Privacy Policy

1. Introduction

Welcome to Manilla Finance (“Manilla,” “we,” “our,” or “us”). We value your privacy and are fully committed to protecting your personal information in accordance with the Nigeria Data Protection Regulation (NDPR), the Nigerian Constitution, and other relevant Nigerian laws and regulations. This Privacy Policy explains in detail how we collect, use, disclose, and protect your personal data when you use our mobile application, website, and related services (collectively, “Services”). Please read this policy carefully. By accessing or using our Services, you acknowledge that you have read, understood, and agreed to the terms herein. If you do not agree, please do not use the Services.

2. Information We Collect

To provide you with a seamless and secure service, Manilla Pay collects various types of personal data:

2.1 Personal Identification Information:

We collect your full name, date of birth, valid Nigerian government-issued identification numbers (e.g., National ID, Driver’s License, International Passport), email address, phone number, and residential address. This data is necessary for identity verification under KYC (Know Your Customer) and AML (Anti-Money Laundering) requirements.

2.2 Financial and Payment Information:

This includes your bank account details, debit/credit card information (which is processed securely by PCI-DSS certified third parties), and your cryptocurrency wallet addresses when you opt to pay or receive payments using digital assets like USDC or USDT.

2.3 Transaction Data:

We record detailed information about your bill payments, purchases, invoice histories, transaction timestamps, transaction amounts, and crypto wallet activity on our platform to ensure accurate records and compliance with Nigerian financial regulations.

2.4 Device and Technical Data:

To optimize your experience and maintain security, we collect technical information such as IP addresses, device types (smartphone, tablet), operating systems, browser types, mobile network information, and app usage statistics. This helps us diagnose issues and improve app performance.

2.5 Location Data:

With your explicit consent, we may collect your geolocation data for fraud prevention, security checks, and to offer location-based services like nearest vendor or branch locations.

2.6 Cookies and Tracking Technologies:

We use cookies and similar technologies on our website and app to remember your preferences, improve functionality, and collect usage analytics. Please refer to our separate Cookie Policy for more information.

3. How We Use Your Information

Your data is used strictly for legitimate business purposes, including but not limited to:

Service Delivery: Processing payments, enabling bill payments, travel bookings, crypto transactions, and other service features. Identity Verification and Compliance: Performing KYC and AML checks required by Nigerian law to prevent fraud, money laundering, and financing of terrorism. Customer Support: Handling inquiries, complaints, refunds, disputes, and providing technical assistance. Service Improvement: Analyzing user behavior and feedback to enhance our platform’s security, functionality, and user experience. Marketing and Communication: With your prior consent, sending you newsletters, promotions, product updates, or special offers via email, SMS, or in-app notifications. Legal Obligations: Complying with lawful requests from regulatory bodies, law enforcement agencies, or courts in Nigeria.

4. Sharing Your Information

Manilla Pay is committed to safeguarding your privacy and will only share your information under strict conditions:

Third-Party Service Providers: We may share your data with trusted vendors such as payment processors (e.g., Paystack), identity verification services, cloud hosting providers, and blockchain networks. These providers are contractually obligated to protect your data and use it solely for service delivery. Regulatory and Law Enforcement Authorities: We may disclose your personal data when required by Nigerian law, court orders, or governmental investigations. Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity under confidentiality obligations. With Your Consent: We may share information if you expressly agree or request so. We do not sell, rent, or trade your personal data to third parties for marketing purposes.

5. Data Security

We implement robust security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These include:

Industry-standard encryption protocols (e.g., SSL/TLS) for data transmission. Secure data storage in encrypted databases hosted on Nigerian and internationally certified servers. Regular security audits, vulnerability assessments, and penetration testing. Access controls ensuring only authorized personnel can access sensitive information. Use of PCI-DSS compliant partners for all card payment processing; Manilla Pay itself does not store your card details. Blockchain technology for immutable transaction records and enhanced security on crypto payments. Despite these measures, no system can guarantee 100% security. We urge users to safeguard their passwords and devices.

6. Data Retention

Your personal data will be retained only as long as necessary to:

Fulfill the purposes outlined in this policy, Comply with applicable Nigerian laws (including tax and financial record-keeping), Resolve disputes or enforce agreements, or Protect legal rights. After such periods, your data will be securely deleted or anonymized.

7. Your Rights Under Nigerian Law

Under the NDPR, you have the right to:

Access: Request a copy of the personal data we hold about you. Correction: Request correction of inaccurate or incomplete information. Deletion: Request deletion of your personal data, subject to legal or contractual retention obligations. Restriction: Request restriction on the processing of your personal data in certain circumstances. Objection: Object to the processing of your data for marketing purposes. Data Portability: Request transfer of your data to another service provider, where technically feasible.

To exercise any of these rights, please contact our Data Protection Officer at dpo@manilla.finance. We will respond within the timeframe mandated by Nigerian law.

8. Children’s Privacy

Manilla Pay does not knowingly collect personal data from children under the age of 18. If we learn that we have inadvertently collected such data, we will promptly delete it.

9. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our services, technology, or regulatory requirements. We will notify you of significant changes via email or app notifications. Please review this policy regularly to stay informed.

10. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact: Data Protection Officer, Manilla Finance Nigeria Email: dpo@manilla.finance