Privacy Statement & Cookie Notice

This Statement informs you about how we collect, use, store, disclose, safeguard, and otherwise process your personal information - and explains your rights under data protection law.

Personal information may occasionally be processed in another country. In such cases, we ensure recipients are bound by code, law, contracts, or corporate rules that provide adequate protection. In the absence of such protection, transfers may still occur where:

• You have given informed consent despite understanding possible risks.
• It is necessary for the performance of a contract you are party to.
• It is for your sole benefit and obtaining consent is not reasonably practicable.
• It is required for important reasons of public interest.
• It is necessary for the establishment, exercise, or defence of legal claims.
• It is necessary to protect your vital interests where you cannot consent.

The personal data we collect includes information you provide directly - identity, contact, biometric, delivery address, and financial data. Specifically:

• Contact details - name, postal address, phone numbers, and email addresses.
• Demographic information - date of birth, age or age range, and gender.
• Online registration data - passwords and other authentication credentials.
• Payment information - ATM card details and billing address.
• Survey responses - answers to customer satisfaction surveys or market research.
• Competition entries and submissions.

We automatically collect and store information about your use of our platform - searches, views, downloads, and purchases. We may also receive data from carriers, payment providers, merchants, and advertising services. This includes:

• Name and age (or predicted age range).
• Device, operating system, browser, and IP address.
• Unique identifiers associated with your device.
• Details of web pages you have visited.
• Products searched for, viewed, purchased, or added to a basket.
• Time spent on website areas, and date and time of your visit.
• Personal data in user-generated content, social media usernames, and profile information.

Cookies help us distinguish you from other users and provide an enhanced experience. We use cookies to:

• Recognise and count users, and understand how they navigate the site.
• Identify your preferences and personalise your experience.
• Send newsletters and advertising messages tailored to your interests.

Approved third parties - including search engines, analytics providers, social networks, and advertisers - may also set cookies when you use our services.

We use your personal data to operate, provide, and improve our services, including:

• Registering you as a new user or merchant.
• Providing TradEX services to you.
• Managing your ongoing relationship with us.
• Enabling you to participate in promotions, competitions, and surveys.
• Improving our website, applications, products, and services.
• Recommending and advertising products or services of interest to you.
• Complying with legal obligations, including identity verification.
• Detecting fraud and abuse.

The lawful bases we rely on include:

• Your consent to use our services.
• Processing necessary to deliver TradEX services under our Terms of Use.
• Processing required to remain compliant with applicable laws and regulations.

We may share your personal data with third parties for the following purposes:

• Provision of Services - To process transactions, we may share contact and purchase data with relevant merchants.
• Third-party providers - We engage third parties for data analysis, marketing, payment processing, content delivery, risk management, and customer service.
• Business transfers - Customer information may transfer as part of a sale or acquisition of business assets.
• Fraud prevention - We may release data to other companies for fraud protection, credit risk reduction, and legal compliance.

We require all third parties to handle your data in accordance with this Statement and applicable law. We do not permit them to use your data for their own purposes.

We may transfer your personal data to locations in another country where permissible under applicable law. Where international transfers occur, we put in place appropriate safeguards to protect your data and respect your legal rights pursuant to this Statement and local law.

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used without authorisation, altered, or disclosed. Access is limited on a strict need-to-know basis; all such parties are subject to a duty of confidentiality.

In compliance with PCI DSS requirements, we implement access controls, encryption, firewall technologies, and periodic security updates to protect card information. We have also appointed Data Protection Officers to ensure compliance with the Nigerian Data Protection Regulation (NDPR).

We process your personal data for the minimum period necessary for the purposes in this Statement. Your information may be retained in identifiable form only for as long as:

• We maintain an ongoing relationship with you.
• Your information is necessary for the stated purposes and we have a valid legal basis.
• Any applicable limitation period during which a legal claim could be brought.

We actively review the personal data we hold and delete or anonymise it when there is no longer a legal, business, or consumer need for retention.

Please keep us informed of any changes to your personal data to ensure our records remain accurate. Under certain circumstances, you have rights under data protection law, including the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete personal data.
• Erase your personal data (in certain circumstances).
• Object to or restrict our processing of your data.
• Unsubscribe from marketing emails and newsletters.

This Privacy Statement may be modified as needed. All amended versions will be posted on our website and other platforms. You are encouraged to review this policy periodically. Continued use of TradEX services after an update constitutes your express consent to any amendments.

For more information on how we process your personal data, or to exercise your legal rights, please reach out to us directly: