Privacy Policy

Effective 16th of June 2024

Welcome to Wallet by Cycuit ("we", "our", "us"), a chat-enabled multi‑currency wallet service provided by Cycuit Limited (RC 2021869). This Privacy Policy explains how we collect, use, disclose, and protect your personal data in compliance with Nigeria Data Protection Commission (NDPC) Data Protection Rights and the Nigeria Data Protection Act (NDPA) 2023..

Scope

This Policy applies to all personal data we process about individuals located in Nigeria who use our services, including users of our WhatsApp integration, web portal, and any other channels.

Definitions

  • Personal Data: Any information relating to an identified or identifiable natural person.
  • Processing: Any operation performed on personal data, whether automated or not.
  • Data Subject: The individual to whom the personal data relates.
  • Data Controller: Cycuit Limited, determining the purposes and means of processing personal data.
  • Data Protection Officer (DPO): The individual appointed by Cycuit to oversee NDPA compliance.

Information You Provide

  • Registration Data: Name, email address, phone number, date of birth, residential address, government-issued ID (such as National ID, Bank verification number, National Passport, etc.).
  • Payment Information: Bank account details, debit/credit card data (tokenized), transaction history.
  • KYC Documents: Scanned copies of IDs, utility bills, selfies for biometric verification.

Information Collected Automatically

  • Usage Data: Chat logs, IP address, device identifiers, browser type, geolocation (where permitted).
  • Cookies and Tracking Technologies: Session identifiers, preference settings.

Purposes of Data Processing

  • Provide Services: To open accounts, process transactions, verify identity, and maintain security.
  • Compliance: To comply with NDPA, anti‑money laundering (AML), and Know Your Customer (KYC) regulations.
  • Improvement and Analytics: To improve our platform, detect fraud, and personalize your experience.
  • Marketing: To send promotional offers and updates (with your consent).

NDPC Data Subject Rights

Under the NDPA and NDPC guidelines, you have the following rights:

  • Right to Be Informed: You can request details about how we process your data.
  • Right of Access: You may obtain confirmation of whether we hold your data and receive a copy.
  • Right to Correction/Rectification: You may ask us to correct inaccurate or incomplete data.
  • Right to Erasure/Deletion: You may request deletion of your data where processing is no longer necessary or lawful.
  • Right to Withdraw Consent: You may withdraw consent at any time without affecting prior processing.
  • Right to Object: You can object to processing based on legitimate interests or direct marketing.
  • Right to Data Portability: You may receive your data in a structured, commonly used format.
  • Right to Restrict Processing: You may ask to limit processing in certain circumstances.
  • Right to Lodge a Complaint: You may file a complaint with the NDPC or our DPO.

Data Retention

We retain personal data only as long as necessary to fulfill the purposes outlined above, to comply with legal obligations, resolve disputes, and enforce agreements. Specific retention periods:

  • KYC Records: 5 years after account closure (per NDPC guidelines).
  • Transaction Data: 7 years (per AML regulations).
  • Marketing Data: Until consent is withdrawn.

Data Security

We implement appropriate technical and organizational measures, including:

  • Encryption in transit (TLS) and at rest.
  • Access controls, multi‑factor authentication, and regular security assessments.
  • Employee training on data protection and incident response procedures.

Disclosure to Third Parties

We may share personal data with:

  • Service Providers: Banks, payment processors, KYC/AML vendors, hosting providers.
  • Regulators and Law Enforcement: NDPC, EFCC, CBN, tax authorities, or courts when required.
  • Affiliates: Cycuit group companies for centralized support.
  • Marketing Partners: Only with your consent.

International Data Transfers

Where data is transferred outside Nigeria, we ensure adequate protection via standard contractual clauses, binding corporate rules, or other NDPC‑approved mechanisms.

Cookies and Tracking

We use cookies and similar technologies to:

  • Ensure platform functionality and security.
  • Analyze usage patterns for optimization.
  • Personalize your experience (with consent).

You can manage cookie preferences through your browser settings or our cookie banner.

Contact Information

If you have questions, concerns, or wish to exercise your rights, please contact:

Data Protection Officer
Cycuit Limited
Email: dpo@cycuit.com

Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of significant changes via email, in-app notification, or by updating the effective date above.