Privacy Policy

  1. Introduction

    Africhange Technologies Limited (“NairaEx Pro”, “we” or “ us”) are committed to protecting your privacy and safeguarding your personal information. The purpose of this privacy policy (the “Privacy Policy”) is to inform you about our privacy practices, including how we collect, use and disclose your personal information. This Privacy Policy applies to our website, mobile applications, digital asset trading platform and related services (collectively, the “NairaEx Pro Services”). By visiting, accessing, or using the NairaEx Pro Services, you consent to the policies and practices of this Privacy Policy so please read them carefully. If any policies or practices of this Privacy Policy are unacceptable to you, please do not visit, access, or use the NairaEx Pro Services.

  2. What's in this privacy policy?

    • Privacy Policy Amendments
    • Personal Information We Collect
    • How we use personal information
    • How we share personal information
    • Privacy of Digital Assets
    • Information Security
    • Retention of personal information
    • Rights regarding your Personal Information
    • Direct Marketing
    • Data Transfer
    • Third Party Websites and Services
    • Children's Privacy
    • Contact Us
  3. Privacy Policy Amendments

    Your privacy matters to us so whether you are new to the NairaEx Pro Services or a long-time user, please take the time to get to know and familiarize yourself with our policies and practices. Feel free to print and keep a copy of this Privacy Policy, but please understand that we reserve the right to change any of our policies and practices at any time. But don’t worry, you can always find the latest version of this Privacy Policy here on this page. Visiting, accessing, or using the NairaEx Pro Services following any changes to this Privacy Policy is considered to be your acceptance of any such changes. You should, therefore, read this Privacy Policy from time to time. If you do not agree to be bound by this Privacy Policy, you should not visit, access or use the NairaEx Pro Services.

  4. Personal Information We Collect

    • The personal information we collect about you may include the following. In each case, we identify the grounds that we rely on to process your personal information under the Data Protection Regulation 2019 (“Act”):
    • Account Profile – when you open an account, we may collect your name, email address, phone number, home address, date of birth, bank verification number or any comparable identification number issued by a governmental authority and any other information or documentation we require for identity verification (e.g. driver’s license, passport or other government-issued ID) or other legal compliance purposes (for more information, please read our AML & KYC Policy). Applicable legal grounds: contract performance, consent, legitimate interests (to enable us to perform our obligations and provide our services);
    • Device Information – information that is automatically collected about your device, such as hardware, operating system, browser, etc. Applicable legal grounds: legitimate interests (to allow us to provide content and services on the website), consent, contract performance;
    • Location Information – information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us. Applicable legal grounds: legitimate interests (to allow us to provide content and services on the website), consent, contract performance;
    • · Log Information – information that is generated by your use of the NairaEx Pro Services that is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information, system activity and any internal and external information related to NairaEx Pro pages that you visit. Applicable legal grounds: legitimate interests (to allow us to provide content and services on the website), consent, contract performance;
    • Account Activity – information that is generated by your account activity including, but not limited to, trading activity, order activity, deposits, withdrawals, and account balances. Applicable legal grounds: legitimate interests (to enable us to perform our obligations and provide our services), legal claims, consent, contract performance;
    • Financial Account Transfer Information – information that you provide to us to facilitate the transfer of fiat currency or Digital Assets (as defined below) into and out of your NairaEx Pro account, such as your bank account information and public cryptocurrency wallet address (we do not collect private keys): Applicable legal grounds: legitimate interests (to allow us to provide content and services on the website), consent, contract performance; and
    • Correspondence – information that you provide to us in correspondence, such as when you submit questions or inquiries and with respect to ongoing customer support. Applicable legal grounds: legitimate interests (to enable us to perform our obligations and provide our services), consent, contract performance.

    NairaEx Pro may also make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (“Cookies”) on your computer or other devices used to access the NairaEx Pro Services. Cookies are small bits of information that are automatically stored on the web browser of your device that can be retrieved by us. The type of information we collect includes, but is not limited to, uniquely identifying visitor information and information related to your usage preferences. We use these technologies to help us recognize you as a user, collect information about your use of the NairaEx Pro Services to better customize our services and content for you, and collect information about your computer or other access devices to (i) ensure compliance with our BSA/AML Program (for more information, please read our AML & KYC Policy) and (ii) ensure that your account security has not been compromised by detecting irregular or suspicious account activities. By using the NairaEx Pro Services, you acknowledge and agree that we may collect and/or transmit any data collected to our third-party service providers, such as analytics providers, which may also make use of such technologies described above. Please note that if you block or delete cookies you will not be able to use some or all of the NairaEx Pro Services.

  5. How we use personal information

    • We Take Steps Designed To Ensure That Only Those Employees Who Need Access To Your Personal Information To Fulfil Their Employment Duties Will Have Access To It. We May Use The Personal Information We Collect To: Provide You With The NairaEx Pro Services, Including Customer Support;

    • Optimize And Enhance The NairaEx Pro Services, Including To Develop New Products, Services, Features, And Functionality;
    • Respond To Inquiries And Other Requests;
    • Conduct Anti-Fraud And Identity Verification Checks, Including By Engaging Third Party Services Providers To Assist With Such Checks (For More Information, Please Read Our AML & KYC Policy);
    • Provide You With Information That We Think May Interest You, Including In Regards To Our Products And Services;
    • Monitor The Usage Of The NairaEx Pro Services, Including By Conducting Automated And Manual Security Checks;
    • Understand And Analyze The Usage Trends And Preferences Of Our Users;
    • Create Aggregated And Anonymized Reporting Data About The NairaEx Pro Services;
    • Investigate Legal Claims;
    • Carry Out Such Purposes For Which We May Obtain Consent From Time To Time; And
    • Carry Out Such Other Purposes As May Be Permitted Or Required By Applicable Law.
  6. How we share personal information

    We may disclose your personal information to law enforcement and governmental entities when required by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We may also disclose your personal information to a third party in the event of any potential or completed reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business.

    We rely on third party services providers to perform a variety of services on our behalf, such as identity verification, detection of fraud or security threats, telephone or technical support, payment card processing, hosting services, and data storage or processing, and we may transfer your personal information to our service providers for such purposes. Third party service providers have access to and may collect personal information only as needed to perform their functions and are not permitted to share or use the information for any other purpose. When we disclose your personal information to third parties, we take reasonable measures to ensure that the rules set forth in this Privacy Policy are complied with and that such third parties provide sufficient guarantees to implement appropriate technical and organizational measures to protect your personal information.

  7. Privacy of Digital Assets

    As used herein, “Digital Asset” means a digital asset (also called a “cryptocurrency,” “virtual currency,” “digital currency,” or “digital commodity”), such as Bitcoin or Ether, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.

    Please be aware that Bitcoin, Ether, and other Digital Assets are not necessarily truly anonymous. Generally, anyone can see the balance and transaction history of any public Digital Asset address. We, and any others who can match your public Digital Asset address to other information about you, may be able to identify you from a blockchain transaction. This is because, in some circumstances, information published on a block chain (such as your Digital Asset and IP address) can be correlated with information that we and others may have. This may be the case even if we, or they, were not involved in the blockchain transaction. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other information about you. As part of our security, anti-fraud and/or identity verification and authentication checks, we may conduct such analysis to process such information about you. You acknowledge and agree to allow us to perform such practices.

  8. Information Security

    We take your privacy very seriously and have implemented physical, organizational and technological security measures with a view to protecting your personal information from loss or theft, unauthorized access, disclosure, copying, use or modification. In particular, we encrypt the NairaEx Pro website with SSL; we require two-factor authentication for all user sessions; we periodically review information collection, storage, and processing practices; and we restrict access to your information on a need-to-know basis for our employees, contractors, and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

    Despite the measures outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “Contact Us” section below.

  9. Retention of personal information

    We will use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law.

  10. Rights regarding your Personal Information

    Under certain circumstances and in accordance with the Act and the NDPR or other applicable data protection laws, you have the following rights:

    • Right to request from NairaEx Pro access to and rectification or erasure of your Registration Information;
    • Right to withdraw consent at any time which shall not affect the processing of your
    • Registration Information provided with consent before its withdrawal;
    • Right to lodge a complaint with the National Information Technology Development Agency (NITDA);
    • Right to object to the processing of your Registration Information for the purpose of marketing;
    • Right to request for the deletion of your Registration Information;
    • Right to request for your Registration Information which will be provided in a structured, commonly used and machine-readable format.
  11. Direct Marketing

    Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using information collected from you. If you no longer want to receive marketing-related communications from us, you may opt-out of such communications by clicking the “unsubscribe” link at the bottom of emails you receive from us. You may also opt-out by contacting us directly using the contact information in the “Contact Us” section below. We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us reasonable time to process your request. We will not provide your information to third parties for direct marketing or other unrelated purposes without your written consent.

    Please note that if you opt-out from receiving marketing-related communications, we may still need to send you communications about your use of our products or services, or other matters, subject to applicable laws and regulations.

  12. Data Transfer

    Your personal information may be stored and processed in any country, province or state (each a “Country”) where we have facilities or in which we engage third party service providers. As a result, your personal information may be transferred to Countries outside your Country of residence, which may have different data protection rules than in your Country. While such information is outside of your Country, it is subject to the laws of the Country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other Country, pursuant to the laws of such Country. However, our practices regarding your personal information will at all times continue to be governed by this Privacy Policy and we will comply with the NDPR requirements of providing adequate protection for the transfer of personal information.

  13. INTERNATIONAL VISITORS

    This Service is hosted in Nigeria. If you are an international visitor, you should note that by providing your personal information, you are: (i) permitting the transfer of your personal information to Nigeria which may not have the same degree of data protection laws as the country in which you reside; and (ii) permitting the use of your personal information in accordance with this Privacy Policy.

  14. Third Party Websites and Services

    This Privacy Policy applies only to the NairaEx Pro Services and does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third-party privacy policies prior to using third party websites or products or services.

  15. Children's Privacy

    The NairaEx Pro Services are not directed towards anyone under the age of 18. If a parent or guardian becomes aw are that his or her child under the age of 18 has created an account with nairaex.com and/or provided us with personally identifiable information, please contact us at hello@nairaex.pro.

    Additionally, if we become aware at any point that a child under the age of 18 is using our service, we will terminate his or her account.

  16. Contact Us

    For any questions or comments about this Privacy Policy or your personal information, to make an access or correction request, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices, our Privacy Officer can be reached at hello@nairaex.pro.

This privacy policy was last updated on [20 February 2020]