Privacy Policy

3. Personal Data We Collect

The information we collect depends on the FinQard services you use and how you interact with us.

3.1 Identity Information

We may collect first name, last name, full legal name, date of birth, gender where necessary, National Identification Number (NIN), Bank Verification Number (BVN), government-issued identification, photograph or selfie, facial verification information and other information required for identity verification.

3.2 Contact Information

We may collect telephone number, email address, residential address and other contact information you provide.

3.3 Financial and Banking Information

We may collect bank name, bank account number, account holder name, payment references, payment and payout information, wallet balances and transaction information, funding information and other information necessary to process financial transactions.

3.4 Cryptocurrency Information

Where you use cryptocurrency-related services, we may process cryptocurrency wallet addresses, blockchain networks, transaction hashes, transaction amounts, cryptocurrency type, deposits and withdrawals, blockchain transaction history relevant to a transaction, wallet risk information and related transaction information.

Blockchain transactions may be publicly accessible independently of FinQard because of the nature of public blockchain networks.

3.5 Gift Card Information

Where you use FinQard's gift card services, we may collect gift card brand, card type, denomination, currency, country or region, gift card images, card codes or related information where necessary, proof of purchase where requested, transaction value and information relating to verification and processing of the gift card.

3.6 Virtual Card Information

Where virtual card services are available, FinQard and its relevant card-service providers may process cardholder identity, card issuance and status, card funding and balance, transaction amounts and currencies, merchants and merchant categories, transaction dates and times, transaction location information where available, authorisations, declined transactions, reversals, refunds, chargebacks, billing information, and fraud and security information.

FinQard may not directly issue virtual cards. Card services may be provided through third-party financial institutions, card issuers, payment processors, card networks or other service providers.

3.7 Bill Payment Information

Where you use bill-payment services, we may collect bill type, service provider, customer or meter number, telephone number, account identifier, payment amount, payment reference and transaction status.

3.8 Device and Technical Information

We may automatically collect IP address, device type, operating system, browser, application version, device identifiers, login timestamps, session information, crash information, diagnostic data, security logs and other technical information.

3.9 Communications

We may retain customer-support conversations, emails, complaints, enquiries, dispute information, feedback and other communications.

3.10 Compliance and Risk Information

We may collect or generate information relating to KYC verification, identity-verification results, sanctions screening, fraud indicators, transaction-monitoring alerts, account security, suspicious activity, compliance reviews and risk assessments.

4. How We Collect Personal Data

We may obtain personal data directly from you; when you register an account, complete KYC, perform a transaction or contact customer support; through our website or applications; from banks and payment providers; identity-verification providers; card issuers and processors; blockchain networks and analytics providers; fraud-prevention and compliance providers; publicly available sources; and other third parties where legally permitted.

5. How We Use Personal Data

FinQard may use personal data to create and maintain accounts; verify identity; authenticate account access; provide FinQard services; process gift card and cryptocurrency transactions; provide wallet functionality; facilitate payments and payouts; provide bill-payment services; facilitate virtual card issuance and management through relevant providers; fund and manage virtual cards; process card transactions; communicate transaction status; provide customer support; investigate disputes; prevent fraud and scams; detect unauthorised transactions; perform transaction monitoring; conduct KYC and AML/CFT/CPF compliance; perform sanctions screening where applicable; protect accounts and platform security; comply with legal obligations; enforce our Terms and policies; improve products; perform analytics; diagnose technical problems; communicate important service information; send marketing communications where permitted; and establish, exercise or defend legal claims.

6. Lawful Bases for Processing

Depending on the circumstances, FinQard may process personal data based on contractual necessity, legal obligation, consent, legitimate interests or other lawful bases recognised under applicable law.

Where processing depends on consent, you may withdraw that consent subject to applicable law.

Legitimate interests may include fraud prevention, cybersecurity, platform security, service improvement, protecting FinQard and its customers, and establishing or defending legal claims.

7. KYC and Identity Verification

FinQard may use third-party service providers to verify customer identities. Information provided during KYC may be checked against authorised identity databases or other verification sources.

FinQard may share relevant personal data with identity-verification providers where necessary for identity verification, fraud prevention, regulatory compliance, account security and risk management.

8. How We Share Personal Data

FinQard does not sell your personal data.

We may share personal data where necessary with identity-verification providers; banks; payment processors and service providers; virtual account providers; card issuers, processors and networks; cryptocurrency and wallet infrastructure providers; blockchain analytics providers; bill-payment providers; cloud infrastructure, database and storage providers; email and communications providers; analytics providers; cybersecurity and fraud-prevention providers; compliance and sanctions-screening providers; professional advisers; auditors; insurers; and other technology providers supporting FinQard.

We may also disclose information to regulators, courts, law enforcement agencies and other competent authorities where required or permitted by law.

9. Virtual Card Providers and Payment Networks

Where you request or use a virtual card, personal data may need to be shared with the relevant card issuer, processing partner, payment network or financial institution.

These parties may process information necessary to verify cardholders, issue cards, authorise and settle transactions, process refunds, manage chargebacks, prevent fraud, comply with legal obligations and operate card services.

Some providers may act as independent data controllers for certain processing activities and may have their own privacy policies.

10. International Data Transfers

Some FinQard service providers may process or store personal data outside Nigeria.

Where personal data is transferred internationally, FinQard will take appropriate measures required under applicable data protection law to ensure the transfer is subject to appropriate safeguards or another legally recognised basis.

11. Data Security

FinQard maintains technical and organisational measures designed to protect personal data against unauthorised access, accidental loss, unlawful processing, alteration, disclosure, destruction and misuse.

Measures may include encryption, access controls, authentication, logging, security monitoring, restricted employee access, secure infrastructure, backups, vulnerability management and incident-response procedures.

No electronic system or method of data transmission or storage can be guaranteed to be completely secure. Customers are responsible for keeping passwords, PINs, verification codes and other account credentials confidential.

12. Card Security

FinQard and its card-service providers may implement additional security measures relating to virtual cards.

Customers must protect card details, card credentials, PINs where applicable, one-time passwords, authentication codes and FinQard account credentials.

Suspected unauthorised card transactions should be reported promptly through FinQard's official support channels.

13. Data Rentention

FinQard retains personal data for only as long as reasonably necessary for the purposes for which it was collected and to satisfy applicable legal, regulatory, AML/KYC, accounting, tax, fraud-prevention, dispute-resolution and legitimate business requirements.

Certain identity, transaction and compliance information may therefore be retained after you close your FinQard account.

14. Your Privacy Rights

Subject to applicable law, you may have the right to obtain information about processing; request access to personal data; request correction or completion; request deletion in applicable circumstances; request restriction of processing; object to certain processing; withdraw consent where applicable; request data portability; object to certain automated decision-making; and lodge a complaint with the Nigeria Data Protection Commission or another competent authority.

These rights are not absolute. FinQard may be legally required to retain KYC, transaction, fraud-prevention or AML records even after receiving a deletion request.

15. Automated Processing and Fraud Detection

FinQard may use automated systems to assist with identity verification, fraud detection, transaction monitoring, account security, risk assessment and suspicious activity detection.

Where applicable law gives you rights concerning decisions based solely on automated processing that significantly affect you, FinQard will provide appropriate mechanisms for exercising those rights.

16. Cookies and Similar Technologies

FinQard's website and applications may use cookies, software development kits and similar technologies to maintain sessions, authenticate users, remember preferences, measure performance, understand product usage, detect fraud, improve security and improve FinQard's Services.

Where required, FinQard will provide appropriate choices regarding non-essential cookies.

17. Marketing Communications

Where permitted, FinQard may send information about products, new features, promotions, offers, rewards and company updates.

You may unsubscribe from marketing communications using the unsubscribe option provided or other available preference controls.

Even if you unsubscribe from marketing, FinQard may continue sending essential transaction notifications, account notifications, security alerts, compliance communications, legal notices and service-related communications.

18. Children's Privacy

FinQard's transactional financial services are intended only for persons who meet applicable age and eligibility requirements.

Where required by applicable law, FinQard will notify the Nigeria Data Protection Commission and/or affected individuals within applicable legal requirements and may take steps to contain the incident, investigate its cause, secure affected systems, minimise potential harm and prevent recurrence.

19. Data Breaches

FinQard maintains procedures for responding to suspected or confirmed personal data breaches.

Where required by applicable law, FinQard will notify the Nigeria Data Protection Commission and/or affected individuals within applicable legal requirements and may take steps to contain the incident, investigate its cause, secure affected systems, minimise potential harm and prevent recurrence.

20. Third-Party Services

FinQard may integrate with or provide links to third-party websites, platforms and services.

Independent third parties may operate under their own privacy policies and terms. FinQard is not responsible for the independent privacy practices of third parties that are not processing personal data on FinQard's behalf.

21. Changes To This Privacy Policy

FinQard may update this Privacy Policy as its services, technology, business operations or legal obligations change.

Where appropriate, we may notify users of material changes through the FinQard website, application, email, push notification or another appropriate communication channel.