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-1805683), 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.

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.

Purpose of Data Processing

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

• Service Delivery
  • Verifying your account and providing secure access.
  • Communicating important information about your account or transactions.
• Issue Resolution

  Resolving disputes and addressing technical issues.

• Regulatory Compliance

  Meeting legal obligations and enforcing site/service terms.

• Fraud Management

  Preventing fraud and verifying identities for your safety.

• Marketing (with consent)
  • Informing you about Xtremepay products or services.
  • Utilizing cookies for tailored features and offers.
• 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:

• Consent

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

• Contractual Necessity

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

• Legal Obligations

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

• Legitimate Interests

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

• 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:

• Sign-Up Information

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

• Transaction Data

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

• Participant Data

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

• External Sources

  Data from social media platforms when resolving complaints or inquiries.

• Customer Support

  Information from interactions with our support teams.

• Job Applications

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

• 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), Xtremepay 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 contracts. 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.
• 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:

• Access and Transparency

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

• Rectification and Erasure

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

• Restriction of Processing

  The right to limit the use of your personal data.

• Objection to Processing

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

• Data Portability

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

• Withdrawal of Consent

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

• Automated Decision-Making

  The right to object to automated processing, including profiling.

• 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 [email protected] 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 [email protected].