RamperPay Privacy Policy

1. Introduction

1.1.This Privacy Policy explains how Trillion Technology and Trades Ltd ("the Company," "we," "us," "our") collects, uses, stores, and discloses personal data when you ("User," "you," "your") use the RamperPay platform and its associated products and services.

1.2.Trillion Technology and Trades Ltd is a private limited liability company incorporated in Nigeria (RC 9261037) and is the data controller for personal information collected in connection with the provision of RamperPay's services.

1.3. This policy explains:

• How we collect, use, manage, and disclose information about our users
• The legal basis on which we process your personal information
• The rights you hold in respect of your own personal data

1.4. By creating an account or otherwise using RamperPay, you confirm that you have read this Privacy Policy and consent to the collection and use of your personal data as described.

2. Definitions

• Personal Data: any information relating to you that is capable of identifying you.
• Platform: the RamperPay application, website, and any connected services.
• Services: the crypto and fiat transaction, remittance, and account services offered through RamperPay.
• Third Party Service Provider: any party engaged by us to process personal data on our behalf, such as identity verification, payment processing, or infrastructure providers.
• You / Your: the User of the RamperPay platform.

3. Scope of Data We Collect

We may collect:

• Personal data you provide directly to us
• Data provided when making an enquiry about our services
• Data provided when reporting an issue or submitting a complaint

4. Types of Data We Collect

• Identity Data: full name, date of birth, gender, and photographic or biometric identification.
• Contact Data: home address, email address, and phone number.
• Account Information: usernames, passwords, authentication methods, and account roles.
• Financial Data: bank account details, payment card information, and wallet addresses.
• Transaction Data: details of crypto and fiat transactions, transfers, and remittances made through RamperPay.
• Technical Data: IP address, device identifiers, login data, browser type, operating system, and time zone.
• Marketing and Communication Data: your preferences regarding marketing communications and notifications.
• Verification Data: government issued identification numbers (such as NIN or BVN) and a selfie or biometric facial data, collected for identity verification purposes.

5. Why We Collect Data

We collect and process your data to:

• Process your registration, transactions, and requests
• Communicate with you about our services and respond to enquiries
• Comply with our Know Your Customer (KYC) and Anti Money Laundering / Combating the Financing of Terrorism (AML/CFT) obligations under applicable Nigerian law
• Detect and prevent fraud, and protect the security of our users and platform
• Maintain, improve, and troubleshoot the functionality of our platform
• Meet our obligations to regulatory and supervisory bodies

6. How We Collect Your Personal Data

7. Storage of Personal Data

7.1. We take reasonable measures to protect the personal data we collect against accidental loss, destruction, or unauthorized access. No method of electronic storage or transmission is completely secure.

7.2. Personal data is retained for as long as your account remains active, or as required to meet our legal, regulatory, and operational obligations.

8. Legal Basis for Processing

We process your personal data under one or more of the following lawful bases, consistent with the Nigeria Data Protection Act:

• Your consent
• Performance of a contract with you
• Compliance with a legal or regulatory obligation, including AML/CFT and KYC requirements
• Protection of your vital interests or those of another individual
• Legitimate interest in preventing fraud and maintaining platform security

9. Data Security

9.1. We apply industry standard security measures, including encrypted storage of sensitive credentials and restricted access controls, to protect your personal data from loss, misuse, or unauthorized disclosure.

9.2. While we take reasonable steps to secure your data, no transmission over the internet can be guaranteed completely secure, and any such transmission is at your own risk.

10. Data Retention

10.1. We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including meeting legal, regulatory, and audit requirements. When data is no longer required, it is securely deleted or anonymized.

11. Disclosure of Your Information

Your personal data may be disclosed:

• To regulatory or governmental bodies where required by Nigerian law, including for AML/CFT compliance
• To our licensed third party service providers, strictly for the purposes described in this policy
• Where necessary to enforce our Terms of Use or other agreements
• To protect our rights, property, or safety, or those of our users
• In response to a valid legal process, such as a court order or regulatory request

12. Third Party Services

12.1. RamperPay relies on regulated third party providers to deliver parts of our services, including identity verification, payment processing, and secure infrastructure hosting. These providers are contractually bound to handle your data in accordance with applicable data protection standards.

12.2. We are not responsible for the privacy practices of third party services you may separately choose to interact with, and we encourage you to review their respective privacy policies.

13. Privacy Policy Changes

13.1. We may update this Privacy Policy from time to time. Material changes will be communicated via email or in app notification. Continued use of RamperPay after changes take effect constitutes acceptance of the revised policy.

14. Your Legal Rights

You have the right to:

• Request access to the personal data we hold about you
• Request correction of inaccurate or incomplete data
• Request restriction of certain processing activities
• Request erasure of your personal data, subject to our legal retention obligations
• Object to processing carried out for direct marketing purposes
• Request portability of your data to another provider, where technically feasible

To exercise any of these rights, contact us using the details below.