Privacy Policy

1. Introduction

Wahya Core Technologies Limited respects your privacy and is committed to handling personal data responsibly across its mobile applications, websites, support channels, merchant services, and related platform operations.

This Privacy Policy explains what information Wahya collects, how it uses that information, when it shares it, how long it keeps it, the rights available to data subjects, and how to contact Wahya about privacy-related concerns.

2. Scope

This Policy applies to personal data processed by Wahya in connection with:

• user registration and account management;

• identity verification and KYC or KYB processes;

• payments, transfers, installment-enabled purchase flows, group savings or ajo activity, and merchant services;

• customer support, complaints, and dispute handling;

• fraud prevention, security monitoring, and compliance operations; and

• website, app, and communications interactions.

3. Categories of Information We Collect

Wahya may collect and process the following categories of information:

3.1 Identity and profile information

• full name;

• email address;

• phone number;

• date of birth where required;

• profile details;

• account identifiers; and

• photographs, selfies, or identity-related images where verification is required.

3.2 Verification and compliance information

• identity documents;

• address information;

• business registration or merchant verification information;

• sanctions, fraud, or risk-screening results;

• onboarding responses; and

• records submitted for KYC, KYB, or compliance review.

3.3 Transaction and financial activity information

• transfer details;

• payment instructions;

• installment schedules and repayment activity;

• group contribution and payout records;

• merchant transaction records;

• refund, reversal, dispute, or chargeback information; and

• related operational metadata.

3.4 Device, technical, and usage information

• device identifiers;

• app and browser information;

• IP address and network information;

• session logs;

• crash or diagnostic information; and

• usage patterns relevant to security, analytics, and service improvement.

3.5 Communications and support information

• support tickets;

• chat, email, or call records where applicable;

• complaint submissions;

• feedback;

• survey responses; and

• records of investigations or escalations.

3.6 Partner and third-party information

Wahya may receive information from licensed partners, processors, banks, identity-verification providers, analytics providers, communications vendors, merchants, or other service providers where needed to operate the platform or comply with legal obligations.

4. How We Use Personal Data

Wahya may use personal data to:

• create and manage accounts;

• authenticate users and secure access;

• verify identity, eligibility, and merchant legitimacy;

• process payments, transfers, installment-enabled purchase flows, group savings or ajo activity, and related service events;

• communicate service updates, alerts, and support responses;

• investigate complaints, disputes, fraud, abuse, or suspicious activity;

• comply with legal, regulatory, audit, tax, partner, and recordkeeping obligations;

• improve product performance, reliability, and user experience; and

• protect Wahya, its users, merchants, partners, and the integrity of the platform.

5. Why We Process Personal Data

Wahya processes personal data because it is necessary to:

• provide requested services and manage the user or merchant relationship;

• verify identity and reduce fraud or compliance risk;

• meet legal, regulatory, partner, audit, or security obligations;

• protect legitimate business and platform interests, including service integrity and abuse prevention; and

• respond to requests, complaints, and support needs.

Where consent is specifically required for a processing activity, Wahya will seek it in an appropriate manner. Where consent is not the only basis for processing, Wahya may continue to process data where another lawful or operational basis applies.

6. Sharing and Disclosure

Wahya may share personal data with:

• licensed financial partners, processors, banks, or acquiring institutions involved in a service flow;

• identity-verification, KYC, KYB, fraud-screening, or sanctions-screening providers;

• cloud, storage, analytics, communications, customer-support, and infrastructure vendors;

• merchants or group participants where visibility is necessary for the relevant product function;

• professional advisers, auditors, insurers, or corporate service providers;

• regulators, law-enforcement bodies, courts, or competent authorities where disclosure is required or reasonably necessary; and

• successor entities in connection with a restructuring, merger, acquisition, or similar transaction, subject to appropriate safeguards.

Wahya does not sell personal data as a standalone commercial product.

7. Data Retention

Wahya retains personal data only for as long as reasonably necessary for the purposes described in this Policy, including service delivery, fraud prevention, dispute handling, legal compliance, audit, tax, security, and recordkeeping.

Retention periods may vary depending on the type of record, the service involved, partner requirements, legal obligations, and whether a complaint, investigation, dispute, or legal hold applies.

Even where a user requests deletion, Wahya may retain limited information where necessary to:

• comply with law or regulatory expectations;

• preserve evidence for fraud, disputes, or investigations;

• maintain audit or tax records;

• enforce agreements; or

• protect the rights, safety, and integrity of Wahya, its users, merchants, partners, or the public.

8. Security Measures

Wahya uses administrative, technical, and organizational measures designed to protect personal data against unauthorized access, misuse, loss, alteration, or disclosure. These measures may include access controls, role restrictions, logging, encryption or secure transmission, vendor controls, and incident-response procedures.

No system can be guaranteed to be completely secure. You are also responsible for protecting your credentials, devices, and account access methods.

9. Your Rights

Subject to applicable law and valid verification of your identity, you may have the right to:

• request access to personal data Wahya holds about you;

• request correction of inaccurate or incomplete data;

• request deletion of data in appropriate circumstances;

• object to or request restriction of certain processing;

• request portability of data where applicable; and

• lodge a complaint with Wahya or a competent authority.

Wahya may request additional information to verify your identity before acting on a request. Wahya may also decline or limit a request where an exemption, legal obligation, fraud concern, or overriding operational necessity applies.

10. Data Deletion Requests

Wahya provides a route for users to request account or data deletion. Submission of a deletion request does not guarantee immediate or complete erasure of all records. Wahya may need to retain some information for legal, fraud, audit, tax, security, or regulatory reasons.

Where a deletion request is accepted, Wahya will take reasonable steps to delete or anonymize data that no longer needs to be retained.

11. Children's Data

Wahya's services are not intended for children under 18 in connection with financial activity requiring adult eligibility. Wahya does not knowingly design its core financial services for minors. If Wahya becomes aware that personal data has been collected from a child inappropriately, it may take steps to delete or restrict that data subject to legal obligations.

12. International or Cross-Environment Processing

Wahya may use service providers or infrastructure that process data across different technical environments or jurisdictions. Where this occurs, Wahya will seek to apply appropriate safeguards, contractual controls, and access restrictions consistent with the sensitivity of the data and applicable legal expectations.

13. Cookies, Analytics, and Similar Technologies

Wahya may use cookies, SDKs, logs, and similar technologies to support authentication, security, analytics, diagnostics, and service improvement. Some of these tools help Wahya understand how users interact with the platform and detect abuse or technical issues.

14. Complaints and Privacy Questions

If you have a privacy question, concern, or complaint, you may contact Wahya using the official support or privacy contact routes made available by the company. Wahya may request information needed to verify your identity and understand the issue.

15. Changes to this Policy

Wahya may update this Privacy Policy from time to time to reflect changes in law, regulation, product design, partner arrangements, operational needs, or data-handling practices. The updated version becomes effective when published or otherwise communicated, unless a later date is stated.

16. Contact

Wahya Core Technologies Limited 15 Badagry Street Garki Email: support@wahya.com.ng

Review Note

This draft assumes Wahya shares data with licensed partners, processors, banks, and service providers as part of a partner-led operating model. Nigerian counsel should review the rights language, lawful-basis framing, cross-border wording, and retention disclosures before publication.