Introduction

Welcome to Cashmatrix. This Data Consent Policy explains how we obtain, use, and protect your explicit consent for the collection, processing, and storage of your Personal Data.

As a financial institution licensed by the Central Bank of Nigeria (CBN) and insured by the Nigeria Deposit Insurance Corporation (NDIC), we are required to collect certain Personal Data from you to provide our services, comply with regulatory requirements, and protect against fraud.

This policy is designed to inform you about what data we collect, why we collect it, how we use it, and your rights as a data subject under the Nigeria Data Protection Act 2023 (NDPA).

By using our services, you consent to the collection and processing of your Personal Data as described in this policy. If you do not agree, you must not use our services.

What Data We Collect

We collect various categories of Personal Data to provide and improve our services:

Identity Data: Your full name, date of birth, gender, Bank Verification Number (BVN), National Identification Number (NIN), government-issued ID documents (National ID, Driver's License, International Passport, Voter's Card), photographs, live videos, and facial biometric data.

Contact Data: Your home address, work address, billing address, email address, and telephone numbers.

Financial Data: Your bank account details, payment card details, and information about your financial situation.

Transaction Data: Details about payments to and from you, transaction history, merchant information, and data related to your transactions with third parties.

Technical Data: Internet protocol (IP) address, browser type and version, time zone setting, operating system, and other technology on the devices you use to access our services.

Device Data: Details of your handset/device, unique device identifiers (IMEI or serial number), information about the SIM card, mobile network, operating system, and browser settings.

Location Data: With your consent, we collect your GPS location data for identity verification, address verification, and compliance with applicable regulatory requirements.

Image Data: Your portrait images, selfies, and facial biometric data for account opening, KYC verification, and regulatory compliance.

Why We Collect Your Data

We collect your Personal Data for the following purposes:

To provide our services: Process payments, transfers, bill payments, manage savings and investment accounts, and deliver other financial services.

To verify your identity: Conduct KYC (Know Your Customer) verification as required by CBN regulations and other applicable laws.

To prevent fraud and manage risk: Detect, prevent, and address fraudulent activities and unauthorized access to your account.

To comply with legal obligations: Meet regulatory requirements, respond to legal processes, and comply with applicable laws and regulations.

To improve our services: Analyze usage patterns, develop new features, and enhance user experience.

To communicate with you: Send transaction notifications, account updates, and (with your consent) marketing communications.

To resolve disputes: Address complaints, troubleshoot problems, and resolve conflicts.

How We Use Your Data

We use your Personal Data for the following specific purposes:

Service Provision: Initiate payments, send or request money, pay bills, manage your account, and authenticate your access.

Risk Management: Develop and adopt measures to verify your identity, detect fraud, and prevent abuse of our services.

Regulatory Compliance: Comply with CBN regulations, anti-money laundering (AML) requirements, and other applicable laws.

Communication: Send transaction confirmations, account statements, security alerts, and customer support responses.

Marketing: With your prior consent, send promotional materials about our products and services.

Analytics: Analyze usage patterns to improve our services, develop new features, and enhance user experience.

Data Minimisation: We ensure that Personal Data processed is adequate, relevant, and limited to what is necessary for the purposes for which it is collected.

Who We Share Your Data With

We may share your Personal Data with the following categories of recipients:

Cashmatrix Group Entities: Other entities within our group that are subject to equivalent levels of internal control, as necessary to provide technical services and manage risk.

Service Providers: Third-party companies that perform services on our behalf, such as payment processing, identity verification, customer support, and marketing.

Financial Institutions: Other financial institutions we partner with to provide Cashmatrix-related services.

Regulatory Authorities: Government agencies, law enforcement, and regulatory bodies as required by law or legal process.

Transaction Parties: Other users and their service providers involved in transactions you initiate.

Professional Advisers: Lawyers, accountants, auditors, and insurers who need access to your data for professional services.

We will not sell your Personal Data to third parties without your explicit consent.

Your Rights

Under the Nigeria Data Protection Act 2023, you have the following rights:

Right to be Informed: You have the right to be informed about how we collect, use, and protect your Personal Data.

Right to Access: You have the right to request a copy of the Personal Data we hold about you.

Right to Rectification: You have the right to request correction of inaccurate or incomplete Personal Data.

Right to Erasure: You have the right to request deletion of your Personal Data when it is no longer necessary for the purpose it was collected, or if you withdraw your consent.

Right to Restrict Processing: You have the right to request restriction of processing in certain circumstances.

Right to Data Portability: You have the right to receive your Personal Data in a structured, commonly used, machine-readable format.

Right to Object: You have the right to object to processing, including for direct marketing purposes.

Right to Withdraw Consent: You have the right to withdraw your consent at any time, and we will stop processing your data unless another lawful basis exists.

How to Exercise Your Rights

To exercise any of the rights described in this policy, please contact us at hello@cashmatrix.ng.

We may need to verify your identity before processing your request to ensure that Personal Data is not disclosed to unauthorized persons.

You will not have to pay a fee to access your Personal Data or exercise your rights, unless the request is clearly unfounded, repetitive, or excessive.

We aim to respond to all requests within one month. In complex cases, we may extend this period by an additional two months, and we will notify you of any extension.

If you are not satisfied with our response, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at info@ndpc.gov.ng.

Data Security

We implement appropriate technical and organizational measures to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction.

Our security measures include: encryption of data in transit and at rest, firewalls and intrusion detection systems, physical access controls to our premises, regular security audits and assessments, and employee training on data protection.

We restrict access to Personal Data to employees, contractors, and agents who need to know that information to process it on our behalf.

While we strive to protect your data, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

We will notify you of any data breaches that may result in high risks to your rights and freedoms.

Changes to This Policy

We may update this Data Consent Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

We will notify you of any material changes by posting the updated policy on our website and, where appropriate, by email notification.

We encourage you to review this policy periodically to stay informed about how we are protecting your data.

Your continued use of our services after any changes to this policy constitutes your acceptance of the updated policy.

Contact Us

If you have any questions, concerns, or requests regarding this Data Consent Policy or our data practices, please contact us:

Email: hello@cashmatrix.ng

We will acknowledge receipt of your inquiry within 24 hours and aim to resolve it within 14 business days.

If you are not satisfied with our response, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC):

NDPC Email: info@ndpc.gov.ng