Privacy Policy

We may collect:

1. full name;
2. date of birth;
3. gender, where applicable;
4. Nationality;
5. photograph or selfie;
6. National Identification Number (NIN);
7. Bank Verification Number (BVN);
8. Tax Identification Number (where applicable);
9. government-issued identification documents;
10. signatures;
11. other identity verification information required by law.

We may collect:

1. residential address;
2. correspondence address;
3. email address;
4. telephone number;
5. emergency contact details where applicable.

Depending on the services you use, we may collect:

1. wallet information;
2. linked bank account details;
3. account balances;
4. savings information;
5. transaction history;
6. payment history;
7. merchant information;
8. recurring payment details;
9. bill payment information;
10. salary or income information where voluntarily provided or lawfully obtained;
11. loan application information;
12. repayment history;
13. credit-related information obtained from licensed credit bureaus;
14. financial goals and savings preferences.

To comply with KYC and AML obligations, we may collect:

1. proof of address;
2. source of funds;
3. source of wealth;
4. employment information;
5. occupation;
6. business information;
7. politically exposed person (PEP) declarations;
8. sanctions screening information;
9. enhanced due diligence documentation where required.

When you use the Platform, we may automatically collect:

1. device model;
2. operating system;
3. browser type;
4. application version;
5. IP address;
6. device identifiers;
7. mobile network information;
8. language preferences;
9. time zone;
10. crash reports;
11. diagnostic information;
12. security logs.

Where you grant permission, we may collect:

1. GPS location;
2. approximate location;
3. device location;
4. transaction location;
5. merchant location.

Location information may be used for fraud prevention, security, regulatory compliance and personalized financial services.

We may collect information regarding your interaction with the Platform, including:

1. login history;
2. pages viewed;
3. features used;
4. session duration;
5. clickstream data;
6. transaction frequency;
7. spending patterns;
8. savings behaviour;
9. user preferences;
10. communication preferences.

Where enabled by you or required for identity verification, we may process:

1. facial recognition data;
2. liveness detection results;
3. fingerprint authentication confirmations;
4. other biometric authentication information supported by your device.

Biometric information is processed solely for authentication, fraud prevention and regulatory compliance.

Our AI systems may generate:

1. spending categories;
2. budgeting recommendations;
3. cash flow forecasts;
4. financial health indicators;
5. Wellness Scores;
6. fraud risk indicators;
7. savings recommendations;
8. personalized financial insights;
9. product eligibility recommendations.

AI-generated information is derived from data already available to us and is used solely for the purposes described in this Privacy Policy.

You provide information directly when you:

1. create an account;
2. complete KYC verification;
3. update your profile;
4. link financial accounts;
5. make transactions;
6. apply for financial products;
7. contact Customer Support;
8. participate in surveys or promotions;
9. communicate with us.

Certain information is collected automatically through your use of the Platform, including:

1. device information;
2. application usage;
3. security logs;
4. technical diagnostics;
5. cookies and similar technologies where applicable;
6. fraud monitoring systems.

We may receive information from licensed financial institutions providing services connected to the Platform, including:

1. account verification;
2. payment confirmations;
3. savings information;
4. loan servicing information;
5. transaction confirmations;
6. account status.

Where you choose to connect eligible financial accounts, we may receive financial information from participating institutions in accordance with your express consent and applicable law.

We may lawfully obtain information from:

1. identity verification providers;
2. credit bureaus;
3. fraud prevention agencies;
4. sanctions screening providers;
5. regulatory databases;
6. public records;
7. analytics providers;
8. technology service providers.

Our websites and digital platforms may use cookies, software development kits (SDKs), web beacons and similar technologies to improve functionality, security, analytics and user experience.

Where required by law, your consent will be obtained before placing non-essential cookies on your device.

We process your information where necessary to:

1. create and maintain your Account;
2. provide the services you request;
3. process payments;
4. facilitate savings;
5. provide financial insights;
6. administer lending services;
7. operate the Platform.

We process personal information where necessary to comply with obligations arising under applicable laws, including obligations relating to:

1. KYC;
2. AML/CFT/CPF;
3. fraud prevention;
4. regulatory reporting;
5. tax compliance;
6. financial record keeping;
7. consumer protection.

Subject to applicable law and your rights, we may process information where necessary for our legitimate interests, including:

1. improving the Platform;
2. developing new products;
3. strengthening cybersecurity;
4. fraud detection;
5. risk management;
6. customer support;
7. internal administration;
8. business analytics;
9. service quality improvement.

Where required by law, we process personal information based on your consent.

This may include processing relating to:

1. Open Banking connections;
2. personalized marketing communications;
3. optional location services;
4. certain AI-powered personalization features;
5. cookies requiring consent.

You may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Where necessary, we may process personal information to protect your vital interests or those of another person, including responding to emergencies, preventing fraud or protecting customer funds.

Where permitted by applicable law, we may process personal information in the public interest or in the exercise of official authority conferred upon competent regulatory or law enforcement authorities.

We use your information to:

1. create and manage your ChequeIn Account;
2. verify your identity;
3. maintain your Wallet;
4. facilitate savings and financial management services;
5. process transfers and payments;
6. enable lending and repayment services where applicable;
7. generate account statements;
8. provide customer support;
9. administer your account settings and preferences.

We process your information to:

1. perform Know Your Customer (KYC) verification;
2. comply with Anti-Money Laundering, Counter-Terrorism Financing and Counter-Proliferation Financing obligations;
3. conduct sanctions and Politically Exposed Person (PEP) screening;
4. prevent identity theft;
5. investigate suspicious transactions;
6. comply with regulatory reporting obligations;
7. respond to lawful requests from regulators and law enforcement agencies.

Your information is used to:

1. authenticate transactions;
2. execute payment instructions;
3. process deposits and withdrawals;
4. reconcile financial records;
5. resolve failed transactions;
6. monitor transaction activity;
7. investigate disputed transactions.

To help you better manage your finances, we may use your information to:

1. categorize transactions;
2. prepare spending reports;
3. identify recurring expenses;
4. track savings goals;
5. monitor financial habits;
6. generate budgeting recommendations;
7. forecast cash flow;
8. identify opportunities to improve savings.

Your transaction history, savings behaviour, spending patterns and other relevant financial information may be analysed to generate your Wellness Score.

The Wellness Score is intended to provide an indication of your financial habits and assist you in making informed financial decisions.

The Wellness Score is informational only and does not constitute financial advice or guarantee eligibility for any financial product.

We process information to:

1. detect fraud;
2. identify suspicious transactions;
3. prevent unauthorized access;
4. monitor cybersecurity threats;
5. investigate security incidents;
6. authenticate users;
7. improve platform security.

We may use information to:

1. improve existing products;
2. develop new features;
3. enhance user experience;
4. conduct research and analytics;
5. test system functionality;
6. improve AI models;
7. monitor platform performance.

We use your information to send:

1. transaction notifications;
2. account alerts;
3. security notifications;
4. service announcements;
5. regulatory notices;
6. customer support responses;
7. marketing communications where you have consented or where otherwise permitted by law.

ChequeIn uses Artificial Intelligence (AI), machine learning and other automated technologies to improve your experience and deliver intelligent financial management services.

AI may be used to:

1. categorize transactions;
2. identify spending trends;
3. recommend budgets;
4. generate savings insights;
5. estimate future cash flow;
6. generate Wellness Scores;
7. identify unusual transaction patterns;
8. support fraud detection;
9. recommend financial products;
10. assist customer support.

Certain services may involve automated analysis of your financial information to:

1. assess product suitability;
2. estimate affordability;
3. identify potential savings opportunities;
4. generate financial recommendations;
5. evaluate risk indicators;
6. support eligibility assessments for selected financial services.

Where legally required, significant decisions affecting your rights or interests will not be based solely on automated processing without appropriate safeguards.

Where an automated decision significantly affects you, and applicable law provides such right, you may request that the decision be reviewed by an appropriately authorized member of our team or, where applicable, our licensed financial partner.

Human review does not guarantee that the outcome will change but ensures that relevant circumstances are considered.

AI-generated outputs, including Wellness Scores, budgeting recommendations and financial insights:

1. are estimates based on available information;
2. may not reflect all relevant circumstances;
3. should not be regarded as professional financial, legal, investment or tax advice;
4. should be considered alongside your own financial judgment.

We may use anonymized or aggregated information to improve our AI models, provided that such processing complies with applicable law and does not identify individual users.

Where supported, you may choose to connect eligible financial accounts maintained with participating financial institutions.

Connected accounts allow the Platform to provide a consolidated view of your financial information.

We access connected financial information only after obtaining your express authorization.

Your authorization may be withdrawn at any time, subject to legal and regulatory obligations.

Subject to your consent, we may access:

1. account balances;
2. transaction history;
3. account identifiers;
4. recurring payments;
5. direct debit information;
6. merchant details;
7. income information;
8. spending patterns;
9. financial product information.

Open Banking information may be used to:

1. generate financial insights;
2. improve budgeting;
3. support Wellness Scores;
4. verify account ownership;
5. detect fraud;
6. facilitate account linking;
7. assess eligibility for financial products;
8. improve customer experience.

Open Banking connections use secure authentication methods and industry-standard encryption.

We do not collect your online banking passwords or credentials unless specifically required by a regulated authentication process authorized by the relevant financial institution.

You may disconnect linked financial accounts through the Platform at any time.

Withdrawal of consent may limit the availability of certain features that rely on connected financial information.

Where necessary to provide regulated financial services, your information may be shared with licensed financial institutions supporting services available through the Platform.

Personal information may be shared with regulated payment infrastructure providers to process payments, transfers and settlement instructions.

We may disclose information to trusted identity verification providers for:

1. identity verification;
2. document authentication;
3. biometric verification;
4. fraud prevention;
5. sanctions screening.

Where permitted by law and applicable to the services you request, information relating to lending products may be shared with licensed credit bureaus.

We may engage carefully selected third-party service providers to support:

1. cloud hosting;
2. customer support;
3. cybersecurity;
4. fraud monitoring;
5. analytics;
6. software development;
7. communication services;
8. document storage.

Such providers are contractually required to protect your information and process it only on our documented instructions.

We may disclose personal information where required or permitted by law to:

1. the Central Bank of Nigeria;
2. the Nigeria Data Protection Commission;
3. the Nigerian Financial Intelligence Unit;
4. law enforcement agencies;
5. courts and tribunals;
6. other competent governmental authorities.

If Trybesave undergoes a merger, acquisition, restructuring, investment transaction or sale of assets, personal information may be transferred to the relevant successor entity, subject to applicable law and appropriate confidentiality safeguards.

Certain service providers supporting the Platform may process information outside Nigeria.

Where personal information is transferred internationally, Trybesave shall ensure that appropriate safeguards are implemented in accordance with applicable Nigerian law.

Where required, cross-border transfers shall be protected through one or more appropriate mechanisms, including:

1. contractual safeguards;
2. legally recognized transfer mechanisms;
3. regulatory approvals where applicable;
4. adequate security controls;
5. encryption;
6. organizational measures designed to protect personal information.

Where information is transferred outside Nigeria, Trybesave shall take reasonable steps to ensure that recipients provide a level of protection that is not materially lower than that required under applicable Nigerian data protection laws.

Our websites and digital platforms may use cookies and similar technologies to improve functionality, remember your preferences, enhance security and analyse how the Platform is used.

We may use:

1. cookies;
2. software development kits (SDKs);
3. local storage;
4. web beacons;
5. pixels;
6. session identifiers;
7. device identifiers.

These technologies may be used to:

1. authenticate users;
2. maintain secure sessions;
3. remember preferences;
4. improve application performance;
5. analyse user behaviour;
6. detect fraud;
7. measure service effectiveness;
8. diagnose technical issues.

We may use analytics tools to understand how customers interact with the Platform.

Analytics information is used to improve functionality, identify system issues and enhance customer experience.

Where practicable, analytics information is aggregated or de-identified.

Where required by applicable law, you may manage your cookie preferences through your browser settings or any cookie management tools made available by Trybesave.

Please note that disabling certain cookies or similar technologies may affect the functionality or performance of the Platform.

The security of your personal information is a priority for Trybesave. We implement appropriate technical, administrative and organizational measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access or misuse.

While we strive to protect your information using industry-standard security controls, no electronic transmission or storage system can be guaranteed to be completely secure. You are encouraged to take reasonable precautions to safeguard your account credentials and devices.

Depending on the nature of the service provided, we may implement one or more of the following safeguards:

1. Encryption of data in transit and at rest;
2. Secure network architecture and firewalls;
3. Multi-Factor Authentication (MFA);
4. Device binding and trusted device verification;
5. Biometric authentication where enabled by you;
6. Role-based access controls;
7. Security monitoring and logging;
8. Fraud detection and transaction monitoring systems;
9. Malware protection and vulnerability management;
10. Penetration testing and periodic security assessments;
11. Backup, disaster recovery and business continuity procedures;
12. Employee confidentiality obligations and security awareness training.

You are responsible for maintaining the confidentiality of your:

1. password;
2. security PIN;
3. one-time passwords (OTPs);
4. biometric authentication methods;
5. security questions;
6. registered devices.

You must immediately notify Trybesave if:

1. your device is lost or stolen;
2. you suspect unauthorized access to your Account;
3. your login credentials have been compromised; or
4. you discover any unauthorized transaction.

Where a personal data breach occurs that is likely to result in a risk to your rights or freedoms, Trybesave will investigate the incident, take appropriate remedial action and notify the Nigeria Data Protection Commission (NDPC) and affected individuals where required under applicable law.

We retain personal information only for as long as reasonably necessary to:

1. provide our services;
2. maintain your Account;
3. comply with applicable legal and regulatory obligations;
4. detect and investigate fraud;
5. resolve complaints and disputes;
6. enforce contractual rights;
7. satisfy audit and accounting requirements.

Transaction records, KYC documentation, communications and other financial records may be retained for the periods prescribed by applicable Nigerian laws and regulatory requirements.

During the applicable retention period, personal information is securely stored and protected against unauthorized access, disclosure, alteration or destruction.

Access to retained information is restricted to authorized personnel and service providers with a legitimate business or legal need.

Where personal information is no longer required for legal, regulatory or operational purposes, it will be securely deleted, anonymized or irreversibly de-identified in accordance with our data retention policies.

Where deletion cannot occur immediately due to statutory obligations, the information will remain securely archived until deletion becomes legally permissible.

You may request confirmation of whether we process your personal information and obtain a copy of the information we hold about you.

You may request correction of inaccurate, incomplete or outdated personal information.

Where processing is based on your consent, you may withdraw that consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

You may request deletion of your personal information where permitted under applicable law.

We may decline such requests where continued retention is necessary to comply with legal or regulatory obligations, prevent fraud, resolve disputes or establish, exercise or defend legal claims.

Where permitted by law, you may request that we temporarily restrict the processing of your personal information in certain circumstances.

You may object to processing carried out on the basis of our legitimate interests where your rights and freedoms outweigh those interests.

Where technically feasible and legally applicable, you may request that certain personal information be provided in a structured, commonly used and machine-readable format or transferred to another service provider.

Where a decision that significantly affects you is based solely on automated processing, you may request human intervention, express your views and contest the decision, subject to applicable law.

Requests relating to your privacy rights may be submitted through the Platform or by contacting our Data Protection Officer.

We may request additional information to verify your identity before processing your request.

We may send you communications necessary for the administration, security and operation of your Account, including:

1. transaction notifications;
2. login alerts;
3. fraud alerts;
4. security notifications;
5. password reset messages;
6. account updates;
7. regulatory notices;
8. maintenance notifications.

These communications are essential to the operation of the Platform and cannot generally be disabled while your Account remains active.

Where permitted by law or based on your consent, we may send information regarding:

1. new products and services;
2. savings campaigns;
3. financial education;
4. budgeting tips;
5. AI-generated financial insights;
6. promotions and referral programmes;
7. rewards and loyalty programmes;
8. customer surveys and research.

You may update your communication preferences within the Platform or unsubscribe from promotional communications using the instructions provided in our communications.

Opting out of promotional communications will not affect the delivery of essential service or regulatory communications.