NAIRAFX LEGAL & PRIVACY
Privacy Policy
1. Who we are and scope of this notice
NairaFX Change (“NairaFX”, “we”, “us” or “our”) operates the NairaFX website, member marketplace, rate-information features, trade rooms, support channels and related services. This Privacy Policy applies to visitors, registered members, prospective members, subscribers, transaction counterparties and people who contact us.
We aim to process personal data transparently and in accordance with applicable data-protection law, including the Nigeria Data Protection Act 2023 where applicable. This policy should be read with our platform terms, notices presented during registration or verification, and any specific notice issued for a particular service.
2. Personal data we collect
| Category | Examples | Why it may be needed |
|---|---|---|
| Account and contact data | Name, email address, phone number, username and password hash | To create, secure and administer your account and communicate with you. |
| Verification and profile data | Country, location, account type, trading preference, government ID, proof of address and business documents where required | To assess eligibility, prevent misuse and support Compliance review. |
| Trade and marketplace data | Listings, reservations, trade-room actions, agreed rates, payment-route information, confirmations, support records and dispute information | To operate the marketplace, coordinate trades, resolve issues and maintain audit records. |
| Payment and receiving-account data | Bank or payment-route details, masked account details, payment references and proof submitted by you | To enable agreed member-to-member settlement instructions and review token purchases. NairaFX does not request your online-banking password or card PIN. |
| Security and technical data | OTP verification records, login/security events, IP address, browser/device information, cookies and server logs | To secure accounts, detect fraud or abuse, troubleshoot and improve service reliability. |
| Communications and subscriptions | Support messages, email preferences, rate-report subscriptions, consent records and marketing opt-outs | To respond to you and send communications you have requested or that are otherwise permitted by law. |
3. How we use personal data and our lawful bases
Depending on the context, we process personal data to provide the services you request; take steps at your request before providing a service; meet legal, regulatory, audit, fraud-prevention or dispute-resolution obligations; pursue legitimate interests in operating a safe and reliable platform; and, where required, obtain and rely on your consent.
Examples include account registration, email OTP or link verification, Compliance checks, member support, transaction notices, operational alerts, marketplace safety, analytics, enforcement of our terms, and rate updates you choose to receive. You may withdraw consent for optional marketing at any time; this does not affect processing that occurred before withdrawal or processing based on another lawful basis.
4. Verification documents and sensitive information
Verification documents are collected only when needed for member verification and are intended to be accessible only to authorised Compliance personnel with a legitimate work need. We use administrative, technical and access-control measures designed to protect these files. Do not upload documents containing information beyond what NairaFX requests.
5. Information shared with other members and service providers
Where necessary to operate a listing, reservation or trade, we may show the relevant counterparty limited information such as your display name, verification status, member reputation, listing terms, trade-room messages and agreed payment-route instructions. We do not intentionally make your verification documents or password available to another member.
We may use carefully selected service providers to host the platform, deliver email, provide security and content-delivery services, manage backups, perform analytics, or support payments when a payment provider is enabled. They may process data only as needed to provide their services to us and subject to appropriate safeguards. We may also disclose information where required by law, a lawful authority, or to protect the rights, safety and security of NairaFX, our members or others.
6. International transfers
Our technology and service providers may process data in countries other than the country where you live. Where a cross-border transfer is required, we will use appropriate safeguards and take account of applicable legal requirements.
7. Retention
We retain personal data only for as long as reasonably necessary for the purposes described in this policy, including account administration, security, verification, legal or regulatory obligations, dispute resolution, audits and enforcement of our terms. Retention can continue after account closure where required or justified for those purposes. We seek to delete, anonymise or securely isolate data when it is no longer needed, subject to lawful retention requirements.
8. Your rights and choices
Subject to applicable law and any valid exceptions, you may request access to, correction of, deletion of, restriction of, or an objection to the processing of your personal data. You may ask for portability where applicable, withdraw consent, request human review of a decision where relevant, and make a complaint to the Nigeria Data Protection Commission or another relevant regulator.
You can update certain account information in your member profile, manage email preferences through the links in emails where provided, and ask us for help with other requests. We may need to verify your identity before acting on a request and may retain limited information where necessary to prevent fraud, resolve disputes or meet legal obligations.
9. Email, rate reports and marketing
We send essential service communications such as account security, verification, reservation, trade and operational notices. If you subscribe to rate reports, market updates or other optional communications, you can unsubscribe at any time through the relevant email link or by contacting us. We maintain suppression records to honour opt-out requests.
10. Cookies, analytics and third-party services
We use cookies and similar technologies needed for website operation, security, preferences and measurement. Some third-party tools may collect technical or usage information when you visit the website. You can manage browser cookie settings, but disabling essential cookies may affect site functionality. Where consent is required for a non-essential technology, we will seek it before using that technology.
11. Security
We use measures designed to protect personal data against unauthorised access, loss, misuse or alteration. No internet service can guarantee absolute security. Keep your password and OTP confidential, use a unique password, and notify us promptly if you believe your account or information has been compromised.
12. Children
NairaFX is not intended for children. Do not use the platform or provide personal data if you are below the legal age required to use the service in your location. If you believe a child has provided us personal data, contact us so we can review the situation.
13. Changes to this policy
We may update this policy when our services, security practices or legal requirements change. We will post the updated version on this page and revise the effective date. Where a change is material, we may also provide an additional notice by email or within the platform where appropriate.
14. Contact and privacy requests
Privacy and data-protection contact:
[email protected]
Please use the subject line “Privacy Request” and describe your request. Do not send passwords, OTPs or full bank-card details by email.