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Privacy Policy

How Naya collects, uses and protects your data.

Last Updated: June 2026

1. Introduction

Usenaya Ltd ("Naya", "we", "us", or "our") is committed to protecting the privacy and personal data of all individuals who use our platform. This Privacy Policy describes how we collect, use, share, and protect your personal information when you interact with Naya through WhatsApp or any other channel we support.

By using Naya, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your information as described herein.

2. Information We Collect

2.1 Information You Provide Directly

  • Full name, date of birth, and nationality
  • Phone number linked to your WhatsApp account
  • Bank Verification Number (BVN) or National Identification Number (NIN)
  • Government-issued identification documents
  • Source of funds and employment information, where required
  • Financial account details necessary to execute transactions

2.2 Information Collected Automatically

  • Transaction records including amounts, recipients, timestamps, and reference numbers
  • Spending patterns, bill payment history, and crypto transaction history
  • Device identifiers and WhatsApp account metadata
  • Interaction logs with Naya's AI assistant within WhatsApp
  • IP address and approximate location data

2.3 Information From Third Parties

  • Identity verification data from CBN-licensed identity services
  • Bank account verification data from our licensed banking partners
  • Credit risk signals from regulated financial data providers where applicable

3. How We Use Your Information

  • To verify your identity and complete KYC/AML checks as required by Nigerian law and CBN regulations
  • To process and execute transfers, bill payments, airtime purchases, and crypto trades
  • To power Naya's AI assistant across English, Pidgin, Yoruba, and Hausa
  • To provide spending insights, budget alerts, and transaction summaries
  • To detect and prevent fraud, money laundering, and unauthorised account access
  • To comply with legal and regulatory obligations, including reporting to relevant authorities
  • To improve the platform, including AI model training based on anonymised interaction data
  • To communicate service updates, security alerts, and policy changes

4. Legal Basis for Processing

We process your personal data under the Nigeria Data Protection Act (NDPA) 2023 on the basis of contractual necessity, legal obligation, legitimate interests, and consent where applicable.

5. Data Sharing and Disclosure

We do not sell your personal data. We may share your information with:

  • CBN-licensed banking and payment partners required to execute your transactions
  • Identity verification providers for KYC compliance
  • Regulatory authorities where required by law or court order
  • Law enforcement agencies in response to valid legal process
  • Technology service providers operating under strict data processing agreements
  • Successor entities in the event of a merger, acquisition, or restructuring

6. Data Retention

We retain your personal data for as long as your account remains active and for a minimum of five (5) years after account closure, as required by Nigerian AML/CFT regulations. Transaction records may be retained longer where required by law or ongoing regulatory proceedings.

7. Your Rights Under NDPA 2023

As a data subject under Nigerian law, you have the right to:

  • Access a copy of the personal data we hold about you
  • Request correction of inaccurate or incomplete data
  • Request deletion of your data, subject to regulatory retention obligations
  • Object to or restrict certain types of processing
  • Receive your data in a structured, machine-readable format
  • Withdraw consent at any time where processing is based on consent

To exercise any of these rights, contact us at support@usenaya.com. We will respond within 30 days.

8. Cross-Border Data Transfers

As Naya expands to Kenya, Ghana, South Africa, and other markets, your data may be transferred to and processed in jurisdictions outside Nigeria. We ensure that all cross-border transfers comply with applicable data protection laws and are subject to appropriate contractual safeguards.

9. Security of Your Data

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures are described in our Security Policy, which forms part of this document.

10. Children

Naya's services are not intended for individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a minor, we will promptly delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via WhatsApp notification or other appropriate channels. Your continued use of Naya following any update constitutes acceptance of the revised policy.

12. Contact

Data Controller: Usenaya Ltd

Email: support@usenaya.com

WhatsApp: wa.me/2349163718648