Privacy Policy

Updated: Oct 9, 2025

IMPORTANT NOTICE: This Privacy Policy describes how Pairgate Venture (“Pairgate,” “we,” “us,” or “our”) collects, uses, discloses, and protects your personal information. By using our Platform, you consent to the data practices described in this Policy.

1. INTRODUCTION AND SCOPE

1.1 Application: This Privacy Policy applies to all personal information collected through:

The Pairgate website (https://pairgate.com)
Mobile applications (iOS and Android)
Customer support channels & email communications
Social media interactions and any other services operated by Pairgate (collectively, the “Platform”)

1.2 Acceptance: By accessing or using the Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree, you must immediately discontinue use.

1.3 Changes to Policy: We reserve the right to modify this Privacy Policy at any time. Changes are effective immediately upon posting. Your continued use after changes constitutes acceptance.

1.4 Age Restrictions: The Platform is not intended for persons under 18 years of age. We do not knowingly collect personal information from minors. If we discover such collection, we will delete it promptly.

1.5 Incorporation into Terms: This Privacy Policy is incorporated into our Terms and Conditions. Capitalized terms not defined herein have the meanings assigned in the Terms.

2. DEFINITIONS

“Personal Information” means any information relating to an identified or identifiable individual.
“Processing” means any operation performed on personal information, including collection, storage, use, disclosure, and deletion.
“Data Controller” means Pairgate Venture, which determines the purposes and means of processing personal information.
“Sensitive Personal Information” includes financial information, identification numbers, biometric data, and other information requiring heightened protection.
“Usage Data” means information about how you use the Platform.

3. INFORMATION WE COLLECT

3.1 Information You Provide Directly

A. Registration and Account Information

Full name, email address, phone number, date of birth, gender, residential address, username/password, profile photograph, BVN, NIN, other government‑issued identification numbers.

B. Financial and Payment Information

Bank account details, debit/credit card information, payment method details, transaction history, billing address, tax identification information, and credit/debit history on the Platform.

C. Verification Documents

Government‑issued ID (National ID, Driver’s License, Passport), utility bills, bank statements, proof of address, selfie photographs for KYC/AML compliance.

D. Communication & Transaction Information

Customer support inquiries, feedback, reviews, messages, email communications, phone call recordings, purchase details, recipient information, transaction dates, refunds and disputes.

3.2 Information Collected Automatically

Device & technical data: IP address, device type, OS version, browser type, device identifiers, mobile network, language, time zone.
Usage analytics: Pages visited, time spent, click patterns, search queries, error logs, referral sources.
Location information: GPS coordinates (with permission), IP‑based location, network location.
Cookies & tracking: Session cookies, persistent cookies, web beacons, pixel tags, local storage, device fingerprints.

3.3 Information from Third Parties

Identity verification results, fraud risk scores, watchlist screening, credit bureau information, payment processor confirmations, social media profile data (if linked), data brokers, public records.

3.4 Inferred Information – preferences, risk profiles, fraud likelihood scores, behavioral patterns.

4. HOW WE USE YOUR INFORMATION

Service Provision & Account Management: Create/manage accounts, process transactions, deliver services, verify identity, authenticate access, send notifications.
Security & Fraud Prevention: Detect/prevent fraud, monitor unauthorized access, conduct risk assessments, enforce Terms.
Legal & Regulatory Compliance: Comply with KYC/AML, tax reporting, respond to legal requests, cooperate with law enforcement.
Platform Improvement & Analytics: Analyze usage, improve user experience, test features, debug errors, develop new products.
Marketing & Communications: Send promotional emails, personalized offers, targeted ads, SMS, push notifications (opt-out available).
Personalization: Customize experience, remember preferences, display relevant content.

5. LEGAL BASIS FOR PROCESSING

Contractual Necessity: To perform our contract with you and provide Services.
Legal Obligations: KYC/AML, tax, regulatory requirements.
Legitimate Interests: Fraud prevention, platform improvement, business analytics, marketing, legal defense.
Consent: Where required by law, you may withdraw consent at any time.

6. HOW WE SHARE YOUR INFORMATION

We share information with categories of recipients including:

Service providers (payment processors, cloud providers, identity verification, analytics, marketing partners).
Financial institutions & payment networks (banks, card networks, mobile money operators).
Telecom & utility providers, government & regulatory authorities, legal advisors.
Business transaction parties (mergers/acquisitions), affiliated companies, credit bureaus, and with your consent.
Aggregate & de-identified data for any purpose.

7. INTERNATIONAL DATA TRANSFERS

The Platform is operated from Nigeria. Your personal information may be transferred to, stored in, and processed in Nigeria and other countries where we or our service providers operate. We implement safeguards such as standard contractual clauses. By using the Platform, you consent to cross-border data transfers.

8. DATA RETENTION

We retain personal information as long as necessary for the purposes outlined, legal obligations, and dispute resolution. Retention periods: Account information – duration of account plus 7 years after closure; transaction records – minimum 7 years; identity verification docs – 7 years after account closure; usage logs – up to 2 years; legal records – up to 10 years as required. When no longer needed, data is securely deleted or anonymized.

9. DATA SECURITY

We implement reasonable technical, physical, and administrative safeguards: SSL/TLS encryption, firewalls, intrusion detection, access controls, employee training, and incident response procedures. While no system is fully secure, we continuously enhance security measures. In case of a breach, we will notify affected users and regulators as required.

10. COOKIES & TRACKING TECHNOLOGIES

We use essential, analytics, marketing, and third-party cookies. You can manage cookies via browser settings. Disabling essential cookies may affect functionality. We do not currently honor “Do Not Track” signals.

11. YOUR RIGHTS AND CHOICES

Access: Request confirmation of processing and access to your data.
Correction & Deletion: Update inaccurate info or request deletion (subject to legal limits).
Restriction, Portability, Objection: Restrict processing, receive data in a portable format, object to marketing or legitimate interest processing.
Withdraw Consent & Marketing Opt-out: Unsubscribe via email links or account settings.

To exercise rights, email contact@pairgate.com (subject “Privacy Rights Request”). We respond within 30 days. You may also lodge a complaint with the Nigerian Data Protection Commission (NDPC).

12. CHILDREN'S PRIVACY

Our Platform is not for persons under 18. We do not knowingly collect children’s data. If we become aware, we delete it immediately.

13. THIRD-PARTY WEBSITES AND SERVICES

Our Platform may contain links to third-party sites. We are not responsible for their privacy practices. Please review their policies before providing any personal information.

14. AUTOMATED DECISION-MAKING AND PROFILING

We may use automated decisions for fraud detection, credit risk assessment, transaction approval, and personalized recommendations. You may request human review by contacting us.

15. MARKETING AND PROMOTIONAL COMMUNICATIONS

You may receive promotional messages unless you opt out via unsubscribe links or contacting support. Essential service communications (e.g., transaction alerts) cannot be opted out of.

16. CALIFORNIA PRIVACY RIGHTS (CCPA)

California residents have the right to know what personal information we collect, request deletion, and opt-out of data “sale.” To exercise rights, email contact@pairgate.com with “CCPA Request.”

17. EUROPEAN ECONOMIC AREA (EEA) & UK RIGHTS

If you are located in the EEA or UK, you have GDPR rights including access, rectification, erasure, restriction, portability, and objection. Contact our Data Protection Officer at contact@pairgate.com.

18. NIGERIA DATA PROTECTION COMPLIANCE (NDPR)

We adhere to the Nigeria Data Protection Regulation (NDPR) principles. For NDPR inquiries: contact@pairgate.com (subject “NDPR Compliance”).

19. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy. Material changes will be posted with an updated “Last Updated” date. Continued use constitutes acceptance.

20. CONTACT INFORMATION

Pairgate Venture
Email: support@pairgate.com | Website: https://pairgate.com
Data Protection Officer: support@pairgate.com (subject “Data Protection Officer”)
Privacy Rights: contact@pairgate.com
For complaints: Nigeria Data Protection Commission (NDPC) / NITDA – https://nitda.gov.ng

21. CONSENT AND ACKNOWLEDGMENT

By using the Platform, you acknowledge that you have read and understood this Privacy Policy, consent to the collection, use, and processing described, including international data transfers, and accept our security measures.

22. SUPPLEMENTARY INFORMATION

Language: English version prevails over translations. Severability: If any provision is invalid, the remainder remains effective. Governing Law: Laws of Nigeria. Integration: This Policy together with Terms constitutes the entire agreement.

END OF PRIVACY POLICY