1. Introduction

POUCHFI LIMITED (“PouchFi”, “we” “our” “us”) values your privacy and the security of the information you share with us. This Privacy Policy explains how we collect, use, disclose and safeguard the information we obtain from you in relation to your use of our website, product, or services. It also provides information about how we store, transfer, use, and delete that information, and what choices you have with respect to the information.

This policy applies to our website and all related sites, applications, services, and tools regardless of how you access or use them. By using our website, products, or services, you consent to the terms and practices contained in this Privacy Policy and you grant us the right to collect and process your data in accordance with the terms of this policy.

Our website and services are not directed to children under 18. We do not knowingly collect information from children under 18. If as a parent or guardian, you become aware that your child or ward child has provided us with any information without your consent, please contact us through the details provided in this Privacy Policy.

For any access requests, questions, or inquiries about how we use your Personal Information, please contact us at info@pouchfi.io.

2. Personal Information We May Collect

At PouchFi, we are committed to safeguarding the privacy of our Users. Our business model is to provide you with the infrastructure to store, save and spend crypto or fiat. We may withhold a small transaction fee when you fund/spend from a virtual card or initiate a transaction and other services offered through the Platform.

We will only collect and process the information that we need to deliver the products and services to you and to continue to maintain and develop the service. We may collect, use, process, store, or transfer personal information such as:

The information you provide to us

This includes but is not limited to your personal data (such as your name, phone number(s), email address, personal identification documents, BVN and NIN details, home, and office addresses, data inputted in our website or application, and responses) and your social network data (such as your social media profiles and usernames).

In our efforts to ensure we are fully compliant with all applicable financial laws, we may collect, use, store, and transfer the different kinds of personal data you supply to us in accordance with our AML Policy, “know your client” obligations under the Money Laundering (Prevention and Prohibition) Act, Countering of terrorism and anti-proliferation financing laws, regulatory guidelines and other financial regulations.

The information we collect automatically

Our system automatically includes but is not limited to your IP address, browser type, mobile device ID, device type, operating system version, connection information, mobile network information, a location derived from GPS-enabled services, information based on your usage of the service such as time, date and duration of your use, referral URLs, search terms and search history, camera, contact list, browsing history, purchase history, advertisement interactions, and other statistics, including transactions you carry out when using our service. The legal basis for this processing is our legitimate interests, namely using this data for the purpose of ensuring the proper administration of our website and business, analyzing the use of the website and services, monitoring and improving our website and services, improving the user experience, preventing abuse, and assisting users with support inquiries. For information about cookies and how to opt out of cookies, see our Cookie Policy.

The information we obtain from third parties

We may retrieve additional personal information about you from third parties and other identification/verification services such as your financial institution and payment processor. With your consent, we may also collect additional personal information in other ways including emails, surveys, and other forms of communication. Once you begin using our services through your PouchFi account, we will keep records of your transactions and collect information on your other activities related to our services. We will not share or disclose your personal information with a third party without your consent except as may be required for the purpose of providing you with our services or under applicable legislation.

In providing you with our services, we may rely on third-party servers located in foreign jurisdictions from time to time, which as a result, may require the transfer or maintenance of your personally identifiable information on computers or servers in foreign jurisdictions. We will endeavour to ensure that such foreign jurisdictions have data protection legislation that is no less than the existing data protection regulations in force in Nigeria and that your personally identifiable information is treated safely and securely.

Customer Support Information.

We may process information that you send to us, should you choose to submit a request to our support email. If you contact us, we may use your Account, Transaction, or Usage Information to respond. Processing this information is required for performing the contract we entered into with you, at your request (our Terms of Service), as well as our legitimate interest in handling your requests.

3. Why we collect your information

We collect your information to ensure easy and seamless access to our services.

We use the information we collect for the following purposes:

to enable us to provide you with a personalized experience of our product and services;
to communicate with you and provide you with information on our services, such as marketing content, newsletters, and service updates. However, we will provide you with an option to unsubscribe if you do not want to hear from us;
to process your orders and requests;
to identify and fix errors and bugs on our platforms;
to facilitate dissemination of information about our services and our partners;
To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our site about goods or websites that may interest you or them, identify your preferences, and personalize your experience with our website; and
to display ads for features, products, and websites that might be of interest to you;
to provide support services to you;
to analyze and understand your use of our products and services;
to protect against illegal, malicious, and fraudulent activity;
to analyze and improve the quality of our services and offerings;
to facilitate your interactions with our social media platforms.

Third-party information sharing

We may sometimes share the information we have collected from you with third parties with your consent or when we are required to. You agree that we have the right to share your personal information:

with any of our affiliated companies, subsidiaries, website providers, and professional advisers on a need-to-know basis;

with financial website providers, including the financial institutions identified in connection with your account;

with non-financial companies, such as email website providers that perform marketing websites on our behalf, and fraud prevention website providers that use the information to provide websites to us;

with a non-affiliated third party to access and transmit your personal and financial information from a relevant financial institution. You grant the third party the right, power, and authority to access and transmit this information according to the terms of their privacy policy;

with selected third parties including business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you such as hosting/infrastructure/storage providers, payment processors, analysis tools providers, marketing and email providers, and internal communication tools providers;

with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or alternatively, acquire all or parts of their businesses;

in response to a request for information, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation, or legal process; and

with relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud.

4. Marketing

We may process your Personal Information in order to contact you or send you marketing content and communication about our products, services, or surveys. You may exercise your right to object to such contact from us or opt out of the marketing content. Please note however that if you opt-out of marketing content, we may still send you messages relating to transactions and our Services related to our ongoing business relationship.

We may ask you for permission to send notifications to you. Our Services will still work if you do not grant us consent to send you notifications.

5. International data transfer

In some circumstances, your personal data may be transferred to third parties outside Nigeria. Such transfers will only be done in accordance with the Data protection regulations. While undertaking the international transfer of your information, we will put security measures in place to reasonably protect your data during transmission. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

6. Your rights

As an individual, you are granted rights according to the applicable data protection law:

The right to access your personal data
The right to rectification and deletion of your personal data
The right to object to and restriction of our processing of your personal data
The right to request the transfer of your personal data to you or a third party

7. Data retention and deletion

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain your data as follows:

Transaction information will be retained for a minimum period of 5 years following the date of the transaction.

In some cases, it is not possible for us to specify in advance the periods for which your data will be retained. In such cases, we will determine the period of retention based on the following criteria:

Account information will be retained until you decide to delete your account on PouchFi. Information about you used for Product & Marketing communication will be retained as long as you have given us consent to use this information.

The period of retention of usage information will be determined based on the need for historical data to determine statistical validity and relevance for product decisions and technical monitoring

Regardless of the provisions above, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.

If you have a PouchFi account, you can access, and modify your personal information, in Settings. To delete your account, you should send a request to PouchFi at info@pouchfi.io. If you request to delete your account, your information and content will be unrecoverable after that time. We may withhold some personal information to the extent permitted by law.

8. Updates to this policy

We can change these Terms at any time. If a change is material, we will let you know before it takes effect. By using PouchFi on or after that effective date, you agree to the new Terms. If you don’t agree to them, you should contact PouchFi at info@pouchfi.io with the request to delete your account before they take effect, otherwise, your use of the Service and Content will be subject to the new Terms.

All access requests, questions, comments, complaints, and other requests regarding the privacy policy should be sent to info@pouchfi.io. We may request additional details from you regarding your complaints and keep records of your requests and resolution.

Last updated in February 2024.