Privacy Policy

1. Who We Are

Niyyah Digital Technology Ltd is a private limited company registered under the laws of the Federal Republic of Nigeria, with operations headquartered in Abuja, Nigeria.

Important Notice: NiyyahPay is a financial technology platform providing software tools for savings, collective wealth building (Circles), and Murabaha-based asset financing. We are not a licensed bank and do not hold customer funds directly. All customer deposit accounts and financial custodial balances are held securely with our regulated banking partner, Safe Haven Microfinance Bank, a Central Bank of Nigeria (CBN) licensed and NDIC-insured institution.

2. Information We Collect

We collect information that you provide directly to us, as well as data gathered automatically when you interact with our platform:

A. Information You Provide Directly:

• Personal Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (e.g., Bank Verification Number [BVN], National Identification Number [NIN], or International Passport) as required for compliance and anti-fraud checks.
• Contact Information: Active phone number (WhatsApp enabled preferred), email address, residential address, and state of residence.
• Financial Profile Data: Monthly income range, primary income source (salary, commerce, freelance, agriculture), employer or business details, and linked commercial bank accounts for disbursements or deposits.
• Asset Financing Application Data: Detailed item descriptions, estimated retail price, vendor quotes, chosen installment tenure (2 to 5 months), and guarantor information if applicable.
• Circle Participation Data: Contribution amounts, chosen rotation frequency, group associations, and disbursement preferences.

B. Automatically Collected Information:

• Device & Connection Data: IP address, device hardware model, operating system version, browser type, and mobile network information.
• Usage & Interaction Data: Log timestamps, pages viewed, features accessed, session durations, crash reports, and system performance metrics.
• Location Data: Approximate geographic location derived from IP address for regional fraud prevention.

3. How We Use Your Information

We process your data strictly to deliver ethical, transparent, and legally compliant financial services:

• To create, verify, and maintain your NiyyahPay customer profile and digital account.
• To enable automated goal-based savings, locked vault enforcement, and scheduled transfers.
• To manage transparent group contributions and rotation payouts within NiyyahPay Circles.
• To assess eligibility for Murabaha (cost-plus markup) asset financing, procure assets from verified vendors, and track transparent repayment schedules.
• To verify identity and prevent identity theft, money laundering, financial fraud, and unauthorized platform access.
• To send critical transactional notifications, repayment receipts, and concierge customer support responses.
• To fulfill statutory reporting obligations to regulatory agencies in Nigeria.

4. Legal Basis for Processing

Under the Nigeria Data Protection Act (NDPA) and applicable data protection regulations, we process your personal information only when we have a lawful basis:

• Performance of a Contract: Processing necessary to provide you with the services you requested when opening an account or submitting a financing application.
• Legal & Regulatory Obligations: Compliance with anti-money laundering (AML), Know Your Customer (KYC), and financial recordkeeping requirements.
• Legitimate Interests: Securing our systems, detecting fraudulent transactions, and ensuring platform reliability.
• Consent: Where you have granted explicit consent, such as receiving optional promotional newsletters or participating in early feature tests.

5. How We Share Your Information

We never sell, rent, or trade your personal information to third parties for advertising or commercial marketing purposes. We share information only under strict confidentiality and operational safeguards:

• Custodial Banking Partners: Safe Haven Microfinance Bank, to open virtual bank accounts, hold customer funds, and execute settlement transactions.
• Verified Asset Vendors & Logistics: Authorized suppliers and couriers strictly to purchase and deliver approved assets to you.
• Service Providers & Infrastructure: Cloud hosting facilities, SMS/email gateway operators, and credit bureaus who process data under binding data protection agreements.
• Regulatory & Law Enforcement Bodies: Central Bank of Nigeria (CBN), Nigeria Financial Intelligence Unit (NFIU), Economic and Financial Crimes Commission (EFCC), or courts of competent jurisdiction where legally mandated.

6. Customer Funds & Partners

NiyyahPay is committed to full financial and Shariah transparency:

All savings contributions and Circle funds are deposited directly into custody accounts maintained by licensed banking partners regulated by the Central Bank of Nigeria (CBN) and insured by the Nigeria Deposit Insurance Corporation (NDIC). NiyyahPay acts as a technology service provider and software administrator.

7. Data Protection & Security

We implement comprehensive technical and organizational measures to safeguard your data against loss, unauthorized access, and alteration:

• Encryption: All data transmitted between your browser or mobile device and our servers is encrypted using modern Transport Layer Security (TLS 1.3). Sensitive stored data is encrypted at rest using AES-256 standard encryption.
• Access Control: Administrative access to personal data is restricted strictly to authorized employees under least-privilege principles and multi-factor authentication.
• User Responsibilities: You are responsible for keeping your login credentials, device security, and two-factor authentication codes confidential. NiyyahPay staff will never ask for your password or full PIN.

8. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Nigerian laws:

For active accounts, records are maintained during the lifecycle of the customer relationship. Following account closure, financial transaction history and identification documents are retained for a minimum statutory period (typically 5 to 7 years) to comply with anti-money laundering regulations. When data is no longer required, it is permanently deleted or irreversibly anonymized.

9. Your Data Rights

Under Nigerian data protection laws (NDPA/NDPR), you possess comprehensive rights regarding your personal information:

• Right to Access: You can request a confirmation of whether we process your data and obtain a copy of your records.
• Right to Rectification: You may request the prompt correction of incomplete or inaccurate data.
• Right to Erasure ("Right to Be Forgotten"): You may request the deletion of your data where it is no longer required for legal compliance.
• Right to Restrict or Object: You can object to certain processing activities or request that processing be temporarily suspended.
• Right to Data Portability: You can request your personal information in a structured, machine-readable format.
• Right to Withdraw Consent: You may withdraw previously given consent at any time without affecting prior lawful processing.

To exercise any of these rights, please email our Data Protection Officer at privacy@niyyahpay.com. We respond to all verified requests within thirty (30) business days.

10. Marketing Communications

We may periodically send you product updates, educational financial literacy tips, or announcements about new asset categories. You can opt out of non-essential marketing emails at any time by clicking the "Unsubscribe" link at the footer of our emails or by contacting support.

Note: Essential operational notices—such as financing approval updates, repayment receipts, security alerts, and system notices—cannot be opted out of while maintaining an active account.

11. Cookies & Tracking Technologies

We use first-party cookies and similar technologies to preserve your login session, prevent cross-site request forgery (CSRF), and measure web performance. You can control or disable cookies through your web browser preferences; however, disabling essential session cookies may impair the functionality of authenticated features.

12. Third-Party Services

Our website and applications may contain links to external platforms, vendors, or partner websites. This Privacy Policy applies strictly to NiyyahPay. We encourage you to review the privacy policies of any third-party websites you visit before submitting personal information.

13. International Transfers

Our primary servers and operations are located in Nigeria. In instances where we utilize international cloud infrastructure or security providers, we ensure that adequate protection safeguards and standard contractual clauses recognized under Nigerian data protection laws are in place.

14. Children's Privacy

NiyyahPay services are exclusively designed and intended for individuals who are 18 years of age or older. We do not knowingly collect or solicit personal information from minors. If we discover that an individual under 18 has submitted information to our platform, we will promptly delete such records.

15. Security Incidents & Breaches

In the unlikely event of a security incident impacting your personal data, NiyyahPay will notify affected customers and relevant regulatory authorities within the timeframes mandated by Nigerian data protection regulations, along with guidance on remediation measures.

If you identify a security concern or potential vulnerability, please contact our security team immediately at hello@niyyahpay.com.

16. Changes to This Policy

We may revise this Privacy Policy periodically to reflect new features, operational practices, or legal requirements. Material modifications will be announced through notifications on our website or direct email communication. Continued use of our platform after updates indicates your acknowledgment of the revised terms.

17. Contact Us

For questions, feedback, or data privacy inquiries, please contact our team: