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DAPY PLATFORM LIMITED

Privacy Policy

Last updated: December 2025

DAPY PLATFORM LIMITED PRIVACY POLICY Effective Date: [ ]

DAPY Platform Limited ("DAPY," "we," "our," or "us") is committed to protecting your personal data and ensuring your privacy in compliance with the Nigeria Data Protection Act, 2023 ("NDPA"), the Nigeria Data Protection Regulation, 2019 ("NDPR"), and any relevant Central Bank of Nigeria (CBN) guidelines. This Privacy Policy outlines the types of data we collect, the purposes for processing, your rights, and how we protect your information.

1. DEFINITIONS

  • Personal Data: Any information that can identify you, including but not limited to your name, phone number, BVN, email address, employment records, salary, and banking information.
  • Processing: Any operation performed on personal data including collection, recording, organization, storage, adaptation, retrieval, consultation, use, disclosure, erasure, or destruction.
  • Data Subject: You, the individual whose data we collect and process.
  • Third Party: Any person or entity other than you and DAPY.
  • NDPA/NDPR: Nigerian laws governing personal data protection and privacy.

2. DATA WE COLLECT

We collect and process the following categories of personal data:

  • Data: Full name, date of birth, gender, BVN, means of identification (e.g., NIN, voter card).
  • Contact Data: Email address, mobile number, residential address.
  • Employment Data: Employer name, salary frequency, net pay, employment status, attendance data.
  • Financial Data: Bank account details, wallet transactions, EWA requests.
  • Device & Usage Data: IP address, device ID, geolocation, mobile OS, session logs.

3. HOW WE COLLECT DATA

  • Directly from you during account creation or support communication.
  • From your employer, with your consent.
  • From authorized third-party KYC providers (e.g., banks, credit bureaus, identity verification services).
  • Through the app or website (cookies, analytics tools).

4. PURPOSES OF DATA PROCESSING

Your data is processed for the following legitimate purposes:

  • To verify your identity and complete KYC obligations.
  • To assess eligibility and compute earned wages.
  • To provide the EWA service and salary advance options.
  • To notify you about transactions, earnings, deductions, or service changes.
  • To comply with CBN regulations and legal obligations.
  • To detect and prevent fraud or misuse of the platform.
  • For product improvement, customer support, surveys, and analytics.

5. LEGAL BASIS FOR PROCESSING

  • Consent: You grant consent during registration or app usage.
  • Contractual Necessity: To fulfill the agreement between you, your employer, and DAPY.
  • Legal Obligation: To comply with applicable laws and regulatory requests.
  • Legitimate Interest: To operate securely and efficiently as a financial service provider.

6. DATA SHARING AND THIRD PARTIES

We may share your data with the following:

  • Your employer to compute, verify, and deduct EWA payments.
  • Partner banks and wallet service providers for transaction processing.
  • Licensed credit bureaus (e.g., CRC, FirstCentral) if necessary.
  • Government agencies or regulators (e.g., CBN, NDPC, EFCC) upon lawful request.
  • Technology service providers (e.g., cloud hosting, fraud detection systems).

We do not sell or rent your personal data to anyone.

7. DATA RETENTION

  • We retain your data only as long as necessary for service delivery, legal compliance, or dispute resolution.
  • Inactive accounts may be archived or anonymized after 3 years of inactivity.

8. DATA SECURITY MEASURES

We use industry-grade security controls to protect your data:

  • End-to-end encryption (SSL/TLS)
  • Role-based access controls (RBAC)
  • Multi-factor authentication.
  • Regular security audits and penetration testing.

9. YOUR RIGHTS AS A DATA SUBJECT

Under Nigerian law, you have the right to:

  • Access: Request a copy of your personal data.
  • Correction: Rectify inaccurate or incomplete data.
  • Deletion: Request erasure of data no longer necessary.
  • Consent Withdrawal: Revoke consent at any time.
  • Data Portability: Request transfer to another service provider.
  • Lodge Complaint: File a complaint with the Nigeria Data Protection Commission (NDPC).

To exercise your rights, contact us at: support@dapy.io

10. CHILDREN'S PRIVACY

DAPY does not knowingly collect data from individuals under the legal working . If discovered, such data will be deleted.

11. COOKIES AND TRACKING TECHNOLOGIES

We use cookies to enhance your user experience and gather usage insights. You can control cookie settings via your browser.

12. INTERNATIONAL DATA TRANSFERS

DAPY stores data on secure servers in overseas. If data is ever transferred internationally to another (e.g., cloud services), we will ensure such transfers comply with NDPA and include proper safeguards.

13. POLICY UPDATES

This Privacy Policy may be updated periodically. Changes will be communicated via in-app notification, email, or SMS.

14. CONTACT INFORMATION

For inquiries, complaints, or to exercise your data rights: Data Protection Officer (DPO)

DAPY Platform Limited
Email: support@dapy.io
Phone: +234 [Insert Number]
Website: [www.dapy.io]

15. GOVERNING LAW

This Policy shall be governed in accordance with the Nigeria Data Protection Act, 2023, and other applicable regulations under the jurisdiction of the Federal Republic of Nigeria.

DAPY PLATFORM LIMITED

RC [Insert CAC Number] | Compliant with NDPA, NDPR, and CBN Guidelines.