1. Introduction
Koineckta respects your privacy and is committed to protecting personal data entrusted to us. This Privacy Policy explains how personal data is collected, used, stored, shared, protected and otherwise processed when you access or use the Koineckta websites, mobile or web applications, merchant portals, APIs, payment services, customer-support channels and related products or services collectively referred to as the “Services.”
Koineckta is a brand and service operated by KOINECKTA TECHNOLOGIES LIMITED, incorporated under the laws of the Federal Republic of Nigeria with registered address at Plot 2, Road 2, Ikota Villa Estate, Lekki, Lagos Island LGA, Lagos State 101342, Nigeria (“Koineckta”, “we”, “us” or “our”).
This Policy is intended to comply with applicable privacy and data-protection requirements, including the Nigeria Data Protection Act 2023 (“NDPA”), applicable directives and guidance issued by the Nigeria Data Protection Commission (“NDPC”), and other applicable laws. By using the Services, you acknowledge that you have read this Privacy Policy.
2. Scope
This Privacy Policy applies to personal data processed in connection with:
- koineckta.com and other Koineckta-controlled domains and subdomains;
- Koineckta mobile and web applications;
- individual and merchant accounts;
- digital-asset payment and wallet functionality;
- bank and mobile-money settlement services;
- payment links, QR payments and checkout services;
- merchant dashboards;
- APIs and webhooks;
- account registration, KYC and KYB processes;
- customer-support interactions;
- marketing, newsletters and product communications; and
- fraud prevention, security, compliance and transaction monitoring.
Third-party websites, wallets, banks, mobile-money operators or services accessible through Koineckta may operate under their own privacy policies.
3. Personal Data We Collect
Depending on the Services you use, we may collect the following categories of personal data.
3.1 Identity and Contact Information
This may include:
- full name;
- date of birth;
- nationality;
- residential or business address;
- email address;
- telephone number;
- gender, where legally required;
- government-issued identification details;
- photograph; and
- other information required to establish or verify identity.
3.2 KYC, KYB and Compliance Information
For individuals or businesses subject to verification, we may process:
- national identification documents;
- passports, driver’s licences or other approved documents;
- Bank Verification Number or equivalent identifiers where lawfully required;
- facial verification or biometric information where necessary and permitted by law;
- proof of address;
- company registration information;
- directors, shareholders and beneficial-owner information;
- politically exposed person (“PEP”) screening information;
- sanctions and watchlist results;
- fraud-risk indicators; and
- information required for anti-money-laundering, counter-terrorist-financing or other regulatory checks.
Where biometric or other sensitive personal data is processed, Koineckta will apply appropriate safeguards and lawful processing requirements.
3.3 Financial and Payment Information
This may include:
- bank-account information;
- mobile-money details;
- payment references;
- beneficiary details;
- transaction values;
- settlement information;
- funding and withdrawal information; and
- records associated with payment processing or reconciliation.
Koineckta does not intentionally collect full payment-card credentials unless required for a supported service and processed through an appropriately secured payment provider.
3.4 Digital-Asset and Wallet Information
Depending on the wallet or transaction model, we may collect:
- public wallet addresses;
- blockchain transaction identifiers;
- supported asset and network information;
- wallet type;
- deposit and withdrawal information;
- transaction history;
- conversion instructions;
- blockchain analytics and risk information; and
- other information required to complete or investigate transactions.
Public blockchain information may remain publicly accessible independently of Koineckta.
3.5 Merchant and Business Information
For merchants we may collect:
- business name;
- registration details;
- industry and business type;
- business address;
- website and social-media details;
- authorised representatives;
- ownership and control information;
- expected transaction volumes;
- settlement preferences;
- products or services offered; and
- information needed for risk assessment and merchant onboarding.
3.6 Device and Technical Information
When you access the Services we may automatically collect:
- IP address;
- device identifiers;
- operating system;
- browser type;
- login information;
- session information;
- approximate location derived from IP address;
- device and application events;
- security logs;
- crash reports; and
- usage information.
3.7 Communications
We may retain communications you send to us, including:
- support requests;
- complaints;
- emails;
- calls or chat records where permitted;
- survey responses; and
- feedback.
3.8 Marketing and Registration Information
Where you register for product updates, communications or related programmes, we may collect information such as:
- name;
- email;
- telephone number;
- country;
- business information;
- product interests;
- intended use of Koineckta; and
- marketing preferences.
4. How We Obtain Personal Data
We may obtain personal data:
- directly from you;
- from merchants using Koineckta;
- from your device or browser;
- from banks and payment providers;
- from wallet, custody and blockchain infrastructure providers;
- from identity-verification and KYC/KYB providers;
- from fraud, sanctions, AML and blockchain-analysis providers;
- from publicly available databases and blockchains;
- from regulators, law-enforcement agencies or authorised public bodies;
- from business partners; and
- through cookies and similar technologies.
5. Why We Process Personal Data
Provide the Services
Including to:
- create and administer your account;
- authenticate users;
- provide wallets and payment functionality;
- process payments;
- execute authorised asset conversions;
- process withdrawals and settlements;
- facilitate merchant payment acceptance;
- maintain transaction histories;
- reconcile transactions; and
- provide customer support.
Verify Identity and Meet Legal Obligations
Including to:
- perform KYC and KYB checks;
- verify beneficial ownership;
- screen against sanctions and PEP lists;
- monitor transactions;
- investigate suspicious activity;
- prevent fraud and money laundering; and
- respond to lawful regulatory or governmental requests.
Maintain Security
Including to:
- protect user accounts;
- detect unauthorised access;
- investigate suspicious behaviour;
- protect Koineckta systems;
- prevent abuse; and
- maintain audit and security records.
Improve Our Products
Including to:
- analyse service performance;
- diagnose problems;
- develop new features;
- understand user behaviour;
- improve usability; and
- measure service reliability.
Communicate With You
Including to send:
- transaction notifications;
- security alerts;
- account notices;
- service announcements;
- regulatory notices;
- support responses; and
- marketing communications where permitted.
6. Lawful Bases for Processing
Depending on the circumstances, Koineckta may process personal data because:
- processing is necessary to perform a contract with you;
- processing is necessary to comply with a legal obligation;
- you have provided valid consent;
- processing is necessary for Koineckta’s legitimate interests, provided those interests do not override your rights;
- processing is necessary to protect vital interests where applicable; or
- another lawful basis recognised under applicable law applies.
Consent will not be treated as the lawful basis where another legal basis properly applies. You may withdraw consent where processing is based specifically on consent. Withdrawal does not invalidate lawful processing carried out before withdrawal.
7. Automated Screening and Risk Decisions
Koineckta and its service providers may use automated systems to assist with:
- identity verification;
- fraud detection;
- transaction monitoring;
- sanctions screening;
- blockchain-risk assessment;
- account-security monitoring; and
- risk-based transaction controls.
Such systems may result in a transaction being delayed, reviewed, rejected or an account being temporarily restricted. Where applicable law provides a right to challenge a decision based solely on automated processing that significantly affects you, you may contact us to request appropriate review.
8. How We Share Personal Data
Koineckta does not sell personal data. We may disclose information where reasonably necessary to:
Service Providers
Including:
- hosting and cloud providers;
- identity-verification providers;
- KYC/KYB providers;
- AML, sanctions and transaction-monitoring providers;
- blockchain-analysis providers;
- wallet or custody infrastructure providers;
- liquidity and conversion providers;
- banks;
- payment processors;
- mobile-money operators;
- telecommunications providers;
- fraud-prevention vendors;
- email and communications providers;
- customer-support providers;
- analytics providers; and
- professional advisers.
Merchants and Transaction Counterparties
Where necessary to complete a payment or settlement, we may disclose information such as:
- payment status;
- transaction reference;
- amount;
- payer or recipient information where appropriate; and
- settlement information.
Regulators and Authorities
We may disclose personal data where required or permitted by law to:
- courts;
- regulators;
- law-enforcement agencies;
- tax authorities;
- financial-intelligence bodies; or
- other competent governmental authorities.
Corporate Transactions
Information may be disclosed in connection with a:
- merger;
- acquisition;
- financing;
- restructuring;
- sale of assets; or
- similar corporate transaction.
Any such disclosure will be subject to appropriate confidentiality and legal safeguards.
9. International Data Transfers
Some Koineckta service providers or infrastructure may be located outside Nigeria. Where personal data is transferred internationally, Koineckta will take reasonable and legally required steps to ensure an appropriate level of protection, which may include:
- transfers to jurisdictions recognised as providing adequate protection;
- contractual safeguards;
- regulatory-approved mechanisms;
- consent where legally appropriate; or
- another legally permitted transfer mechanism.
10. Data Retention
Koineckta retains personal data only for as long as reasonably necessary for the purposes for which it was collected and to satisfy applicable:
- legal requirements;
- AML/CFT obligations;
- regulatory obligations;
- tax and accounting requirements;
- dispute-resolution requirements;
- fraud-prevention requirements; and
- security needs.
Certain identity, KYC/KYB and transaction records may therefore be retained after an account is closed where applicable law requires or permits such retention. Once information is no longer required, it will be deleted, anonymised or securely disposed of in accordance with applicable requirements.
11. Data Security
Koineckta uses administrative, organisational and technical safeguards designed to protect personal data against:
- unauthorised access;
- accidental loss;
- misuse;
- alteration;
- disclosure; and
- destruction.
Controls may include encryption, access restrictions, authentication controls, monitoring, audit logging, secure development practices and vendor-risk management. No electronic or internet-based system can, however, be guaranteed to be completely secure. You are responsible for protecting passwords, authentication credentials, devices and other account-security information under your control.
12. Your Privacy Rights
Subject to applicable law, you may have rights to:
- be informed about processing of your personal data;
- access personal data held about you;
- request correction of inaccurate or incomplete data;
- request deletion where legally applicable;
- request restriction of certain processing;
- object to certain processing;
- withdraw consent where consent is the applicable lawful basis;
- request portability of eligible personal data;
- object to direct marketing;
- seek review of certain automated decisions; and
- lodge a complaint with the Nigeria Data Protection Commission or another competent authority.
Some requests may be restricted where Koineckta must retain or process information to comply with law, resolve disputes, prevent fraud or protect legal rights. We may need to verify your identity before acting on a privacy request.
13. Children
Koineckta’s financial and digital-asset Services are not intended for persons under 18 years of age, unless a particular service expressly states otherwise and is legally permitted. We do not knowingly permit minors to establish standard Koineckta transactional accounts. If we become aware that personal data has been collected from a minor contrary to our requirements, appropriate steps will be taken.
14. Cookies and Similar Technologies
Koineckta websites may use cookies and similar technologies for:
- essential website functionality;
- security;
- authentication;
- remembering preferences;
- analytics;
- performance measurement; and
- marketing where permitted.
Where required, non-essential cookies will be activated only after appropriate consent. Users should be provided with access to cookie-preference controls where applicable.
15. Marketing Communications
Where permitted, Koineckta may send product information, promotions or updates. You may opt out of non-essential marketing communications at any time using the unsubscribe mechanism provided or by contacting us. Operational, security, legal and transaction-related communications may still be sent where necessary.
16. Third-Party Services and Links
The Services may contain links or integrations with third parties. Koineckta is not responsible for the privacy practices of third-party websites or services that operate independently from Koineckta. You should review their applicable privacy notices before providing personal information.
17. Data Breaches
Where Koineckta becomes aware of a personal-data breach, we will investigate and take appropriate remedial action. Where required by applicable law, Koineckta will notify the NDPC and affected individuals within the applicable regulatory requirements.
18. Changes to this Privacy Policy
We may amend this Privacy Policy periodically to reflect changes to the Services, operational changes, changes in law, regulatory requirements or improvements to our privacy practices. Material changes will be communicated through an appropriate channel. The date shown at the top of this Policy indicates the latest version.
19. Contact Us
Legal Entity
KOINECKTA TECHNOLOGIES LIMITED
Registered Address
Plot 2, Road 2, Ikota Villa Estate, Lekki, Lagos Island LGA, Lagos State 101342, Nigeria
Legal
legal@koineckta.com
Support
support@koineckta.com
For privacy and data-protection enquiries, please contact legal@koineckta.com. Where applicable, contact details for Koineckta’s Data Protection Officer or Data Protection Compliance Organisation will be made available through the Services. You also have the right, where applicable, to lodge a complaint with the Nigeria Data Protection Commission (NDPC).