Privacy Policy
Effective Date: January 2026
Last Updated: January 2026
Introduction
CollatePay (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our website, mobile application, and services (collectively, the “Services”).
By using CollatePay, you consent to the data practices described in this Privacy Policy. If you do not agree with our practices, please do not use our Services.
1. Information We Collect
1.1 Information You Provide
We collect information you voluntarily provide when using our Services:
Account Information
- Full legal name
- Email address
- Phone number
- Password (encrypted)
- Date of birth
Identity Verification (KYC)
- Government-issued ID (NIN, Passport, Driver’s License, Voter’s Card)
- Selfie or photograph for identity matching
- Proof of address documents
- Bank Verification Number (BVN)
Financial Information
- Bank account details for withdrawals
- Transaction history within CollatePay
- Wallet balances and activity
Communication Data
- Messages sent to customer support
- Feedback and survey responses
- Email correspondence
1.2 Information Collected Automatically
When you use our Services, we automatically collect:
Device Information
- Device type and model
- Operating system and version
- Unique device identifiers
- Mobile network information
Usage Information
- Features accessed and actions taken
- Time and duration of usage
- App performance data
- Error logs and crash reports
Location Information
- IP address
- General geographic location (country, city)
- We do not collect precise GPS location
Cookies and Tracking
- Session cookies for authentication
- Analytics cookies to improve our Services
- You can manage cookie preferences in your browser settings
2. How We Use Your Information
We use collected information for the following purposes:
2.1 Providing Services
- Creating and managing your account
- Processing transactions (buy, sell, withdrawals, bill payments)
- Enabling wallet functionality
- Verifying your identity through KYC processes
2.2 Security and Fraud Prevention
- Detecting and preventing fraudulent activity
- Monitoring for suspicious transactions
- Protecting against unauthorized access
- Verifying user identity
2.3 Legal Compliance
- Complying with anti-money laundering (AML) regulations
- Meeting Know Your Customer (KYC) requirements
- Responding to legal requests and court orders
- Reporting to regulatory authorities as required
2.4 Communication
- Sending transaction confirmations and receipts
- Providing customer support
- Notifying you of important account updates
- Sending security alerts
2.5 Improvement and Analytics
- Analyzing usage patterns to improve Services
- Developing new features
- Troubleshooting technical issues
- Conducting research and analysis
2.6 Marketing (with consent)
- Sending promotional offers and updates
- Informing you about new features
- You can opt out of marketing communications at any time
3. How We Share Your Information
We do not sell your personal information. We may share your information in the following circumstances:
3.1 Service Providers
We share information with trusted third-party providers who assist us in operating our Services:
- Payment processors
- Identity verification services
- Cloud hosting providers
- Customer support platforms
- Analytics providers
These providers are contractually obligated to protect your information and use it only for specified purposes.
3.2 Financial Partners
To process transactions, we share necessary information with:
- Banks and financial institutions
- Cryptocurrency exchanges and liquidity providers
- Bill payment service providers
3.3 Legal Requirements
We may disclose information when required by law or to:
- Comply with legal processes or government requests
- Enforce our Terms of Service
- Protect the rights, property, or safety of CollatePay, our users, or others
- Detect, prevent, or address fraud or security issues
3.4 Business Transfers
If CollatePay is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.
3.5 With Your Consent
We may share information for other purposes with your explicit consent.
4. Data Security
We implement robust security measures to protect your information:
4.1 Technical Safeguards
- Encryption of data in transit (TLS/SSL) and at rest
- Secure password hashing
- Two-factor authentication options
- Regular security audits and penetration testing
- Intrusion detection systems
4.2 Organizational Safeguards
- Access controls limiting employee access to user data
- Employee training on data protection
- Incident response procedures
- Regular security assessments
4.3 Your Responsibilities
You play a role in protecting your information:
- Use a strong, unique password
- Enable two-factor authentication
- Do not share your login credentials
- Log out after using shared devices
- Report suspicious activity immediately
5. Data Retention
We retain your information for as long as necessary to:
- Provide our Services to you
- Comply with legal and regulatory requirements
- Resolve disputes and enforce agreements
- Maintain business records
Retention Periods:
- Account information: Duration of account plus 7 years after closure
- Transaction records: 7 years (regulatory requirement)
- KYC documents: 7 years after account closure
- Support communications: 3 years
- Marketing data: Until you opt out
After retention periods expire, we securely delete or anonymize your information.
6. Your Rights and Choices
You have the following rights regarding your personal information:
6.1 Access
You can request a copy of the personal information we hold about you.
6.2 Correction
You can request correction of inaccurate or incomplete information.
6.3 Deletion
You can request deletion of your information, subject to legal retention requirements.
6.4 Portability
You can request your data in a portable, machine-readable format.
6.5 Withdrawal of Consent
You can withdraw consent for optional data processing (such as marketing) at any time.
6.6 Objection
You can object to certain processing of your information.
6.7 Exercising Your Rights
To exercise these rights, contact us at privacy@collatepay.com. We will respond within 30 days. We may need to verify your identity before processing requests.
7. Marketing Communications
7.1 Promotional Messages
With your consent, we may send promotional emails about new features, offers, and updates.
7.2 Opting Out
You can opt out of marketing communications by:
- Clicking “unsubscribe” in any marketing email
- Adjusting preferences in your account settings
- Contacting us at support@collatepay.com
7.3 Transactional Messages
Even if you opt out of marketing, we will still send essential transactional messages about your account and transactions.
8. Children’s Privacy
CollatePay is not intended for use by individuals under 18 years of age. We do not knowingly collect personal information from children. If we discover that we have collected information from a child, we will delete it promptly. If you believe a child has provided us with personal information, please contact us immediately.
9. International Data Transfers
Your information may be transferred to and processed in countries other than Nigeria, where data protection laws may differ. When we transfer data internationally, we implement appropriate safeguards to protect your information, including:
- Standard contractual clauses
- Data processing agreements
- Ensuring adequate security measures
10. Third-Party Links
Our Services may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any information.
11. Updates to This Policy
We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of material changes by:
- Posting the updated policy on our website
- Sending an email notification
- Displaying a notice in the app
The “Last Updated” date at the top indicates when the policy was last revised. Continued use of our Services after changes take effect constitutes acceptance of the updated policy.
12. Cookies Policy
12.1 What Are Cookies
Cookies are small text files stored on your device when you visit our website or use our app.
12.2 Types of Cookies We Use
Essential Cookies Required for basic functionality like authentication and security. Cannot be disabled.
Analytics Cookies Help us understand how users interact with our Services to improve performance.
Preference Cookies Remember your settings and preferences for a better experience.
12.3 Managing Cookies
You can manage cookies through your browser settings. Disabling certain cookies may affect functionality.
13. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Privacy Inquiries Email: privacy@collatepay.com
General Support Email: support@collatepay.com
Mailing Address CollatePay Lagos, Nigeria
Response Time We aim to respond to all privacy-related inquiries within 30 days.
14. Regulatory Information
CollatePay operates in compliance with applicable Nigerian data protection regulations, including the Nigeria Data Protection Regulation (NDPR) and the Nigeria Data Protection Act (NDPA). We are committed to upholding the highest standards of data protection and privacy.
By using CollatePay, you acknowledge that you have read and understood this Privacy Policy.