Data Privacy Policy

Your privacy is our priority. Learn how we protect and use your data.

Version 1.0Last Updated: October 2024Next Review: October 2027

Background

Xchange Box Solutions Ltd and its affiliate companies (together "Xchange Box Solutions Ltd" or "We" or "Our") are totally committed to protecting and respecting the privacy of our customers and agents.

When you sign up and use Xchange Box Solutions Ltd services, you accept the terms described within this agreement. We will not share your personal information with anyone except as described in this Privacy policy.

This Privacy Policy is intended to meet our obligations under the Nigeria Data Protection Act (NDPA), a legal framework that sets guidelines for the protection and processing of personal information of individuals within the Federal Republic of Nigeria.

Who We Are and How to Contact Us

Xchange Box Solutions Ltd is a FinTech company dedicated to supporting rural SMEs by providing them with access to credit and digitized transaction records. Our platform, PayRep, uses low-end technology to enable credit access, repayments, and collections, while also generating empirical transaction records. This approach supports sustainable growth for businesses in rural communities.

Your Rights Relating to Personal Data

You have the following rights under this Privacy Policy:

Request access to your personal data

Receive a copy of the personal data we hold about you and check that we are lawfully processing it.

Request correction

Have any incorrect or incomplete information about you corrected.

Request erasure

Ask us to delete or remove personal data where there is no good reason for us continuing to process it.

Object to processing

Object to processing of your personal data where we are relying on a legitimate interest.

Request restriction

Ask us to suspend the processing of personal data about you.

Request transfer

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

Withdraw consent

Withdraw your consent at any time where we are relying on consent to process your personal data.

What Personal Data We Collect

1. Customer Information

To use the Xchange Box Solutions Ltd Services, you must provide customer information via our registration, wallet upgrade or profile forms. This includes:

  • Full name, email address, phone number, address, gender, date of birth
  • Bank Verification Number (BVN), ID documentation and photograph (where applicable)
  • Communication records with our Customer Services team

2. Device Information

The following information may be collected automatically when you use our mobile app:

  • Device details, unique identifiers (IMEI or serial number), SIM card information
  • Mobile network, operating system and browser settings

3. Location Information

Certain features may require location information from your device's GPS. With your consent, this information will be collected for these services. You can turn off location services, though some features may become unavailable.

4. Analytics & Tracking

We use in-app analytics technologies like Google Analytics to help improve and simplify the overall app design and service. We also use cookies to identify and track visitors and their usage patterns.

How We Use Your Personal Data

We collect and use your personal data only where we have lawful bases. The lawful basis depends on the services you use and how you use them:

Service Delivery

To provide you the services, including operating the platform, customer support, and personalized features.

Payment Processing

To process payments and share necessary information with transaction parties (excluding full card/account numbers).

Identity Verification

To comply with financial regulations and prevent fraud.

Legitimate Interests

For research and development, marketing, and protecting our legal rights.

Legal Compliance

To comply with legal or regulatory obligations.

How We Protect Your Personal Data

Xchange Box Solutions Ltd is entirely committed to protecting the information we collect from you. We maintain appropriate administrative, technical and physical safeguards designed to prevent accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use of your information.

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Data Encryption

End-to-end encryption for all sensitive data

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Firewalls

Advanced firewall protection for our systems

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Security Guards

Physical security at our facilities

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Access Control

Strict access controls and authentication

Data Retention

We retain your information for as long as your account is active or as reasonably needed for the purposes outlined in this policy. We are required to retain transaction details for the period mandated under financial regulations.

Your Responsibilities

Important Security Notice

You are responsible for the protection of your password or PIN. You must not share your credentials with anyone.

We will never request for your PIN or password via email, SMS, or any other means. If you receive such communication, please disregard and contact us immediately.

If you believe your password or PIN has been compromised, please change it immediately and contact us.

Contact & Complaints

Questions or Concerns?

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

Filing a Complaint

If you would like to submit a complaint regarding this Privacy Policy or our practices, please contact us. We endeavor to reply to complaints as soon as possible. If you feel your complaint has not been adequately resolved, the NDPA gives you the right to contact the National Information Technology Development Agency (NITDA).

Changes to this Privacy Policy

Xchange Box Solutions Ltd may change its Privacy Policy from time to time, at our sole discretion. We will notify you when changes have been made. By continuing to use the mobile application or website after the change, you agree to accept the new policy.

Have Questions About Your Privacy?

Our team is here to help you understand how we protect your data

Contact Us