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1. Introduction

At SalyPay, your privacy and trust are our highest priority. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our services, including the SalyPay App, Saly AI Bot (WhatsApp, Telegram, iMessage, in-app), and our API Infrastructure for businesses.

By using our services, you consent to the practices described in this Policy.

2. Information We Collect

We collect information necessary to deliver our financial services safely and efficiently:

• Personal Identification Information: Full name, phone number, email, date of birth, gender, residential address.

• Government Identifiers: BVN, NIN, Passport/Driver’s License/ID card (for KYC).

• Financial Information: Bank account details, card details, transaction history, crypto wallet addresses.

• Device and Usage Data: IP address, device type, browser type, app usage statistics, location data (where consented).

• Chat & Interaction Data: Commands and interactions with Saly AI (e.g., “Send ₦200k to John”), which are securely logged for transaction execution and dispute resolution.

• Third-Party Data: Information retrieved through integrated APIs (e.g., Paystack, Fincra, Flutterwave, Bitnob, YellowCard, VTPass).

3. How We Use Your Information

Your information is used strictly for providing services and improving your experience:

• To verify your identity (KYC/AML compliance).

• To create and manage your SalyPay wallet and accounts.

• To process transfers, payments, crypto transactions, and bill payments.

• To generate receipts, statements, and transaction history.

• To power AI-driven financial insights, budgeting advice, and reminders.

• To comply with regulatory and legal requirements (CBN, NDPC, AML/CFT).

• To improve SalyPay’s features and personalize your experience.

4. Sharing of Information

We do not sell or rent your personal data. However, we may share your information under these circumstances:

• With Regulators: To comply with NDPC, CBN, EFCC, or court orders.

• With Service Providers: APIs (Paystack, Fincra, Flutterwave, Bitnob, YellowCard, VTPass) to execute transactions.

• With Business Partners: For merchant payments, card issuers, and cross-border remittance partners.

• With Your Consent: When you authorize sharing (e.g., linking a bank account via API).

  
  

All partners must comply with data protection laws (NDPR/GDPR).

5. Data Retention

• KYC data: Stored for 5 years after you close your account (per AML law).

• Transaction records: Stored for at least 7 years.

• Chatbot logs: Retained for 3 years, unless tied to disputes.

• After expiry, records are securely deleted.

6. Security of Data

We adopt bank-level security protocols to safeguard your data:

• AES-256 encryption for storage.

• SSL/TLS encryption for all communication.

• Role-based access control and multi-factor authentication.

• Daily data backups and quarterly recovery testing.

• Continuous monitoring for fraud and suspicious activity.

  
  

Despite our efforts, no system is 100% secure. Users must also protect their accounts (PINs, passwords).

7. Your Rights

As a SalyPay user, you have rights under NDPR and GDPR:

• Right to Access: Request a copy of your data.

• Right to Rectification: Correct inaccurate or incomplete data.

• Right to Erasure: Request deletion where legally possible.

• Right to Restrict Processing: Limit how your data is used.

• Right to Data Portability: Request transfer of your data to another provider.

• Right to Withdraw Consent: Opt out of data use (e.g., marketing).

  
  

Requests can be made to our Data Protection Officer (DPO) at: dpo@salypay.com.

8. Cookies & Tracking

If you access SalyPay via web, we may use cookies to:

• Improve site performance.

• Remember user preferences.

• Track anonymized usage patterns.

  You may disable cookies in your browser, though some features may not work.

9. Cross-Border Data Transfers

Where services require, we may transfer your data outside Nigeria. In such cases, we ensure compliance with NDPR adequacy principles and international data protection safeguards.

10. Children’s Data

SalyPay services are not intended for minors under 18. We do not knowingly collect data from children.

11. Changes to this Policy

We may update this Privacy Policy from time to time. Significant changes will be notified to users via in-app alerts, email, or SMS.

12. Contact Us

For questions, requests, or complaints, contact:

Data Protection Officer (DPO)
Saly App Nigeria Limited
📍 Address: No 2 Aliade CL. Garki 2, FCT
📧 Email: dpo@salypay.com, info@salypay.com
📞 Phone: +2348145313661

13. Certification

This Privacy Policy was approved by the Board of Directors of Saly App Nigeria Limited on 31st August, 2025 and is binding on all staff and stakeholders.