This policy explains how KWIQ Digital Company Ltd (RC 1989754) ("KWIQ", "we", "us") handles personal data when you use the KWIQ mobile app, kwiq.app and our support channels (together, the "Services"). We process personal data in line with the Nigeria Data Protection Act 2023 and other applicable laws.

If anything here is unclear, email us at admin@kwiq.app.

1. The data we collect

Information you give us

Account details: your name, email address, phone number, date of birth and password.
Identity verification: the details and documents the law requires us and our licensed partners to check, such as a government-issued ID, a selfie or photo for matching, and other identifiers where required.
Payout details: the Nigerian bank account details you add for withdrawals.
Messages: what you send us through live chat, email, phone or social media, and forms on our website.

Information created when you use KWIQ

Transactions: deposits, swaps, sales, withdrawals, bill and airtime payments, including amounts, dates, wallet addresses, blockchain transaction IDs and the rates applied.
Device and usage data: IP address, device type, operating system, app version, pages and screens viewed, and crash and performance logs.
Advertising identifiers and how you found us: in the app, your phone's advertising ID (Google's advertising ID on Android; on iPhone, Apple's IDFA only if you allow tracking) and an app-specific identifier; on our websites, the campaign details in the link you arrived from, or the kind of site that sent you (such as a search engine or social media). We use these to see which ad or link led to your download, sign-up or first trade. See section 7.
Cookies and similar technologies: see section 7.

Information from others

Verification, fraud-prevention and payment partners may share results of checks they carry out for us.
Blockchain networks are public, so transaction data linked to your wallet addresses is visible to anyone.

2. How we use your data

Purpose	Why we're allowed to
Opening and running your account, processing trades and payouts	To perform our contract with you
Verifying your identity and preventing fraud, money laundering and terrorist financing	Legal obligation
Keeping the Services and your account secure	Legitimate interest and legal obligation
Answering your questions and complaints	To perform our contract with you
Improving the app and website, and fixing problems	Legitimate interest
Sending service messages (security alerts, transaction receipts, changes to terms)	To perform our contract with you
Sending marketing, and measuring our ads	Consent, which you can withdraw at any time

We do not sell your personal data.

We share personal data only where needed for the purposes above:

Licensed partners that provide wallet, custody and naira payment services on KWIQ, and the banks that receive your withdrawals.
Service providers that work for us under contract, such as identity verification, cloud hosting, customer support (live chat), email and analytics providers.
Analytics and advertising partners: Google (Google Analytics) and advertising partners such as Meta, Snapchat and X receive limited website usage data, so we can understand how the site is used and measure our ads. See section 7.
Our measurement partner, Singular: Singular Labs, Inc. measures which ads bring people to KWIQ. It receives your device's identifiers, IP address, device and app details, a KWIQ account number that doesn't reveal who you are, and the main things you do in the app, such as installing, signing up, verifying your identity and completing a trade, with the amount KWIQ earned from it. On our websites it receives the pages you visit, your browser's details and IP address, and, when you're signed in on mobile.kwiq.app, the same account number. When you tap a download button on your phone, we send you to the app store through Singular, with where your visit came from (such as the campaign name or the search engine) and which button you tapped. It never receives your name, email address, phone number, bank details or documents. Singular may tell the ad network that showed you an ad whether that ad led to an install or a trade.
Authorities, such as regulators, law enforcement and courts, when the law requires it or to protect our users and the Services.
A buyer or successor if KWIQ is involved in a merger, acquisition or sale of assets, under the same protections.

Some providers may process data outside Nigeria. When they do, we use the safeguards the Nigeria Data Protection Act requires.

4. How we protect your data

We use encryption in transit and at rest, access controls, monitoring and automated systems to protect personal data. Only people who need data to do their job can access it.

No system is perfectly secure, so please protect your account too: use a strong, unique password, keep your phone locked, and never share your password, PIN or one-time codes. KWIQ staff will never ask you for them.

5. How long we keep it

We keep personal data for as long as your account is open, and afterwards for as long as the law requires, for example under anti-money-laundering and financial record-keeping rules. When we no longer need it, we delete or anonymise it.

6. Your rights

Under the Nigeria Data Protection Act you can ask us to:

give you a copy of your personal data;
correct data that is wrong or incomplete;
delete your data, where we're not required to keep it;
restrict or object to certain processing, including direct marketing;
move your data to another provider, where this applies;
withdraw your consent at any time, for processing based on consent.

To make a request, or to close your account, email admin@kwiq.app from the address linked to your account. We may need to verify your identity first, and we'll respond within the time the law allows. If you're unhappy with our answer, you can complain to the Nigeria Data Protection Commission.

7. Cookies and similar technologies

Our website uses:

Essential storage in your browser to remember choices such as dark mode or a dismissed banner.
Analytics from Google Analytics, which uses cookies to count visits and show us which pages are useful. It doesn't tell us who you are.
Our own usage counts: a random ID stored in your browser lets us count which pages are viewed and which buttons are tapped on kwiq.app. The ID isn't linked to your name or your KWIQ account, and we don't store your IP address with these counts. Clearing your browser's data for kwiq.app removes the ID.
Advertising and measurement pixels from Meta, Snapchat and X, which help us see whether our ads lead to visits and app downloads.
A campaign cookie: when you arrive from an ad, a link with campaign tags, a search engine, an AI assistant, social media or another website, we keep where you came from (such as the campaign name and the ad network's click ID, or the search engine's name), the page you landed on and the site that sent you, in a cookie shared by kwiq.app and mobile.kwiq.app for 7 days. A later visit from somewhere else replaces it; typing our address in doesn't. It tells us what led to your app download or web sign-up, and it doesn't contain your name or contact details.
Ad measurement by Singular: Singular's script sets a cookie with a random ID, shared by kwiq.app and mobile.kwiq.app for a year, and records the pages you visit, so we can see which ad led to a visit, a web sign-up or an app download. The cookie doesn't contain your name or contact details.
Live chat, which stores a small identifier so your conversation continues across pages.

You can block or delete cookies in your browser settings, opt out of Google Analytics with Google's browser add-on (tools.google.com/dlpage/gaoptout), and manage ad personalisation in your Google, Meta, Snapchat and X account settings. Blocking cookies may affect some features, such as live chat.

In the KWIQ app, Singular's software measures installs and the main things you do in the app (see section 3). On iPhone, the app asks your permission before using Apple's advertising identifier (IDFA); if you say no, measurement uses Apple's anonymous ad reports and an identifier that only works within KWIQ's apps. On Android, you can reset or delete your advertising ID in your phone's settings (Settings, then Google, then Ads). Either way, the app keeps working as normal.

8. Children

KWIQ is for people aged 18 and over. We don't knowingly collect data from children. If you believe a child has given us personal data, contact us and we will delete it.

9. Changes to this policy

We may update this policy as our Services or the law change. We'll change the "Last updated" date above and, for significant changes, tell you in the app or by email.

10. Contact us

Company: KWIQ Digital Company Ltd (RC 1989754)
Email: admin@kwiq.app
Phone: +2348098460000
Live chat: on kwiq.app and in the app
Contact form: kwiq.app/contact

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