Privacy Policy

1. Introduction

OINZPAY
LIMITED recognizes that privacy and data protection are fundamental rights of
individuals.

As a digital fintech and lifestyle platform that processes customer information,
financial transactions, and user engagement data, OINZPAY is committed to
ensuring that personal information is handled responsibly, securely, and
transparently.

This Data Protection and Privacy Policy establish the principles and procedures
governing the collection, use, storage, sharing, and protection of personal
data processed by OINZPAY.

This Policy is designed in compliance with:

          •        Nigeria Data Protection Act 2023

          •        CBN Consumer Protection Framework 2019

          •        Applicable global privacy and data protection best practices.

OINZPAY LIMITED acknowledges the importance of maintaining a comprehensive and evolving
privacy framework that protects users while enabling innovation and service
delivery.

2. Purpose of this Policy

This policy seeks to ensure that OINZPAY LIMITED:

Processes personal data lawfully, fairly, and transparently.

— Collects data only for specific and clearly defined purposes.

— Protects personal data against unauthorized access, misuse, alteration, or
disclosure.

— Establishes internal governance and accountability mechanisms for data
protection.

— Provides clear rights and protections for data subjects.

— Maintains a comprehensive privacy framework that adapts to regulatory and
technological changes.

The Company recognizes the need for continuous improvement of privacy practices in
order to protect users and maintain trust in digital financial platforms.

3. Scope

This policy applies to:

*All personal and sensitive information collected or processed by OINZPAY.

*All employees, contractors, consultants, and third-party partners handling personal data.

*All digital platforms, mobile applications, databases, servers, and systems operated or integrated with OINZPAY.

4. Categories of Personal Data Collected

OINZPAY collects only the information necessary to deliver services and meet regulatory obligations.

4.1 Personal Identification Data

          •        Fullname

          •        Date of birth

          •        Residential address

          •        Phonenumber

          •        Email address

4.2 Financial and Transactional Data

          •        Wallet information

          •        Transaction history

          •        Payment account details

4.3 Usage and Technical Data

          •        App usage activity

          •        Deviceinformation

          •        IP address

          •        Login times

          •        Engagement metrics

4.4 Know Your Customer (KYC) Data

          •        Government-issued identification documents

          •        Photographs or biometric verification

          •        Verification information obtained from licensed partners

5. Lawful Basis for Processing Personal Data

Personal data processed by OINZPAY is based on one or more of the following lawful
bases: Consent: Users

provide explicit consent when creating accounts or agreeing to specific
services. Contractual Necessity:

Processing required to provide core services such as wallet management, task rewards, and
transactions.

Legal Obligation:

Compliance with applicable financial and data protection regulations including AML/CFT
requirements.

Legitimate Interest:

Activities necessary to improve platform functionality, detect fraud, prevent abuse, and
enhance user experience.

6. Purpose and Justification for Data Collection

OINZPAY collects personal data only for legitimate, defined, and transparent purposes,
including:

*Creating and managing user wallet.

*Conducting identity verification and KYC processes.

*Processing transactions, rewards, and withdrawals.

*Providing customer service and account support.

*Improving platform functionality, personalization, and user engagement.

*Detecting and preventing fraud or security threats.

*Meeting regulatory, audit, and legal obligations.

Personal data is not collected for vague or undefined purposes, and users are informed
about the reasons for data processing.

OINZPAY does not sell, rent, or trade personal data to third parties.

7. Data Security and Protection Measures

OINZPAY implements strong technical and organizational safeguards to protect personal
data.

Security measures include:

*AES-256 encryption for stored data.

*TLS/SSL encryption for data transmission.

*Access control and role-based authorization.

*Regular security monitoring and vulnerability assessments.

*Secure cloud infrastructure with redundancy and fail-over
systems.

8. Data Retention Policy

Personal data is retained only for as long as necessary to fulfill the purpose for which
it was collected or to meet regulatory requirements.

Retention considerations include:

*Legal and financial compliance requirements

*Fraud prevention and dispute resolution

*Service delivery obligations

When data is no longer required, it will be securely deleted, anonymized, or
archived in accordance with applicable regulations.

9. Data Sharing and Third-Party Processing

OINZPAY may share limited personal data with trusted entities where necessary to
deliver services.

These may include:

*Licensed partner banks and financial institutions.

*Regulatory authorities and law enforcement agencies where required by law.

*Verified service providers offering:

          •        Identity verification services

          •        Analytics tools

          •        marketing or communication services

          •        cloud infrastructure

10. Data Subject Rights

OINZPAY recognizes and supports enhanced rights for individuals whose data is
processed.

Users have the right to:

–Right of Access

–Request access to personal data held by OINZPAY.

–Right to Rectification

–Correct inaccurate or incomplete personal
information.

–Right to Erasure

–Request deletion of personal data where it is no
longer necessary.

–Right to Restrict Processing

–Limit how personal data is processed in certain
situations.

–Right to Data Portability

–Request transfer of personal data in a structured
format.

–Right to Object

–Object to processing for direct marketing or
profiling.

–Right to Withdraw Consent

–Withdraw consent previously given for data
processing.

–Right to Complaint

–Lodge complaints with relevant data protection
authorities if privacy rights are violated.

Requests
should be submitted to info@oinzpay.com and will be
addressed within 7 working days.

11. Protection of Children’s Data

OINZPAY
recognizes that children require enhanced protection when their personal data
is processed.

*OINZPAY services are not primarily intended for children under 18 years of age.

*Personal data from minors will not be knowingly collected without parental or
guardian consent.

*Where children’s data is processed, additional safeguards will be applied.

12. Transparency and Accountability

OINZPAY
maintains internal processes to ensure compliance with data protection laws and
ethical data practices.

These include:

*Internal data governance frameworks.

*Employee training on privacy and security practices.

*Compliance monitoring and audits.

*Incident response procedures for data breaches.

OINZPAY
LIMITED remains committed to maintaining a comprehensive and continuously
improving privacy program.

13. Policy Review and Updates

This policy will be reviewed:

*Annually, or

*Whenever there are changes in regulations, technology, or business operations.

Updates will be approved by management and communicated through official company
channels.

14. Contact Information

For privacy inquiries, complaints, or requests regarding personal data:

 INFO@OINZPAY.COM

 09112666602.