NDPA 2023 Compliant

Privacy Policy

Learn how LibertyPay collects, uses, and safeguards your personal data across our digital applications, POS terminals, and agency banking services.

Effective: June 24, 2023Last Updated: October 16, 2026
Official Regulatory Policy

LibertyPay Privacy Policy

Effective: June 24, 2023Last Updated: October 16, 2026

This Privacy Policy explains how LibertyPay collects, uses, discloses, stores, and protects personal information in accordance with the Nigeria Data Protection Act 2023 (NDPA), applicable regulations, and other relevant legal and regulatory requirements.

1

Introduction

LibertyPay (“LibertyPay”, “we”, “our” or “us”) is committed to protecting the privacy, confidentiality and security of the personal information entrusted to us by our customers, agents, merchants, business partners and other individuals who interact with our services.

This Privacy Policy explains how we collect, use, disclose, store and protect personal information when you visit our website, use the LibertyPay mobile application or POS terminals, conduct transactions, register as an agent or merchant, contact our support team, or otherwise interact with our products and services.

We process personal data in accordance with the Nigeria Data Protection Act 2023 (NDPA), applicable regulations and other relevant legal and regulatory requirements.

By using our services, you acknowledge that you have had the opportunity to read this Privacy Policy. Where consent is the applicable legal basis for processing, we will seek your consent as required by law. Using our services does not constitute blanket consent to every form of data processing described in this Policy.

2

Who We Are

LibertyPay provides digital payment and financial technology services, including services delivered through mobile applications, POS terminals and agency banking channels.

For the purposes of applicable data protection law, the company responsible for determining how your personal data is processed will generally act as the data controller for that processing. In certain circumstances, LibertyPay may process personal data on behalf of another organisation and act as a data processor.

Corporate & Data Protection Information:

Data ControllerLibertyPay Limited
Registered Address27 Alara Street onike sabo yaba, Lagos Nigeria
Privacy & Data Protection Enquirieslibertypay@libertyng.com
Telephone01 280 3801

Where a service is provided by another company within the Liberty Group or by an independent partner, the relevant service provider may have separate responsibilities for your personal data. We will identify the relevant organisation where required by applicable law.

3

Personal Information We Collect

The information we collect depends on the services you use and your relationship with LibertyPay.

3.1 Identity and Contact Information

We may collect:

  • •Full name and other identifying details.
  • •Telephone number and email address.
  • •Residential or business address.
  • •Date of birth and other information required to establish eligibility.
  • •Photographs, identity documents and verification information where required.
  • •Business registration details and information about agents or merchants.

3.2 Account Registration and Verification Information

Where applicable, we may collect information required to create, verify and maintain your account, including account identifiers, customer or agent identification numbers, verification results and Know Your Customer (KYC) information.

We may verify relevant information through authorised identity verification providers, financial institutions, payment partners or other legally permitted sources.

3.3 Financial and Transaction Information

When you use our payment and financial services, we may process:

  • •Bank account details, wallet identifiers and other relevant payment credentials.
  • •Transaction amounts, dates, times, references and statuses.
  • •Transfers, deposits, withdrawals and payment history.
  • •Airtime, data and bill payment records.
  • •POS transaction information and settlement records.
  • •Savings or Ajo records, where applicable.
  • •Loan application, eligibility, repayment and related information where you use a loan service.
  • •Refunds, reversals, disputes and chargeback information.

We do not intentionally collect or store complete payment card security credentials unless this is specifically required and legally permitted for an applicable service. Where payment processing is handled by a third party, that provider's own data handling practices may also apply.

3.4 Agent, Merchant and Business Information

If you register or operate as a LibertyPay agent, merchant or business customer, we may collect business details, business addresses, transaction and settlement records, commissions, operational records and information about authorised representatives.

Where applicable, we may also process information relating to POS terminal allocation, device registration, business activity and service usage.

3.5 Device and Technical Information

When you access our website, application or digital services, we may collect relevant technical information, including:

  • •Device type, operating system and application version.
  • •IP address and technical identifiers.
  • •Login timestamps, session records and security logs.
  • •Application performance, crash reports and diagnostic information.
  • •Information about how you interact with our website or application.

We may use cookies or similar technologies on our website where applicable. Where consent is required, non-essential cookies or similar technologies will only be used after the appropriate consent has been obtained.

3.6 Location Information

We may collect or process location information where it is necessary for a particular service, security verification, fraud prevention, agent operations or another disclosed and lawful purpose.

Location information may be obtained from your device or provided directly by you. Where a service requires access to device location, we will request the relevant permission where required.

You can manage device-level location permissions through your device settings, although disabling them may affect services that depend on location.

3.7 Communications and Support Information

When you contact us, we may process your enquiries, complaints, feedback, correspondence, support tickets and information you provide to help us resolve an issue.

We may also retain relevant communication records for service quality, dispute resolution, security, compliance and record-keeping purposes.

3.8 Information From Third Parties

Where permitted by law, we may receive information from banks, payment processors, identity verification providers, merchants, service providers, fraud prevention partners, credit information providers and other authorised sources.

We use such information only for relevant purposes, including transaction processing, identity verification, fraud prevention, service delivery and legal or regulatory compliance.

4

How We Use Your Personal Information

We process personal information for specific, legitimate and disclosed purposes, including:

1
Account management: Creating, verifying, maintaining and securing customer, agent and merchant accounts.
2
Transaction processing: Facilitating payments, transfers, deposits, withdrawals, settlements, airtime purchases and bill payments.
3
Service delivery: Providing access to the features and services you request.
4
Savings and loan services: Administering applicable savings products, assessing loan applications where relevant, managing repayments and meeting related obligations.
5
Agent and merchant operations: Managing POS services, agent relationships, commissions, business records and settlements.
6
Gaming-related services: Supporting applicable lottery, betting or gaming transactions where offered through the platform and provided by the legally responsible operator.
7
Customer support: Responding to enquiries, investigating complaints and resolving transaction disputes.
8
Security and fraud prevention: Detecting suspicious activity, preventing unauthorised access and protecting customers and our systems.
9
Legal and regulatory compliance: Meeting applicable financial services, identity verification, record-keeping, anti-money laundering, reporting and data protection obligations.
10
Service improvement: Diagnosing technical problems, evaluating performance and improving our products and services.
11
Communications: Sending service notifications, transaction alerts, security messages and important policy updates.
12
Marketing: Sending promotional messages about relevant products and services where permitted by law and, where required, with your consent.
13
Dispute resolution: Establishing, exercising or defending legal claims and investigating suspected violations of our terms or applicable law.
We will not use personal information for purposes that are incompatible with the purposes for which it was collected unless we have a lawful basis to do so.
6

Sharing and Disclosure of Personal Information

We do not sell your personal information as a standalone commercial product.

We may share relevant personal information with the following categories of recipients where necessary, proportionate and legally permitted:

6.1 Banks and Payment Partners

We may share transaction and account information with banks, payment processors, switching companies, settlement partners and other financial institutions involved in processing your transactions.

6.2 Identity Verification and Compliance Providers

We may disclose relevant information to authorised identity verification providers, fraud prevention services, credit information providers and compliance partners where necessary for verification, risk management or legal compliance.

6.3 Technology and Infrastructure Providers

We may use service providers for hosting, cloud infrastructure, software maintenance, customer support, analytics, communications and security monitoring. Such providers may process personal information on our behalf under appropriate contractual and security arrangements.

6.4 Group Companies and Service Operators

Where a service is operated by another company within our corporate group or by a third-party service provider, relevant information may be shared to provide the service, manage accounts, process transactions or meet legal obligations.

Where another organisation independently determines the purposes and means of processing, that organisation may have its own privacy responsibilities and notice.

6.5 Regulators, Law Enforcement and Legal Advisers

We may disclose personal information to courts, regulators, law enforcement agencies, tax authorities or other competent bodies where required or authorised by law. We may also disclose information to professional advisers where necessary for legal, audit or compliance purposes.

6.6 Business Transfers

If our business or part of it is involved in a merger, restructuring, acquisition or transfer, relevant personal information may be disclosed as part of that process, subject to applicable legal requirements and appropriate safeguards.

We seek to ensure that third parties receiving personal information are subject to appropriate confidentiality, security and data protection obligations.

7

International Transfers of Personal Information

Some of our service providers or technology infrastructure may be located outside Nigeria, or personal information may otherwise need to be transferred internationally.

Where personal information is transferred outside Nigeria, we will comply with applicable requirements under the NDPA and relevant regulations. This may include assessing the destination, ensuring an applicable lawful transfer mechanism and implementing appropriate safeguards where required.

You may contact us using the details in this Policy to request further information about relevant international transfers, subject to applicable legal restrictions.

8

Data Security

We implement appropriate technical and organisational measures designed to protect personal information against unauthorised access, unlawful processing, accidental loss, destruction, alteration or disclosure.

Depending on the system and processing activity, safeguards may include access controls, authentication measures, encryption, security monitoring, backups, staff confidentiality obligations and restricted access to personal information.

Access to personal information is limited to authorised personnel and service providers who need it for legitimate business or service-related purposes.

Although we take reasonable steps to protect personal information, no electronic transmission, information system or storage method can be guaranteed to be completely secure.

Where a personal data breach occurs, we will assess and respond to it in accordance with applicable legal and regulatory requirements, including any applicable notification obligations.

9

Data Retention

We retain personal information only for as long as necessary for the purpose for which it was collected, subject to applicable legal, regulatory, contractual and operational requirements.

Retention periods may depend on:

  • •The type of information and the service involved.
  • •The duration of your customer, agent or merchant relationship.
  • •Financial transaction and record-keeping requirements.
  • •Fraud prevention, dispute resolution and security needs.
  • •Applicable limitation periods and legal obligations.

When personal information is no longer required, we will take appropriate steps to delete, anonymise or securely dispose of it, subject to lawful retention requirements. Some information may need to be retained after an account is closed, for example to meet financial record-keeping obligations, investigate disputes or comply with a lawful request.

10

Your Data Protection Rights

Subject to applicable law and any relevant exceptions, you may have the right to:

Be informed

Receive clear information about how your personal information is processed.

Access

Request confirmation of whether we process your personal information and obtain access to relevant information.

Rectification

Request correction of inaccurate or incomplete personal information.

Erasure

Request deletion of personal information where the applicable legal conditions are met.

Restriction

Request restriction of certain processing activities where permitted by law.

Object

Object to processing in circumstances provided for by applicable law, including certain processing based on legitimate interests and direct marketing.

Data portability

Request a copy of certain personal information in a structured, commonly used and machine-readable format where the legal conditions apply.

Withdraw consent

Withdraw consent where processing is based on consent.

Protection in relation to automated decisions

Exercise applicable rights concerning decisions based solely on automated processing that produce legal or similarly significant effects.

Lodge a complaint

Submit a complaint to the Nigeria Data Protection Commission where you believe your data protection rights have been infringed.

These rights are subject to applicable legal conditions, exceptions and restrictions. For example, we may be required to retain certain financial or transaction records even where a request for deletion is made.

11

Cookies and Similar Technologies

Our website may use cookies or similar technologies to support essential website functionality, remember preferences, understand website performance and improve the user experience.

Where applicable, cookies may be categorised as:

Strictly necessary:Required for the website or a requested service to function.
Functional:Used to remember preferences or settings.
Analytics:Used to understand website usage and performance.
Marketing:Used for relevant advertising or marketing measurement where implemented.

Non-essential cookies and similar technologies will be used in accordance with applicable consent requirements. Where a consent mechanism is provided, you can manage your preferences through that mechanism.

You may also be able to restrict cookies through your browser settings. Blocking certain cookies may affect website functionality.

12

Children's Personal Information

LibertyPay's financial and payment services may be subject to age, identity and eligibility requirements.

We do not knowingly collect children's personal information in circumstances where such collection is prohibited by applicable law. Where a service lawfully involves a child or a person requiring special protection, we will apply the safeguards and consent requirements applicable to that processing.

If you believe a child has provided personal information to us unlawfully, please contact us so that we can assess the matter and take appropriate action.

13

Third-Party Websites and Services

Our website, applications or services may contain links to third-party websites, applications or services. These third parties may have their own privacy policies and data handling practices.

We are not responsible for the privacy practices of independent third parties. We encourage you to review their privacy notices before providing personal information directly to them.

Where a third party processes personal information on our behalf, our relationship with that provider will be governed by appropriate contractual and data protection arrangements.

14

Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our services, data handling practices, technology, legal obligations or regulatory requirements.

Where changes are material, we will take reasonable steps to communicate them through our website, application, email or other appropriate channels where required.

The “Last Updated” date at the beginning of this Policy will indicate when the Policy was most recently revised.

15

Contact Us

If you have questions about this Privacy Policy, wish to exercise your data protection rights or want to raise a concern about how your personal information is handled, please contact us:

LibertyPay – Privacy and Data Protection

Office Address27 Alara street Onike sabo, Yaba, Lagos Nigeria

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Contact Information

  • 27, Alara Street,
    Off Commercial Avenue,
    Sabo-Yaba, Lagos.

  • libertypay@libertyng.com

  • 012803801

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