NDPC Compliant • Nigeria Data Protection Act (NDPA 2023)

Privacy Policy & Data Protection

At ZuvaPay, we hold your personal and transactional information with the highest confidentiality. This policy outlines how your data is collected, processed, and safeguarded.

Last Updated & Effective: September 14, 2026

Summary of Our Regulatory Standing

ZuvaPay operates in compliance with the Nigeria Data Protection Commission (NDPC) guidelines and the Nigeria Data Protection Act (NDPA 2023). We adhere strictly to data minimization, lawful processing, purpose limitation, and robust storage encryption.

1

Who We Are

ZuvaPay (“we”, “us”, or “our”) is an automated digital utilities aggregation platform operated by ZuvaPay Technologies Limited in Lagos, Nigeria. We connect consumers and businesses directly with telecommunication networks, power distribution companies, cable television operators, and digital service vendors.

2

Information We Collect

We only collect information necessary to fulfill your requested transactions and secure your account:

  • Identity & Contact: Full name, telephone number, and email address provided during registration or checkout.
  • Utility & Transactional Data: Meter numbers, smartcard numbers, recipient phone numbers for data/airtime top-ups, transaction references, and timestamp logs.
  • Security Credentials: Encrypted password hashes and a self-selected 4-digit transaction authorization PIN. We never store plain-text passwords or PINs.
  • Technical Information: IP address, device operating system, browser type, and diagnostic error logs used solely for fraud prevention, rate limiting, and system stability.
3

Third-Party Service Providers & Data Sharing

Notice on Third-Party Fulfillment:

ZuvaPay is a technology aggregator. Many of our core utility services are fulfilled through regulated external partners, telecom aggregators, and financial infrastructure providers.

To successfully process your orders, specific transactional identifiers are shared with authorized third parties on a strict need-to-know basis:

  • Telecommunication Carriers & Aggregators: Recipient phone numbers and requested bundle sizes are shared with carriers (MTN, Airtel, Glo, 9mobile) and certified data gateways to dispatch SME data and airtime.
  • Electricity Distribution Companies (Discos): Meter numbers and payment amounts are transmitted to discos (IKEDC, EKEDC, AEDC, IBEDC, etc.) to generate your 20-digit prepaid recharge token.
  • Licensed Payment Gateways & Banks: Payment processing, card clearing, and bank transfer verifications are executed via PCI-DSS certified payment processors (e.g. Paystack, Monnify). ZuvaPay does not store or process raw debit card PANs or CVVs.
  • International Carrier Aggregators: For foreign virtual SMS numbers, requests are forwarded to global telecom switches without sharing your personal identity.

We never sell, rent, or trade your personal information to marketing brokers, data aggregators, or unauthorized third parties.

4

Your Rights Under NDPA (2023)

As a data subject under Nigerian law, you are entitled to:

Right to Access

Request a complete copy of all personal records we hold about you.

Right to Rectification

Correct inaccurate, outdated, or incomplete profile details.

Right to Erasure (“To be Forgotten”)

Request account deletion, subject to statutory financial audit record retention.

Right to Object

Opt out of non-essential promotional SMS or emails at any time.

5

Data Security & Encryption

All communications between your device and ZuvaPay are protected using modern TLS/SSL 256-bit encryption. Sensitive database fields are hashed with robust cryptographic salts. Additionally, every financial debit on your wallet is guarded by your private 4-digit PIN.

6

Data Protection Officer (DPO) Contact

For privacy inquiries, rights enforcement, or NDPC-related questions, contact our designated Data Protection Officer:

ZuvaPay Data Privacy Office

Email: hello@zuvapay.com

Location: Victoria Island, Lagos State, Nigeria