Privacy Policy

Introduction

Wittypay is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our payment gateway services.

This Policy complies with:

• Nigeria Data Protection Act (NDPA) 2023
• Nigeria Data Protection Regulation (NDPR) 2019
• General Application and Implementation Directive (GAID) 2025

By using Wittypay's services, you consent to the data practices described in this Privacy Policy.

Data We Collect

2.1 Merchant Information

When you register for a Wittypay account, we collect:

• Business name, CAC registration number, and registration documents
• Business address and contact information
• Director/Owner information (name, BVN, NIN, photo ID)
• Bank account details for settlements
• Email address and phone number
• Tax identification information

2.2 Customer Transaction Data

We collect information about transactions processed through Wittypay:

• Customer name and contact information
• Payment method details (card numbers are tokenized and never stored in plain text)
• Transaction amount, date, and time
• IP address and device information
• Transaction status and settlement details

2.3 Technical Data

• IP addresses, browser type, and operating system
• API usage logs and integration data
• Cookies and similar tracking technologies
• Device identifiers for mobile application users

How We Use Your Data

We use your personal data strictly for the following purposes:

• Payment Processing — To facilitate transactions and settlements between merchants and customers
• KYC/AML Compliance — To verify your identity and comply with Nigerian regulatory requirements
• Fraud Prevention — To detect and prevent fraudulent transactions on our platform
• Customer Support — To respond to inquiries and resolve issues promptly
• Service Improvement — To analyze usage patterns and improve our platform and user experience
• Legal Compliance — To meet our legal and regulatory obligations under Nigerian law
• Communication — To send transaction notifications, receipts, and important service updates

Data Sharing and Disclosure

We share your data only with the following parties and only to the extent necessary:

• PalmPay Limited — Our licensed banking partner for transaction processing
• Banks and Financial Institutions — For payment processing and settlement execution
• Regulatory Authorities — CBN, NITDA, EFCC, and NDPC when required by Nigerian law
• Service Providers — Cloud hosting, analytics, and security services (under strict confidentiality agreements and data processing agreements)
• Law Enforcement — When required by valid court orders or legal processes

Data Security

We implement industry-standard security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction:

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by Nigerian law.

After the applicable retention period, personal data will be securely deleted or anonymized using industry-standard methods.

Your Rights as a Data Subject

Under the Nigeria Data Protection Act (NDPA) 2023 and NDPR 2019, you have the following rights regarding your personal data:

To exercise any of these rights, contact our Data Protection Officer at hello@wittypay.online. We will respond within 30 days of receiving your request.

Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, Wittypay will:

• Notify the Nigeria Data Protection Commission (NDPC) within 72 hours of discovery
• Inform affected individuals within 7 days of discovering the breach
• Provide clear details of the breach, the data involved, and the remedial actions taken
• Offer appropriate support and guidance to affected individuals

Cookies and Tracking Technologies

We use cookies and similar technologies for the following purposes:

• Session Security — To maintain your login session and protect your account
• Preferences — To remember your settings and improve your experience
• Analytics — To analyze website traffic and understand how merchants use our platform
• Fraud Detection — To detect and prevent suspicious activity and fraudulent transactions

You can manage cookie preferences through your browser settings. Note that disabling certain essential cookies may affect the functionality of Wittypay's services, particularly session management and security features.

Children's Privacy

Wittypay's services are intended for business use only and are not directed at individuals under 18 years of age. We do not knowingly collect personal data from minors.

If we discover that we have inadvertently collected data from a minor, we will delete it promptly and take appropriate steps to prevent recurrence. If you believe we may have collected information from a minor, please contact us immediately at hello@wittypay.online.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices or to comply with new legal requirements. When we make material changes, we will:

• Send a notification to your registered email address
• Display a prominent notice on our website
• Provide at least 30 days' advance notice before changes take effect

Continued use of Wittypay's services after the effective date of the updated Privacy Policy constitutes your acceptance of the changes.

Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please reach out to our Data Protection Officer through any of the following channels:

You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data rights have been violated.