How FinesseGate handles your personal data

This policy explains what information FinesseGate collects when you use our service, why we collect it, how it is stored and shared, how you can exercise your rights, and how we keep it secure. It applies to the FinesseGate website and the FinesseGate app.

1. What we collect

We collect: identity and contact details (name, email, phone, mailing address); identification documents (NIN, BVN or passport); proof of address; transaction details (amount, currency, destination, supporting documentation such as an invoice or contract); and device and usage data (device and app version, browser type, usage patterns).

2. Why we collect it

We collect personal data to verify your identity, process and execute cross-border transaction requests through our partner institutions, comply with AML/KYC obligations, communicate transaction status, rates, fees and timelines, and improve the service.

3. How it is stored

Personal data is stored in [encrypted storage method — e.g. Enclave / AES-256 encrypted database with field-level encryption for documents]. Access is restricted to authorised staff via role-based permissions. All access is logged and reviewed. Documents are stored in separate, access-controlled document storage.

4. Who it is shared with

Personal data is shared with partner institutions only as necessary to facilitate a transaction you have requested. It is not sold and is not shared for third-party marketing purposes.

5. Data retention

Identification documents and transaction records are retained for [X years] to meet AML record-keeping expectations, then securely deleted. Where deletion would conflict with a legal retention obligation, data is retained only for as long as required by law.

6. Your rights

You may request access to, correction of, or deletion of your personal data, subject to our legal retention obligations, by contacting info@finessegateservices.com. We will respond within a reasonable timeframe.

7. NDPR statement

FinesseGate processes personal data in line with the Nigeria Data Protection Act 2023 (NDPA) and applicable NDPR guidance. [Confirm registration/filing status with NDPC as applicable once determined with counsel.]

8. App-specific privacy addendum

Camera and photo library access is used only for document upload and identity verification (for example, scanning an ID or proof of address). Push notifications are used to update you on transaction status and can be disabled in device settings. Basic device and app version information may be collected for troubleshooting and security purposes only.

9. Contact

For privacy questions or data requests, contact us at info@finessegateservices.com.