Privacy Policy

This Privacy Policy explains how SnappyPay ("SnappyPay", "we", "us", or "our") collects, uses, stores, shares, and protects personal data when you use our website, mobile application, and related services.

SnappyPay is a Nigerian fintech and payment platform. Through SnappyPay, users can access services such as airtime purchase, data purchase, electricity bill payment, cable TV bill payment, education bill payment, gift card purchase, gift card selling or trading, airtime-to-cash, betting wallet funding, flight and hotel booking, cashback and referral rewards, scheduled payments, wallet balance alerts, social media service orders, wallet services, and virtual card services through our partners.

Some services may be subject to eligibility, age, verification, partner, regulatory, or service-specific requirements.

By using SnappyPay, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this policy, please do not use our services.

SnappyPay is a fintech and payment platform operating in Nigeria. SnappyPay is not a bank and does not hold itself out as a bank.

• Wallet services are provided through a licensed banking partner.
• Virtual card services are provided through a partner that works with a virtual card issuing company.
• Other services may be provided directly by SnappyPay or through approved technology, payment, verification, bill payment, card, travel, betting, gift card, and service partners.

For privacy-related questions, requests, or complaints, contact us at help@snappypay.ng.

This Privacy Policy applies to personal data processed when you use:

• the SnappyPay website;
• the SnappyPay mobile application;
• SnappyPay web platform features;
• SnappyPay customer support channels;
• SnappyPay promotions, referral, cashback, and reward features; and
• any other SnappyPay service that links to or refers to this Privacy Policy.

This policy does not control the privacy practices of independent third-party websites, platforms, merchants, or service providers that may have their own privacy notices. Where you use a third-party service, you should review the privacy notice of that third party.

The personal data we collect depends on the services you use, the information you provide, and the requirements of our partners or applicable law.

Information you provide directly may include:

• Account information, such as your full name, username, phone number, email address, password, and other registration details.
• Profile information, such as date of birth, gender, address, and other details you choose to provide or that may be required for certain services.
• Transaction information, such as transaction amount, service type, recipient details, payment references, order details, receipts, transaction status, and transaction history.
• Bank account information, where needed for wallet funding, withdrawals, refunds, settlements, or account verification.
• Gift card information, where you buy, sell, upload, or submit gift cards through SnappyPay. This may include gift card images, codes, PINs, denominations, country, brand, category, and transaction notes.
• Airtime-to-cash information, such as phone number, network, transfer or recharge details, and transaction proof where required.
• Referral information, such as the name or contact details of people you refer, where you have the right or permission to share that information.
• Support information, such as messages, complaints, feedback, call records where applicable, emails, chat records, screenshots, documents, and other details you send to our support team.

When you use SnappyPay, we may automatically collect certain information to operate, secure, improve, and monitor our services. This may include:

• Device information, such as device type, operating system, browser type, app version, device identifiers, and IP address.
• Usage information, such as pages viewed, buttons clicked, features used, time spent, transaction flow activity, and error logs.
• Approximate location information, such as location derived from IP address or device settings, where applicable.
• Security and log information, such as login activity, session details, authentication records, failed login attempts, and system activity logs.

We do not collect precise GPS location unless it is required for a specific service and you have granted the relevant permission.

We may receive information from third parties where necessary to provide services, verify users, complete transactions, prevent fraud, comply with legal requirements, or support account security. These third parties may include:

• identity verification and KYC API providers;
• banking and wallet service partners;
• payment processors and settlement partners;
• virtual card partners;
• bill payment, gift card, travel, betting, and service providers;
• fraud-prevention, risk screening, or compliance providers;
• analytics and technology providers; and
• regulators, courts, law enforcement, or other lawful authorities where legally required.

Where required, we may collect, receive, submit, or process identity verification information through third-party verification, banking, card, or compliance partners. This may include information such as your name, date of birth, phone number, address, BVN, NIN, identification details, photograph, selfie or liveness check, or other information required for verification.

We use personal data for the following purposes:

• to create, verify, and manage your SnappyPay account;
• to provide, process, and complete transactions and service requests;
• to provide wallet services through our licensed banking partner;
• to provide virtual card services through our card partner;
• to verify identity where required for certain services, partner requirements, security, or compliance;
• to process payments, wallet funding, withdrawals, refunds, settlements, rewards, cashback, and referral benefits;
• to deliver gift cards, process gift card trades, review uploaded card information, and communicate trade status;
• to detect, prevent, investigate, and respond to fraud, unauthorised access, misuse, suspicious activity, or illegal activity;
• to provide customer support and respond to enquiries, complaints, disputes, and chargebacks;
• to send transaction alerts, service messages, security alerts, and account notifications;
• to send marketing communications where permitted by law or where you have consented;
• to improve, test, monitor, and develop our platform, products, and services;
• to comply with legal, regulatory, tax, accounting, audit, and operational obligations; and
• to enforce our Terms of Use and protect the rights, property, and safety of SnappyPay, our users, partners, and the public.

We process personal data in line with applicable Nigerian data protection laws, including the Nigeria Data Protection Act, 2023. Depending on the purpose, we may rely on one or more of the following legal bases:

• Consent, where you have given clear permission for a specific purpose, such as certain marketing communications.
• Contractual necessity, where processing is required to provide a service you requested or to perform our agreement with you.
• Legal obligation, where processing is necessary to comply with applicable laws, regulations, court orders, regulatory requests, fraud-prevention obligations, tax, accounting, audit, or compliance requirements.
• Legitimate interest, where processing is necessary for business, security, fraud-prevention, service improvement, support, or operational reasons, provided your rights do not override those interests.

Where we rely on consent, you may withdraw your consent where applicable. Withdrawal of consent does not affect processing carried out before the withdrawal.

To protect users and the platform, certain SnappyPay services may require identity verification, eligibility checks, transaction monitoring, or partner review. This may be required before or during the use of wallet services, virtual card services, gift card trading, withdrawals, high-risk transactions, account recovery, dispute resolution, or other services.

Verification data may be processed through third-party API providers, banking partners, card partners, or compliance partners. These partners may help verify the information you provide, confirm your identity, check transaction eligibility, screen for fraud or misuse, and meet legal or partner requirements.

We may restrict, delay, reject, reverse, suspend, or review a transaction or account where required for security, fraud prevention, compliance, partner requirements, or legal reasons.

We do not sell your personal data. We may share your information only where necessary for the purposes described in this Privacy Policy, including with:

• licensed banking partners, for wallet services;
• card partners, for virtual card services;
• payment processors and settlement partners, for payment processing, wallet funding, withdrawals, refunds, and settlements;
• verification and KYC API providers, for identity verification, screening, and compliance checks;
• service providers, such as airtime, data, electricity, cable TV, education bills, gift card, travel, betting, social media service, and other transaction partners;
• technology, hosting, analytics, communication, and customer support providers;
• professional advisers, such as lawyers, auditors, consultants, insurers, and accountants;
• regulators, courts, law enforcement agencies, government agencies, or other lawful authorities where required by law; and
• another entity in connection with a merger, acquisition, restructuring, sale of assets, financing, or business transfer, subject to appropriate protections.

Where we use service providers, we expect them to process personal data only for authorised purposes and in line with applicable data protection obligations.

We may disclose information where required or permitted by law, regulation, court order, valid law enforcement request, fraud prevention, security review, compliance obligation, or where necessary to protect the rights, safety, and property of SnappyPay, our users, partners, or the public.

SnappyPay works with partners to provide certain services. This means some personal data may be shared with or processed by those partners where needed to provide the service you request.

• Wallet services are provided through a licensed banking partner.
• Virtual card services are provided through a partner that works with a virtual card issuing company.
• Verification services may be provided through third-party API providers.
• Bill payment, gift card, travel, betting, and other service transactions may be fulfilled through third-party service providers.

These partners may have their own legal, verification, operational, or regulatory requirements. Some services may not be available unless those requirements are met.

Some of our service providers or technology systems may process or store personal data outside Nigeria. Where this happens, we take steps designed to ensure that the transfer and processing of personal data are carried out in line with applicable data protection laws and appropriate safeguards.

These safeguards may include contractual obligations, access restrictions, security controls, and requirements that service providers process data only for authorised purposes.

We retain personal data only for as long as necessary to provide our services, comply with legal and regulatory obligations, prevent fraud, resolve disputes, enforce our terms, keep business records, and meet audit, tax, accounting, operational, or compliance requirements.

Some data may need to be retained after account closure where required by law, regulation, partner requirements, fraud prevention, dispute resolution, audit, or record-keeping obligations.

When personal data is no longer required, we will delete, anonymise, or securely archive it in line with our data retention practices and applicable law.

We use reasonable technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure. These measures may include access controls, staff access restrictions, monitoring, secure system design, and other safeguards appropriate to the type of data we process.

No electronic system, website, app, or transmission method is completely secure. You are responsible for keeping your login details, password, PIN, OTP, and device secure. You should contact us immediately if you suspect unauthorised access to your account.

Subject to applicable law, you may have the right to:

• request access to the personal data we hold about you;
• request correction of inaccurate or incomplete personal data;
• request deletion of personal data where we no longer have a lawful reason to keep it;
• request restriction of certain processing;
• object to certain processing, including direct marketing;
• withdraw consent where processing is based on consent;
• request information about how your personal data is used;
• request data portability where applicable; and
• lodge a complaint with the Nigeria Data Protection Commission or another competent authority.

To exercise your rights, contact us at help@snappypay.ng. We may need to verify your identity before responding to your request. We will respond within the timeframe required by applicable law.

Some requests may be limited where we need to retain or process data for legal, regulatory, security, fraud-prevention, accounting, audit, dispute, or operational reasons.

We may use cookies, software development kits, pixels, analytics tools, and similar technologies to operate and improve our website and app. These technologies may help us:

• keep you signed in and secure your account;
• remember your preferences;
• understand how users interact with our platform;
• detect errors and improve performance; and
• deliver or measure marketing where permitted by law or consented to.

You may be able to manage cookies through your browser settings or any cookie tools we provide. Disabling some cookies may affect how the website or app works.

We may send you service communications and marketing communications.

• Service communications include transaction confirmations, security alerts, account updates, support messages, and important notices about your use of SnappyPay. These are necessary for the service and may not be optional.
• Marketing communications may include promotions, offers, product updates, cashback campaigns, referral campaigns, and newsletters. Where required, we will rely on your consent or another lawful basis to send such communications.

You can opt out of marketing emails by using the unsubscribe link in the message or contacting us at help@snappypay.ng. You may still receive service communications after opting out of marketing messages.

SnappyPay services are not intended for anyone under 18 years of age. We do not knowingly collect personal data from children.

If we discover that we have collected personal data from a person under 18, we may delete the information, restrict the account, or take other appropriate action. If you believe a child has provided personal data to us, contact us at help@snappypay.ng.

You may request to close your SnappyPay account or delete your personal data by contacting us at help@snappypay.ng or using any account closure option available in the app.

Before closing an account, we may need to complete pending transactions, resolve disputes, confirm your identity, settle outstanding obligations, or comply with legal, regulatory, partner, fraud-prevention, accounting, audit, or operational requirements.

After account closure, we may retain certain information where required or permitted by law. Where data is no longer needed, we will delete, anonymise, or securely archive it.

We may update this Privacy Policy from time to time to reflect changes in our services, partners, legal requirements, or data processing practices.

When we make changes, we will update the "Last Updated" date. Where changes are significant, we may notify you through the app, website, email, or other appropriate channels.

Your continued use of SnappyPay after an updated Privacy Policy becomes effective means you acknowledge the updated policy.

For privacy-related questions, requests, or complaints, contact us at:

• Email: help@snappypay.ng
• Website: www.snappypay.ng

You may also contact us through the Support section of the SnappyPay app, where available.