Privacy Policy

1. Introduction

ZuruSafe Systems Limited ("ZuruSafe," "we," "our," or "us") is committed to protecting your privacy and personal data.

This Privacy Policy explains how we collect, use, store, share, disclose, and protect your information when you use the ZuruSafe website, mobile application, APIs, and related services (collectively, the "Service").

By accessing or using ZuruSafe, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

2. Who We Are

ZuruSafe is operated by ZuruSafe Systems Limited, a company registered with the Corporate Affairs Commission (CAC) in Nigeria.

3. Scope of This Policy

This Privacy Policy applies to all users, visitors, and counterparties who access or use ZuruSafe.

It forms part of and is incorporated into the ZuruSafe Terms & Conditions.

4. Information We Collect

4.1 Information You Provide

We may collect:

• Full legal name
• Email address
• Phone number
• Date of birth
• Residential address
• Government-issued identification
• Selfie images and facial data (for identity verification)
• Bank account and payout details
• Passwords (hashed and encrypted)
• Transaction details (amount, description, counterparty details)
• Dispute information and uploaded evidence
• Communications with customer support

You represent and warrant that all information you provide is accurate and up to date.

4.2 Information We Collect Automatically

When you use ZuruSafe, we may collect:

• IP address
• Device identifiers
• Device type and operating system
• Browser type
• Session timestamps
• Log files
• Usage behavior and interaction data
• Location data (approximate)
• Cookies and similar tracking technologies

4.3 Information from Third Parties

We may receive information from:

• Payment processors (including Monnify)
• Banks and financial institutions
• Identity verification providers
• Sanctions screening services
• Fraud detection and credit risk services

5. Sensitive Personal Data

We may process sensitive personal data, including:

• Government identification numbers
• Biometric identifiers (selfie images, facial recognition templates)
• Financial account information

You expressly consent to the collection and processing of such data for identity verification, fraud prevention, and legal compliance.

6. How We Use Your Information

We use your information to:

• Create, verify, and manage user accounts
• Process transactions and payments
• Hold, manage, and release escrow funds
• Conduct KYC, AML, and sanctions screening
• Prevent fraud and abuse
• Resolve disputes and investigations
• Provide customer support
• Send transactional and service-related notifications
• Improve and personalize the Service
• Conduct analytics and internal audits
• Enforce our Terms & Conditions
• Comply with legal, regulatory, and law enforcement obligations

7. Legal Bases for Processing

We process personal data based on one or more of the following legal bases:

• Your explicit consent
• Performance of a contract
• Compliance with legal obligations
• Legitimate business interests (including fraud prevention and platform security)

8. How We Share and Disclose Your Information

We may share or disclose your information to:

• Payment processors and banks
• Identity verification providers
• Fraud prevention and compliance partners
• Cloud hosting and infrastructure providers
• Professional advisers (lawyers, auditors)
• Regulators, courts, or law enforcement agencies

We do not sell your personal data.

9. Marketing Communications

We may send you:

• Transactional emails and SMS
• Service announcements
• Product updates and security alerts

We will only send marketing communications where permitted by law.

You may opt out of marketing emails at any time.

10. Data Retention

We retain personal data for as long as:

• Your account remains active
• Necessary to perform our contractual obligations
• Required to comply with legal, tax, and regulatory requirements
• Needed for dispute resolution, fraud prevention, or enforcement actions

We may retain and use certain information after account closure.

11. Data Security

We implement reasonable administrative, technical, and physical safeguards, including:

• Encryption at rest and in transit
• Secure servers and firewalls
• Access controls and monitoring

However, no system is completely secure.

You acknowledge and accept this risk.

12. Data Breach Limitation of Liability

To the maximum extent permitted by law:

• ZuruSafe shall not be liable for indirect, incidental, special, or consequential damages arising from any data breach.
• ZuruSafe's total liability for any data breach shall not exceed the total fees paid by you to ZuruSafe in the twelve (12) months preceding the incident.

13. Government and Law Enforcement Disclosures

We may disclose your information without notice where required or permitted by law, including in response to:

• Subpoenas
• Court orders
• Regulatory requests
• National security or law enforcement demands

14. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Authenticate users
• Maintain sessions
• Analyze usage
• Improve performance

You may disable cookies through your browser settings, but some features may not function properly.

15. International Data Transfers

Your data may be transferred to, processed, and stored outside Nigeria.

We implement safeguards to ensure adequate protection of your personal data.

16. Your Rights

Subject to applicable law, you may have the right to:

• Access your personal data
• Correct inaccurate data
• Request deletion of your data
• Restrict or object to processing
• Withdraw consent

We may deny requests where legally permitted.

17. Children's Privacy

ZuruSafe is not intended for users under 18 years of age.

We do not knowingly collect personal data from minors.

18. Third-Party Links

The Service may contain links to third-party websites.

We are not responsible for their privacy practices.

19. Changes to This Policy

We may modify this Privacy Policy at any time.

Continued use of the Service constitutes acceptance of the revised policy.

20. Contact Information

ZuruSafe Systems Limited

Email: support@zurusafe.com