatory compliance.
• 3Security: To detect, prevent, and investigate fraudulent, unauthorized, or illegal activities; to protect our systems and users.
• 4Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• 5Communication: To send you service updates, transaction confirmations, security alerts, and promotional materials (with your consent).
• 6Product Improvement: To analyze usage patterns, troubleshoot issues, and develop new features and services.
• 7Legal Compliance: To comply with applicable laws, regulations, court orders, and requests from law enforcement or regulatory authorities.

4. Information Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

4.1 Service Providers

We share information with trusted third-party service providers who assist us in operating our Services, including:

• Payment processors and banking partners (CBN-licensed).
• Identity verification and KYC service providers.
• Cloud hosting and data storage providers.
• Customer support and analytics platforms.
• Cryptocurrency liquidity providers and exchange partners.

All service providers are contractually bound to use your information only for the purposes we specify and to maintain appropriate security measures.

4.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities, including:

• Law enforcement agencies investigating criminal activity.
• Regulatory bodies such as the Central Bank of Nigeria (CBN), EFCC, or Nigeria Data Protection Commission (NDPC).
• Court orders, subpoenas, or other legal processes.

4.3 Business Transfers

If Folaa is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you before your information is transferred and becomes subject to a different privacy policy.

4.4 With Your Consent

We may share your information with third parties when you explicitly authorize us to do so.

5. Data Security

We implement comprehensive security measures to protect your personal information:

• 1Encryption: All data in transit is protected using TLS 1.3 encryption. Data at rest is encrypted using AES-256.
• 2Access Controls: Role-based access controls, multi-factor authentication, and strict internal data access policies.
• 3Security Monitoring: 24/7 security operations center, intrusion detection systems, and regular vulnerability assessments.
• 4Secure Infrastructure: Data stored in SOC 2 Type II certified data centers with physical security controls.
• 5Regular Audits: Annual third-party security audits and penetration testing.

Despite our efforts, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law:

• Account Information: Retained for the duration of your account plus 7 years after account closure (to comply with financial regulations).
• Transaction Records: Retained for a minimum of 7 years as required by CBN and anti-money laundering regulations.
• KYC Documents: Retained for 7 years after account closure or as required by regulatory authorities.
• Communication Records: Retained for 3 years for customer service and dispute resolution purposes.
• Technical Logs: Retained for 12 months for security and troubleshooting purposes.

After the retention period expires, your personal information is securely deleted or anonymized in accordance with our data destruction procedures.

7. Your Data Protection Rights

Under the Nigeria Data Protection Regulation (NDPR) and the Nigeria Data Protection Act 2023, you have the following rights:

• 1Right to Access: You have the right to request copies of your personal information.
• 2Right to Rectification: You have the right to request correction of inaccurate or incomplete information.
• 3Right to Erasure: You have the right to request deletion of your personal information, subject to legal retention requirements.
• 4Right to Restrict Processing: You have the right to request that we restrict processing of your information.
• 5Right to Data Portability: You have the right to receive your information in a structured, machine-readable format.
• 6Right to Object: You have the right to object to processing based on legitimate interests or direct marketing.
• 7Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time.

To exercise any of these rights, please contact us at privacy@Folaa.ng. We will respond to your request within 30 days.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our platform:

• Essential Cookies: Required for the operation of our Services (e.g., authentication, security).
• Functional Cookies: Enable enhanced functionality and personalization (e.g., language preferences).
• Analytics Cookies: Help us understand how visitors interact with our website (e.g., Google Analytics).
• Marketing Cookies: Used to deliver relevant advertisements and measure campaign effectiveness.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of our Services.

9. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at privacy@Folaa.ng. If we become aware that we have collected personal information from a child under 18 without parental consent, we will take steps to delete that information.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service offerings. When we make material changes, we will:

• Notify you via email or in-app notification at least 14 days before the changes take effect.
• Update the "Last updated" date at the top of this policy.
• Post a prominent notice on our website and mobile application.

Your continued use of our Services after the effective date of the updated policy constitutes your acceptance of the changes.

11. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe we have violated your data protection rights.