Privacy Policy

At Xtrempay Nigeria ("we," "our," "us"), we prioritize the privacy of our users and are committed to safeguarding personal data. Operated as a product of Village Assist Nigeria Limited (registered with the Corporate Affairs Commission under RC-1805693), Xtrempay adheres to the highest standards of data protection.

This Privacy Policy outlines how we collect, use, and protect your personal data while highlighting your rights regarding your information. It applies to all our platforms, including websites, mobile applications, and any future digital products developed under Xtrempay.

Covered Platforms

Our policy governs the following existing platforms:

  • Xtrempay Website: Accessible at www.xtrempay.com.

    • We understand the importance of trust in handling personal data. As such, Xtrempay complies with the Nigeria Data Protection Act 2023 and other applicable data protection laws to ensure secure transactions and safeguard your privacy.

    Information Use

    We may use the information we collect from you to personalize your experience, improve our website, and send periodic emails.

    By using our platforms, you agree to this Privacy Policy. If you do not consent to the terms outlined here, please refrain from accessing our services. Xtrempay reserves the right to update this policy periodically, so we encourage you to review it regularly.

    Consent

    Your use of our services indicates your consent to the collection and use of your personal data in line with this policy. This includes consent for sharing your data when necessary. If we make updates to this policy, we will post them on this page to keep you informed. If you disagree with the terms, please discontinue the use of our platforms and services.

    Minors

    Our platforms are intended for individuals aged 18 years and above. We do not knowingly collect or store personal data from minors. If you are under 18, please refrain from providing personal data. If such information has been submitted, parents or legal guardians should notify us immediately so we can delete the data.

    Purpose of Data Processing

    We process personal data to provide a seamless and secure experience, including:

    Purpose of Data Processing

    We process personal data to provide a seamless and secure experience, including:

    1. Service Delivery

    • Verifying your account and providing secure access.
    • Communicating important information about your account or transactions.

    2. Issue Resolution

    • Resolving disputes and addressing technical issues.

    3. Regulatory Compliance

    • Meeting legal obligations and enforcing site/service terms.

    4. Fraud Management

    • Preventing fraud and verifying identities for your safety.

    5. Marketing (with consent)

    • Informing you about Xtrempay products or services.
    • Utilizing cookies for tailored features and offers.

    6. Data Breach Remediation

    • Detecting and addressing information security breaches.

    You have the right to opt out of unsolicited marketing communications at any time, free of charge.

    Lawful Basis for Data Processing

    In compliance with the Nigeria Data Protection Act 2023, we process data based on the following legal grounds:

    1. Consent

    • By using our services, you consent to data processing for specific purposes.

    2. Contractual Necessity

    • To fulfill contractual obligations or take steps toward entering a contract with you.

    3. Legal Obligations

    • Retaining data as required by law, such as customer account details.

    4. Legitimate Interests

    • Preventing fraud, verifying identities, and improving customer experience.

    5. Vital Interests

    • Processing data in critical situations to ensure your safety.

    6. Public Interest

    • Performing tasks in the public interest or under a public mandate.

    Data We Collect

    We gather the following personal data to provide services:

    1. Sign-Up Information

    • Name, BVN, NIN, date of birth, email, phone number, and debit card details.

    2. Transaction Data

    • Details of financial activities, such as amounts, geolocation, and merchant information.

    3.Participant Data

    • Information about transaction participants, including names and financial account details.

    4. External Sources

    • Data from social media platforms when resolving complaints or inquiries.

    5. Customer Support

    • Information from interactions with our support teams.

    6. Job Applications

    • Personal data related to education, employment, health, and background checks for employment purposes.

    7. Third-Party Data Sharing

    • Data shared with academic institutions, recruiters, law enforcement, and referees when necessary.

    Sharing Information About Others

    If you provide data about others, you are responsible for obtaining their consent and informing them of how their data will be used. Please direct them to review our Privacy Policy for further understanding.

    How We Use Your Information

    Under the Nigerian Data Protection Regulations 2019 (NDPR), Xtrempay must have a lawful basis to process your personal information. These bases include contractual or legal obligations, legitimate interests, public interest, vital interests, or your consent.

    Contractual Obligation

    We process your personal data to fulfill our contractual obligations to you or to establish a contract. Specifically, we use your data to:

  • Provide the services outlined in our terms and conditions.
  • Communicate with you about your account and services you use.
  • Exercise our rights under the contract, such as managing or recovering funds owed.
  • Investigate and resolve any complaints or issues.

    • Your Rights as a Data Subject

    Your personal data is protected by legal rights under Data Protection Laws. These rights include:

    1. Access and Transparency

    • The right to know how your personal data is being used and to access it.

    2. Rectification and Erasure

    • The right to request corrections or deletions of your personal data.

    3. Restriction of Processing

    • The right to limit the use of your personal data.

    4. Objection to Processing

    • The right to object to processing based on legitimate interests (note this may limit our ability to provide services).

    5. Data Portability

    • The right to request data in a structured, machine-readable format or transfer it to another organization.

    6. Withdrawal of Consent

    • The right to withdraw consent for processing based on your prior approval, subject to legal or contractual obligations.

    7. Automated Decision-Making

    • The right to object to automated processing, including profiling.

    8. Complaint

    • The right to lodge complaints with relevant supervisory authorities.

    If you request access to your data, a fee may apply if the request is deemed excessive or unfounded.

    How to Exercise Your Rights

  • Submit your request in writing to our official communication channels (e.g., registered email).
  • Specify the right you wish to exercise.
  • Contact our Data Protection Officer (DPO) at dpo@xtrempay.com for assistance.

    • We aim to process all requests within 30 days. If an extension is needed, we will notify you via consented communication channels.

    Data Retention

    We retain personal data only as long as necessary for the purposes outlined in this policy. Generally, we keep data for at least seven (7) years to meet business, legal, and regulatory requirements. In some cases, data may be retained for longer periods if required for legitimate business purposes or compliance with applicable laws.

    Accuracy of Your Data

    It is essential that the data we hold about you is accurate and up-to-date. You can update your information directly through our customer-facing products or by contacting our DPO at dpo@xtrempay.com.

    Security of Your Data

    We have implemented robust organizational and technical measures to protect your data, including:

  • Storing data on secure servers with 256-bit encryption.
  • Restricting access to authorized personnel only.
  • Securing our IT systems against breaches.
  • Establishing protocols to address potential data breaches.

    • In the unlikely event of a data breach, we will take immediate steps to mitigate risks and, if necessary, notify you and the appropriate authorities.

    Sharing of Personal Data

    Xtrempay may disclose or transfer personal data to external service providers and other entities to support its operations. These include:

    a) Service Providers

    We share personal data with third-party service providers who work at our direction to:

  • Verify your identity.
  • Process transactions.
  • Offer customer support.

    • b) Financial Institutions

    Personal data may be shared with partnered financial institutions strictly to facilitate Xtrempay-related services unless you have consented to other uses.

    c) Transaction Participants

    When you use Xtrempay, we may share relevant personal data with:

  • Other users involved in the transaction.
  • Their service providers, to resolve disputes or detect and prevent fraud.

    • d) Other Third Parties

    We may disclose your information for business or legal purposes, including:

  • Compliance with laws, regulations, or legal processes.
  • To government authorities, law enforcement, or other parties as required by court orders or regulations.
  • Protecting against fraud, illegal activity, or financial loss.
  • To credit agencies for compliance or fraud prevention.
  • In audits or compliance reviews.
  • During a business merger, acquisition, or sale of Xtrempay.

    • e) With Your Consent

    We may also share your information as directed or explicitly authorized by you.

    Confidentiality

    Your personal information is treated as confidential. Xtrempay will not sell, rent, or share your data with third parties for unsolicited purposes. Information will only be disclosed to

  • When required by law.
  • To provide agreed-upon services.

    • To protect your data:

  • Access is restricted to employees, agents, or partners who need the information to deliver services.
  • You are encouraged to safeguard your account by logging out on shared devices and ensuring strong password security.

    • Cookies

    Cookies are small files used to track activity on the Xtrempay website during your session. Xtrempay uses encrypted session cookies, which:

  • Are erased after a predefined timeout or when you log out and close your browser.
  • Do not collect personal information but store session identifiers.

    • Certain features of our website may be unavailable if cookies are disabled.

    Remedies for Violations

    If there is a violation of this policy, our Data Protection Officer (DPO) will address it within 7 days. For unauthorized disclosure of your data:

  • The information will be retracted immediately.
  • Confirmation of retraction will be sent to you within 48 hours of redress.

    • Governing Law

    This Privacy Policy aligns with the Nigeria Data Protection Regulation (2019) and other applicable Nigerian laws and international conventions.

    Contact Us

    For questions or concerns about this Privacy Policy or your personal data, contact us through:

  • App Messaging: Send a message via the Xtrempay app.
  • Email:dpo@xtrempay.com.
  • Postal Address: Plot 38, Abosan Orere Estate, Ikorodu, Lagos.