Privacy Policy

1. Introduction

Phiters Global Tech Limited ("we", "us", "our") operates the PhitersPay mobile application. This Privacy Policy outlines our practices regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

2. Information Collection and Use

To provide a secure financial experience, we collect several different types of information for various purposes:

• Personal Identification Information: Name, email address, phone number, and physical address.
• KYC and Financial Data: In compliance with Central Bank of Nigeria (CBN) regulations, we collect your Bank Verification Number (BVN) and bank account details. This is used strictly for identity verification and to prevent fraudulent activities.
• Data Retrieved via Third-Party Services (Mono): With your explicit consent, we may retrieve financial account information (balance, history) and identity verification data (Mono Prove) through our technical partner, Mono Technologies Nig. Limited. This data is used solely to verify your identity and assess eligibility for certain financial products.
• Transaction Records: History of payments, wallet funding, and utility purchases.
• Device and Technical Data: IP address, device ID, operating system, and app usage statistics to improve security and app performance.

3. Purpose and Lawful Basis for Processing

We process your personal data in accordance with the Nigeria Data Protection Act (NDPA) 2023 based on the following legal grounds:

• Forming and Performing a Contract: To facilitate secure financial transactions, wallet management, and product fulfillment.
• Legal Obligation: To verify your identity in accordance with Anti-Money Laundering (AML) and Know Your Customer (KYC) laws (e.g., CBN directives).
• Consent: When you explicitly authorize us to link your bank accounts through third-party services like Mono.
• Legitimate Interests: To monitor for fraudulent or suspicious activity and to improve our service security.

4. Data Sharing and Disclosure

We do not sell your personal data. To provide banking and payment services, we share necessary data with the following licensed partners:

We may also disclose data if required by law or in response to valid requests by public authorities (e.g., a court or government agency).

5. Data Security and Encryption

The security of your data is our highest priority.

• Encryption: All sensitive data, including BVNs and transaction details, is transmitted via 256-bit SSL encryption and stored using industry-standard AES encryption at rest.
• Access Control: Access to your personal data is restricted to authorized employees and partners who need the information to perform specific tasks.

6. Data Retention and Deletion

We retain your personal information only for as long as is necessary for the purposes set out in this policy and as required by Nigeria’s financial regulations (typically 5 to 7 years for KYC/AML records).

Disposal: Once the retention period expires, or upon a valid request for erasure where no legal retention requirement exists, your data will be securely deleted or anonymized to prevent further identification.

Account Deletion: Users may request account deletion at any time through the app settings or by visiting our Account Deletion Request Page.

7. Your Rights Under NDPA 2023

Under the Nigeria Data Protection Act (NDPA) 2023, you have the following rights as a data subject:

• Right to be Informed: To know how we collect and use your data.
• Right of Access: To request copies of the data we hold about you.
• Right to Rectification: To correct inaccurate or incomplete information.
• Right to Erasure ("Right to be Forgotten"): To request deletion of your data when legal reasons for its retention have expired.
• Right to Data Portability: To request the transfer of your data to another service in a machine-readable format.
• Right to Withdraw Consent: To withdraw your consent at any time for data processed based on your authorization (e.g., Mono account linking).

You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your rights have been infringed.