Privacy Policy

At ValourPay, we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your data when interacting with our platform, including our services, website, and API. Our policy is designed to comply with global data protection laws, including the General Data Protection Regulation (GDPR) and the Nigeria Data Protection Regulation (NDPR).

By using our platform, you agree to the collection and use of your information per this policy. We encourage you to read this document carefully to understand our practices.

Information We Collect

We collect personal and non-personal information to provide, enhance, and secure our services. Information is collected in the following ways:

Personal Information

Personal data includes information that can be used to identify you, such as:

• Identity Data: Full name, date of birth, gender, and identification documents (e.g., passport, national ID) for Know Your Customer (KYC) compliance.
• Contact Information: Email address, phone number, and physical address.
• Financial Data: Payment details, bank account numbers, or cryptocurrency wallet addresses used to process your transactions.
• Verification Data: Tax identification numbers, proof of residency, or any other documentation required for identity verification.

Non-Personal Information

We collect non identifiable data automatically, such as:

• Technical Data: IP addresses, browser type, device information, operating system, time zone, and other device-specific data.
• Usage Data: Data about how you interact with our platform, such as page visits, duration of sessions, and clicks.

Sensitive Data

We do not typically collect sensitive data such as health information or religious beliefs. However, if any sensitive data is collected, it will be done with explicit consent and processed in compliance with applicable laws.

Legal Basis for Processing Your Data

In compliance with GDPR and NDPR, we process your data based on the following legal grounds:

• Consent: When you voluntarily provide us with your personal information, you consent to its processing for the purposes outlined in this policy.
• Contractual Necessity: We process your data to fulfill our obligations under any contract you have with us, such as providing our services.
• Legal Obligation: We may process your data to comply with legal or regulatory obligations, including KYC and antimoney laundering (AML) requirements.
• Legitimate Interest: We may process your data for legitimate interests, such as improving our services, preventing fraud, or securing our platform.

How We Use Your Information

We use the personal information we collect for the following purposes:

• Service Delivery: To provide you with access to our platform, including processing transactions and executing currency swaps.
• Identity Verification: To comply with regulatory obligations, such as KYC and AML regulations.
• Customer Support: To communicate with you, address your queries, and resolve any issues with your account.
• Security and Fraud Prevention: To ensure the security of our platform and protect against fraud or malicious activities.
• Improvement of Services: To analyze and improve our platform’s functionality, including through the use of data analytics.
• Legal Compliance: To comply with all applicable laws, court orders, and regulatory requirements.

Data Sharing and ThirdParty Disclosure

We do not sell or rent your personal data to third parties. However, we may share your information under the following circumstances:

Service Providers

We may share your data with trusted third-party service providers that assist us in delivering our services. This includes payment processors, KYC verification partners, cloud storage providers, and cybersecurity firms. All service providers are required to process your data per our privacy policy and applicable data protection regulations.

Regulatory Authorities

Per GDPR, NDPR, and other applicable laws, we may share your personal information with law enforcement or other governmental bodies when required:

• To comply with a legal obligation, court order, or governmental request.
• To prevent or investigate fraud or other illegal activities.

Business Transfers

In the event of a merger, acquisition, or asset sale, your personal data may be transferred as part of the transaction. You will be notified of any such change in ownership or control.

International Data Transfers

Due to the global nature of our business, your personal data may be transferred to and processed in countries outside of your jurisdiction. When we transfer your data internationally, we ensure that:

• The receiving country has adequate data protection laws that meet the standards of GDPR or NDPR, or;
• We implement adequate safeguards, such as Standard Contractual Clauses (SCCs), to protect your personal information.

Data Security

We take your privacy and the security of your personal data very seriously. We use industry-standard security measures, including encryption, firewalls, and access controls, to protect your data. While we strive to protect your information, no online platform is entirely secure. We encourage you to take precautions such as using strong passwords and keeping your account information confidential.

Your Data Protection Rights

Under GDPR and NDPR, you have the following rights concerning your personal data:

• Right to Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You have the right to request corrections to any inaccurate or incomplete information.
• Right to Erasure: You can request that we delete your personal data, subject to legal and contractual obligations.
• Right to Restriction: You can request that we limit how we process your personal data.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used format and transfer it to another provider.
• Right to Object: You may object to our processing of your data based on legitimate interests or direct marketing.
• Right to Withdraw Consent: If we process your data based on your consent, you can withdraw your consent at any time.

To exercise any of these rights, please contact us at legal@valourpay.com. We will respond to your request within 30 days in accordance with applicable regulations.

Retention of Your Information

We retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected or to comply with legal, regulatory, or contractual obligations. When your data is no longer needed, we will securely delete or anonymize it per industry best practices.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our platform. Cookies help us understand how you use our services and allow us to provide you with personalized features. You can manage your cookie preferences in your browser settings. For more details, please see our Cookie Policy.

Children’s Privacy

ValourPay’s platform is not directed toward children under the age of 18. We do not knowingly collect personal information from minors. If we learn that we have inadvertently collected such data, we will take immediate steps to delete it.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or regulatory requirements. Any significant updates will be communicated to you via email or through our platform. Your continued use of our services after any changes indicates your acceptance of the updated policy.

Contact Us

If you have any questions or concerns about this Privacy Policy or how we handle your personal data, please contact our Data Protection Officer at: legal@valourpay.com

By using our services, you acknowledge that you have read and understood this Privacy Policy.

This extended version ensures compliance with GDPR and NDPR while also providing clarity for users about how their data is processed, shared, and secured.