Part One: Privacy Policy
This Privacy Policy applies to the ClearPoint mobile application for Android (distributed via Google Play) and iOS (distributed via Apple App Store), as well as associated web platforms and APIs. Read on to understand our practices, and reach out to us at [email protected] if you have any questions.
1. Who We Are & Data Controller Contact
ClearPoint is a financial technology platform providing virtual dollar and local cards, utility bill processing, airtime/data top-ups, and instant wallet settlement services. For the purpose of applicable data protection laws, ClearPoint Ltd is the Data Controller responsible for your personal data.
Data Protection Officer (DPO): [email protected]
2. Information We Collect and How We Collect It
To provide safe and compliant financial services, we collect personal and financial information in accordance with App Store Guidelines (Section 5.1) and Google Play Data Safety requirements:
- Personal Identity & KYC Data: Full name, date of birth, residential address, phone number, email address, national identity numbers (NIN, BVN), and photo/government ID images for identity verification.
- Financial & Transaction Data: Bank account numbers, transaction amounts, payment history, card tokens, utility account numbers (electricity meters, TV smartcards), and transfer details.
- Device & Technical Identifiers: IP address, device hardware model, OS version, unique device identifiers (IMEI/UUID), cellular network provider, and app crash diagnostics logs.
- Camera & Media Access (With Explicit Permission): Camera access for document uploads during KYC registration or QR code scanning for payments. We never access your camera or photos without explicit permission.
- Location Data: Coarse or precise geographic location data collected strictly to prevent unauthorized access and comply with anti-fraud/AML geographic regulations.
3. Purpose and Legal Basis for Processing
We collect and process your personal data under the following legal bases:
- Service Delivery (Contractual Obligation): Processing transfers, bill payments, issuing virtual cards, and managing wallet account balances.
- Regulatory Compliance (Legal Obligation): Fulfilling Anti-Money Laundering (AML), Counter-Terrorism Financing (CFT), and Know-Your-Customer (KYC) compliance mandates mandated by Nigerian financial regulators and licensing partners.
- Fraud Prevention & Security (Legitimate Interest): Detecting unauthorized access, preventing fraudulent transactions, and safeguarding funds.
4. Sharing and Third-Party Disclosure
We do not sell, rent, or trade your personal data to third parties or advertisers. We share data only with trusted entities required to fulfill financial operations:
- Licensed Financial & Banking Partners: Central Bank of Nigeria (CBN)-licensed banks and switching networks responsible for processing money transfers and Virtual Cards.
- KYC Verification Partners: Identity verification gateways used strictly to validate official government records (e.g., BVN, NIN).
- Cloud Storage & Security Infrastructure: Secure, SOC-2 compliant hosting services to process and store data with end-to-end encryption.
- Legal Authorities: When compelled by valid court orders, subpoenas, or statutory regulatory mandates.
5. Data Retention & Mandatory Retention Period
We retain your personal data for as long as your account remains active. Upon account deletion, statutory accounting, anti-money laundering laws, and banking regulations require financial records (including transaction histories and KYC verification data) to be archived for up to 5 to 7 years before permanent deletion.
6. Account & Data Deletion Rights (App Store & Google Play Requirement)
In compliance with Apple App Store Guideline 5.1.1(v) and Google Play Developer Policies, you have the right to request full account closure and deletion of your personal data at any time.
How to Delete Your Account:
- In-App: Go to Settings > Security & Account > Request Account Deletion in your ClearPoint app.
- Web Request: Submit an account deletion request online via [email protected] with your registered phone number and email address.
Once requested, your account will be immediately deactivated, and non-statutory data will be deleted within 30 days.
7. Children's Privacy (COPPA & GDPR Compliance)
ClearPoint services are intended strictly for users aged 18 and older. We do not knowingly collect or solicit personal information from individuals under the age of 18. If we become aware that a minor has submitted personal information without verifiable parental consent, we will immediately close the account and remove the data.
8. Security Measures
We maintain multi-layered security controls to protect your personal and financial data:
- 256-bit Advanced Encryption Standard (AES) data encryption at rest.
- Transport Layer Security (TLS 1.3) protocols for all network transmissions.
- Biometric authentication (Touch ID / Face ID / Fingerprint) and Mandatory 6-digit transaction PINs.