Privacy Policy

We collect the following types of information when you use ReflexPay:

• Personal Identification Information: This includes, but is not limited to, your name, email address, phone number, BVN, address, and payment details.
• Transaction Data: Information related to transactions made via ReflexPay, such as transaction amount, recipient, date, and payment method.
• Device and Usage Data: Information about the device you use to access our service (e.g., IP address, device type, browser type, operating system) and how you interact with our platform (e.g., usage patterns, login times).
• Location Data: If permitted, we may collect information about your location when you use our services to enhance functionality or for fraud prevention.
• Third-Party Data: We may also collect data from third parties (e.g., partners, service providers) to verify your identity or improve our services.
• Identity Verification with TrueDepth API: Certain Third-Party Providers involved in our identity verification process collect personal data through our platform using Apple Inc.'s TrueDepth Application Programming Interface ("TrueDepth API") or other Identity Verification APIs. This integration allows our platform to leverage data automatically gathered by the device camera on Apple's mobile devices.
• The primary purpose of collecting this data is to analyze facial features and improve the augmented reality (AR) experience during identity verification. Specifically, we may use SmiledID to capture 3D spatial orientation and facial expressions, ensuring that submitted selfies originate from live individuals. This step is essential for fraud prevention and secure user authentication.
• Notably, all data processed via the TrueDepth API remains strictly on your device. Neither spatial orientation nor facial expression data is transmitted to ReflexPay, Third-Party Providers, or any external parties. Furthermore, this data is not permanently stored on your device or any other system.
• We are dedicated to safeguarding your personal data and will take all necessary precautions to ensure compliance with relevant data protection laws. Additionally, we require all Third-Party Providers handling your personal data to adhere to security standards aligned with this Policy and applicable data protection regulations.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Providing Services: To process payments, transfers, and other services you request.
• Customer Support: To address inquiries, issues, and feedback, and improve user experience.
• Fraud Prevention & Security: To prevent fraudulent activities and ensure the security of transactions.
• Marketing and Communication: o send promotional content and updates (you can opt out of marketing communications at any time).
• Compliance with Laws and Regulations:To meet legal and regulatory requirements, including the Central Bank of Nigeria (CBN) guidelines on financial services.

3. How We Share Your Information

We do not sell, rent, or trade your personal data. However, we may share your information in the following circumstances:

• With Service Providers: To facilitate transactions, provide customer support, and perform other services on our behalf (e.g., payment processors, cloud storage providers).
• With Legal Authorities: If required by law, such as to comply with regulatory requirements, respond to legal processes, or protect our rights and interests.
• Business Transfers: In the event of a merger, acquisition, or sale of company assets, your information may be transferred as part of that transaction.

4. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, or as required by law, after which it will be securely deleted or anonymized.

5. Security of Your Information

We take the security of your personal information seriously and use industry-standard security measures to protect your data from unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security.

6. How Long We Retain Your Information

We retain your information only as long as necessary to provide our services to you, enhance your user experience, and otherwise as necessary for our operations or as permitted or required by applicable laws.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to collect data about your browsing behavior on our platform, improve your user experience, and analyze trends. You can manage cookie preferences through your browser settings.

8. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or service offerings. Any changes will be posted on this page with the revised date. Please review this Privacy Policy regularly to stay informed.

Contact Us

If you have any questions or concerns about this Privacy Policy or how we handle your personal data, please contact us at: