1. Introduction

InspireMe Pay ("we", "us", or "our") is a financial technology platform operated in Nigeria, providing services including bill payments, airtime-to-cash conversion, money transfers, virtual accounts, merchant payments, metering, savings, loans, investments, and card services. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use the InspireMe Pay application (the "App"). By registering and using the App, you consent to the practices described in this policy.

2. Information We Collect

To open and operate your account and to provide our services, we collect the following categories of information:

• •Identity & Contact Data — Full name, date of birth, email address, phone number, residential address, and state of residence.
• •Identity Verification Numbers — Bank Verification Number (BVN) and National Identification Number (NIN), or other government-issued identification (driver's licence, voter's card, or international passport).
• •Biometric Data — Facial photographs and selfie captures used for identity verification and fraud prevention.
• •Business Information — For merchant accounts: registered business name, CAC/RC number, and certificate of incorporation.
• •Financial & Transaction Data — Account balance, virtual account number, transaction history, transfers, bill payments, airtime conversions, and payment metadata.
• •Device & Usage Data — Device identifiers, approximate location (for nearby services), app usage logs, and technical data collected automatically when you use the App.
• •Next of Kin Information — Name, phone number, relationship, and address, used for loan eligibility and account recovery.

3. How We Use Your Information

We use your personal information to:

• •Verify your identity (Know Your Customer / KYC) and comply with Nigeria's anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
• •Create and maintain your virtual account and process financial transactions.
• •Provide bill payments, airtime conversion, metering, savings, loans, investments, and other features.
• •Detect, prevent, and investigate fraud, unauthorised access, and other prohibited or illegal activity.
• •Communicate with you about your account, transactions, security alerts, and service updates.
• •Improve and develop our services, and comply with legal and regulatory obligations.

4. KYC Verification

As a financial institution regulated under Nigerian law, we are required to verify the identity of every user. Depending on your chosen tier, you may be asked to provide your BVN, NIN, a government-issued ID, a live selfie, and proof of address. This information may be validated against third-party identity verification services. You cannot access the full features of the App until your KYC is approved.

5. Data Sharing & Disclosure

We do not sell your personal data. We may share your information with the following parties strictly as necessary to provide our services and meet legal obligations:

• •Payment & Banking Partners — such as Paystack, our dedicated virtual account provider, and other licensed payment processors, to facilitate transfers, deposits, and payouts.
• •Bill & Service Providers — such as CorelPay, electricity distribution companies, telecom operators, and other billers, to complete your bill payments and airtime conversions.
• •Identity Verification Providers — to validate your BVN, NIN, and facial identity during KYC.
• •Regulatory & Law Enforcement Authorities — including the Central Bank of Nigeria (CBN), Nigeria Inter-Bank Settlement System (NIBSS), EFCC, and other authorities, when legally required or to report suspicious transactions.
• •Service Providers — trusted vendors that help us operate the App (e.g. cloud hosting, SMS/email delivery), under strict confidentiality obligations.

6. Data Security

We implement industry-standard technical, administrative, and physical safeguards to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These include encryption in transit and at rest, access controls, secure authentication (including transaction and distress PINs, and optional biometric authentication), and continuous monitoring. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7. Data Retention

We retain your personal and transaction information for as long as your account is active, and for a minimum period thereafter as required by Nigerian financial regulations and to fulfil our legal, regulatory, audit, and dispute-resolution obligations.

8. Your Rights

Under the Nigeria Data Protection Act 2023 and the Nigeria Data Protection Regulation (NDPR), you have the right to:

• •Access the personal information we hold about you.
• •Request correction of inaccurate or incomplete information.
• •Request deletion of your personal information, subject to legal retention requirements.
• •Withdraw consent for processing activities that rely on consent.
• •Lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your rights have been violated.

9. Cookies & Tracking

The App may use local storage and similar technologies to remember your preferences, maintain your session, and improve performance. We do not use tracking cookies for third-party advertising.

10. Children's Privacy

The App is not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe a minor has provided us with personal data, please contact us so we can take appropriate action.

11. International Transfers

Your information may be processed on servers located outside Nigeria. Where this occurs, we ensure appropriate safeguards are in place to protect your data in accordance with Nigerian law.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. We will notify you of material changes through the App or by other means. Continued use of the App after changes take effect constitutes acceptance of the updated policy.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at support@inspiremepay.com or +234 700 INSPIRE.