Draft — raw extract, pending revision

LEGAL DOCUMENT

Privacy Policy

How Readies collects, uses, and protects your personal data — in plain language, in full compliance with NDPR and applicable Nigerian law.

Effective: January 1, 2025Last Updated: January 1, 2025Jurisdiction: Federal Republic of Nigeria

01Overview

Welcome to Readies. Readies ("we", "our", "us") is a financial technology platform operated by Readies Technology Limited, a company incorporated under the laws of the Federal Republic of Nigeria. We are committed to protecting the privacy and personal data of all our users.

This Privacy Policy explains how we collect, process, store, and protect your personal information when you use the Readies app, website, and related services, including Readies Mobile Bank, Readiespay, Dnamaz Capital, and Golden Securities.

By downloading or using the Readies app, you agree to the collection and use of your information as described in this Policy. If you disagree with any part of this Policy, you should not use our services.

This Policy is written in plain English and complies with the Nigeria Data Protection Regulation (NDPR) 2019, the Nigeria Data Protection Act 2023, and applicable CBN data governance guidelines.

02Data We Collect

We collect different types of data depending on how you interact with our services. We only collect what is necessary to provide and improve our services.

2.1 Information You Provide Directly

  • Identity Data: Full name, date of birth, nationality, gender
  • Contact Data: Email address, phone number, residential address
  • Identity Verification (KYC):Government-issued ID (NIN, BVN, passport, driver's licence), selfie photographs
  • Financial Data: Bank account details, investment preferences, transaction history
  • Account Credentials: Encrypted password, PIN, biometric templates (stored locally on your device)

2.2 Data Collected Automatically

  • Device Data: Device model, operating system, unique device identifiers, push notification tokens
  • Usage Data: Features accessed, screens visited, session duration, click interactions
  • Location Data: Approximate location (for fraud prevention), precise GPS only if you grant permission
  • Log Data: IP address, time-stamps, error logs, crash reports

2.3 Data from Third Parties

  • BVN and identity verification data from NIBSS, NIN verification from NIMC
  • Credit and financial data from licensed credit bureaux where applicable
  • Transaction confirmation data from payment processors and our licensed microfinance bank partner

03How We Use Your Data

PurposeData UsedLegal Basis
Create and manage your accountIdentity, ContactContract performance
KYC & identity verificationIdentity, KYC documentsLegal obligation (CBN/NFIU)
Process transactions & investmentsFinancial dataContract performance
Fraud detection & preventionDevice, Usage, LocationLegitimate interest
Security & authenticationCredentials, DeviceContract performance
Customer supportIdentity, Contact, TransactionContract performance
Legal & regulatory complianceAll relevant dataLegal obligation
Improve our productsUsage, Log data (anonymised)Legitimate interest
Marketing communicationsContact (with consent)Consent (opt-in only)

We do not use your personal data for automated decision-making that produces significant legal effects without human review.

04Sharing of Data

We do not sell your personal data. We share data only in the following limited circumstances:

  • Service Providers: Payment processors, cloud infrastructure providers, KYC verification partners — all bound by strict data processing agreements
  • Regulatory Bodies: CBN, NFIU, SEC, and other Nigerian regulatory authorities as required by law
  • Law Enforcement: Where we receive a valid court order, subpoena, or legal process from a competent Nigerian authority
  • Corporate Transactions: In the event of a merger, acquisition, or sale of business assets, subject to equivalent privacy protections
  • With Your Consent: Any other sharing we will only do with your express, informed consent
We will never sell your data to advertisers or third-party data brokers. Any marketing communications from us will relate solely to Readies products and services, and only if you have opted in.

05Data Retention

We retain your personal data only as long as necessary for the purposes described in this Policy, or as required by Nigerian law.

Data CategoryRetention PeriodBasis
Account / Profile dataDuration of account + 90 days after deletionContract
KYC / Identity documents5 years after account closureNFIU / CBN AML guidelines
Transaction recordsMinimum 5 yearsCBN Regulations, CAMA 2020
Investment records (Dnamaz)5 years post-maturitySEC guidelines
Security / Fraud logs2 yearsLegitimate interest
Marketing consent recordsUntil opt-out + 2 yearsNDPR

When data is no longer needed, it is securely deleted or anonymised in accordance with industry standards.

06Security

We implement robust technical and organisational measures to protect your data, including:

  • 256-bit SSL/TLS encryption for all data in transit
  • AES-256 encryption for sensitive data at rest
  • Multi-factor authentication and biometric login options
  • Real-time fraud detection and anomaly monitoring
  • Regular independent security audits and penetration testing
  • Role-based access controls — only authorised personnel can access your data
  • Biometric templates are stored locally on your device and never transmitted to our servers

In the event of a data breach that materially affects your rights, we will notify you and the Nigeria Data Protection Commission (NDPC) within 72 hours of becoming aware, as required by the Nigeria Data Protection Act 2023.

07Your Rights

Under the Nigeria Data Protection Regulation and Act, you have the following rights regarding your personal data:

  • Right to Access: Request a copy of the personal data we hold about you
  • Right to Rectification: Request correction of inaccurate or incomplete data
  • Right to Erasure: Request deletion of your personal data (subject to legal retention obligations)
  • Right to Object: Object to processing of your data for marketing or profiling purposes
  • Right to Data Portability: Receive your data in a structured, machine-readable format
  • Right to Withdraw Consent: Withdraw consent for any processing based on consent at any time
  • Right to Lodge a Complaint: Lodge a complaint with the Nigeria Data Protection Commission (NDPC)
To exercise any of these rights, contact us at privacy@readies.ng. We will respond within 30 days of receiving your request.

08Cookies & Tracking

Our mobile app does not use browser cookies. Our website uses limited, necessary cookies to enable core functionality (session management, security tokens). We do not use advertising cookies or third-party tracking pixels on our website.

We use Firebase Analytics and Crashlytics (Google) for app performance monitoring, with data anonymised and used solely for product improvement. You may opt out of analytics data collection in the app settings.

09Children's Privacy

Readies is intended for users aged 18 and above. We do not knowingly collect personal data from persons under the age of 18. If we become aware that we have inadvertently collected data from a minor, we will delete such data immediately.

If you are a parent or guardian and believe your child has provided us with personal data, please contact us at privacy@readies.ng.

10Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

  • Update the "Last Updated" date at the top of this Policy
  • Send a notification to your registered email address
  • Display a prominent notice in the Readies app

Your continued use of Readies after any changes constitutes your acceptance of the updated Policy. We encourage you to review this page periodically.

11Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way we handle your personal data, please reach out to our Data Protection Officer:

Data Protection Officer

Readies Technology Limited · Nigeria

privacy@readies.ng