PRIVACY POLICY FOR YEBA TECHNOLOGIES

YEBA Technologies ("we," "our," or "us") values the privacy and security of our users' personal information. This Privacy Policy outlines how we collect, use, store, and share your personal data when you access our cryptocurrency exchange services in Nigeria. By using our platform, you consent to the practices described in this policy.

This Privacy Policy is strictly restricted to only our services and therefore does not apply to services that are not owned or controlled by us, including third-party platforms/websites. We are committed to handling all personal data provided to us in compliance with both applicable and model data privacy and protection laws. 

Yeba takes your right to privacy seriously. You have a right to know what we do with your personal information so that you can make informed choices while visiting our website. 

We recommend that you read our Privacy Policy carefully to understand our views and practices regarding your personal data and information, its collection and usage. By accessing and using our Platform and/or Services, you signify acceptance of the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. We may provide additional "just-in-time" disclosures or information about our data processing practices. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data. 

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services. 

We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law. 

You agree to hold us harmless of the release of any personal data pursuant to our Privacy Policy. This Privacy Policy describes the way in which the company deals with the information and data you provide to us to enable us to manage your relationship with us. We will process any personal information provided to us via the Platform and other related means. 

Your personal data will not be disclosed to third parties, unless such disclosure is necessary for the processing of your request, such as creating an account on the Platform (the "Yeba Account”), effecting transactions on your Yeba Account or to carry out verification procedures

1. Understanding Personal Data at Yeba Technologies

1.1 What Constitutes Personal Data

At Yeba Technologies, “personal data” refers to any information that can be used to identify you, either directly or indirectly. Your Personal Information will be processed subject to and in accordance with the requirements of the Nigeria Data Protection Act 2023 and Nigeria Data Protection Regulation 2019. 

We will always solicit for your consent before sharing or disclosing your Personal Information with a third party except as may be required for the purpose of providing you with our services or under applicable legislations. 

Given the nature of our cryptocurrency trading services, personal data includes, but isn’t limited to the following:

• User’s Full Name
• Date of Birth
• National Identification Number (NIN), BVN, or other government-issued identification documents
• Contact Information (email address and phone number)
• Bank account details for Naira withdrawals

1.2 Cryptocurrency-Related Personal Data

Given our role as a cryptocurrency trading platform, additional types of personal data specific to digital assets may include but not limited to the following:

• Cryptocurrency transaction records (e.g., wallet address, transaction hash)
• Amount of cryptocurrency exchanged
• Exchange rates at the time of the transaction

1.3 Technical Data

• IP address
• Device information (e.g., browser type, operating system)
• Usage data, including logs of platform activity

1.4 Special Category Data

We may collect biometric data (e.g., facial recognition or fingerprint data) to verify your identity during onboarding, in compliance with applicable laws.

2. Your Privacy Rights

Your Rights as They Relate to Data Protection

We value your control over your personal data. According to the Nigeria Data Protection Act (NDPA) and the Nigeria Data Protection Regulation (NDPR), you have rights regarding your personal data, which include:

• Access to Your Data: You may request a copy of the personal data we hold about you, including any data related to your cryptocurrency transactions.
• Correction of Inaccuracies: If any of your information is incomplete or inaccurate, you have the right to request updates.
• Request for Data Deletion: You may request the deletion of your personal data under specific conditions, though certain data (e.g., transaction data) stored on a blockchain may not be erasable.
• Restriction of Processing: You may limit how we use your data in specific scenarios.
• Data Portability: You have the right to request your data in a structured format that can be transferred to another service provider.
• Object to Data Processing: If we process your data based on legitimate interest or for direct marketing, you may object to this processing.
• Withdraw Consent: For data processing based on consent, you can withdraw consent at any time without affecting prior processing legality.

How to Exercise Your Rights

To exercise your rights, contact us using the details provided at the end of this policy. We will promptly address your requests in accordance with our legal obligations.

3. How We Collect the Personal Data from You

Information You Provide Directly

We collect personal data you provide when you:

• Register for an account, verify your identity, or use any of our services.
• Make cryptocurrency transactions on our platform.
• Engage with our support team via various digital channels like live-chat, messaging apps, or email.
• Participate in surveys, promotions, or engage in events related to our cryptocurrency offerings.

4. How We Collect Personal Data from Other (Third-Party) Sources:

We may receive additional data from reputable third-party sources, which may include:

• Financial Institutions and Payment Providers: Data related to fiat transactions, deposits, and withdrawals, ensuring safe and compliant processing.
• Blockchain Analytics Firms: Information related to risk assessments, compliance, and fraud detection, such as transaction analysis and anti-money laundering (AML) alerts.
• Publicly Available Sources: Data from social media profiles or other publicly available sources that help us verify your identity or assess risk.
• Integrated Platforms and Services: If you choose to connect with other platforms or services, we may receive relevant data as permitted by their privacy policies.

5. Purpose of Data Collection

We collect and process your data for the following purposes:

1. To facilitate cryptocurrency exchange services and process transactions.
2. To verify user identity and comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations, including Nigeria's Money Laundering (Prevention and Prohibition) Act 2022.
3. To enhance user experience and improve our platform.
4. To comply with applicable laws and respond to legal or regulatory requests.

6. Legal Basis for Processing

Our processing of your personal data is based on the following legal grounds:

1. Performance of a Contract:Data is necessary to fulfill our services as per the terms and conditions.
2. Legal Obligations:Compliance with regulatory requirements under Nigerian laws, including:
   • Nigeria Data Protection Regulation (NDPR) 2019
   • Cybercrimes (Prohibition, Prevention, Etc.) Act 2015
3. Legitimate Interests:Preventing fraud, securing our platform, and improving our services.
4. Consent:Where required, such as for marketing communications or processing data of users under 18 (as outlined below).

7. How We Use Your Personal Data & Information

Purpose of Data Processing

Yeba Technologies uses your data responsibly to provide secure and reliable cryptocurrency services. Specifically, we use your data for:

• Service Delivery and User Experience: Your account is setup to understand your preferences, customize your experience, and improve our services. Such that, we process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. Not having your information may affect our ability to respond to your requests and ensure your uninterrupted use of the Services. 
• Compliance with Legal Requirements: To meet our regulatory obligations, including AML and KYC, transaction reporting, and compliance with NDPR, NDPA, and any relevant international standards. A part of our Services is subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, Yeba must identify and verify customers using our Services, in order to comply with local Anti-Money Laundering laws.
  When you seek to link a bank account to your Yeba Account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or information, and/or to manage risk as required under applicable law. Failure to provide personal information required may result in a closure of your account.
• Quality Control & Training Purposes: We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions.
• Marketing and Communication: To keep you informed about our products, updates, and industry developments (with an option to opt-out).
• Transaction Monitoring: We may regularly monitor your transactions (i.e deposits & withdrawals), to prevent fraud, money laundering and terrorist financing of any form.
• Security and Risk Management: To monitor transactions, detect and prevent fraudulent activity, secure your account, and protect our platform’s integrity.

8. Data Sharing and Disclosure of Personal Data

When We Share Personal Data

Yeba Technologies does not sell or rent your personal data to third parties. However, we may share data with the following entities and under the following circumstances:

• Regulatory Authorities: Nigerian Financial Intelligence Unit (NFIU), or other local authorities for AML/KYC compliance.
• With Service Providers: We work with trusted vendors and Third-party payment processors or identity verification providers, subject to strict confidentiality agreements. Some of these providers are; financial institutions, blockchain analytics firms, and identity verification providers, all of whom are contractually obligated to safeguard your data.
• For Legal Compliance & Law Enforcement: We may disclose data in response to subpoenas, regulatory requirements, or lawful requests.
• In Business Transactions: If Yeba undergoes a merger, acquisition, or asset sale, your data may be transferred, subject to the safeguards in this policy.
• To Protect Yeba and Others: When necessary, we may share data to enforce our policies, prevent fraud, and protect users and the public.

Blockchain Transactions

It is important to note that blockchain-based cryptocurrency transactions are inherently transparent. Once a transaction is added to the blockchain, it becomes part of a public ledger and cannot be removed. While the blockchain itself does not directly identify individuals, Yeba Technologies takes additional measures to protect your privacy within our platform.

9. Data Security and Protection Measures at Yeba

Our Approach to Security

Yeba Technologies employs rigorous security protocols, including:

• Encryption: We encrypt sensitive data, such as financial information, during storage and transmission.
• Access Controls: Only authorized personnel have access to sensitive data, protected by multi-factor authentication and strong access control measures.
• Regular Security Audits: We frequently review and audit our security infrastructure to address and mitigate risks.
• Breach Notification Protocol: In the event of a data breach, we will notify affected users and regulatory bodies as required, outlining measures to resolve and prevent future occurrences.

Cryptocurrency-Specific Security

Due to the unique nature of cryptocurrency, Yeba Technologies uses cold storage for the majority of digital assets, meaning assets are stored offline to minimize exposure to unauthorized access. We also deploy robust monitoring systems to detect and respond to unusual or suspicious transactions.

However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur, primarily from your own errors/misdoings. Please recognize that you play a vital role in protecting your own personal information. When registering with our Services, it is important to keep your information and passwords private & confidential, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

10. Children’s Privacy

Data Collection for Minors

Yeba Technologies does not knowingly collect data from individuals under the age of 18. If we discover that we have inadvertently collected such data, we will promptly delete it. Parents and guardians are encouraged to contact us if they believe a minor has provided personal information without consent.

11. Our Commitment to Data Privacy

Internal Privacy Commitment

Yeba Technologies has a companywide dedication to protecting data privacy. We have implemented internal policies and training programs to maintain regulatory compliance and ensure that every team member understands and values data privacy. Our commitment to NDPR, NDPA, and global data protection standards is integral to our culture.

12. Updates to This Privacy Policy

Policy Amendments

We may update this Privacy Policy to reflect changes in our practices or regulatory requirements. Any update will be displayed on our website, and we encourage you to review this policy regularly to stay informed. We will obtain your consent to any material changes if and where this is required by law.