PrivacyPolicy&DataProtection.
This Privacy Policy governs the collection, processing, hardware isolation, and retention of user data across the AjePay Android mobile banking application and digital financial channels operated by AjePay Microfinance Bank Limited.
Who Manages Your Data
The data controller responsible for the processing of your personal and financial information under this policy is:
AjePay Microfinance Bank Limited
Corporate Headquarters: Plot 14 Admiralty Way, Lekki Phase 1, Lagos State, Nigeria
Statutory Licensure: Central Bank of Nigeria (CBN) | NDIC Insured Deposits
Data Protection Officer: privacy@ajepay.ng | concierge@ajepay.ng
Information We Collect and Process
To deliver institutional-grade banking, instant NIP transfers, and automated utility vending, AjePay collects specific categories of user data in strict compliance with Central Bank of Nigeria (CBN) guidelines and the Nigeria Data Protection Act (NDPA):
Full legal name, date of birth, residential address, active Nigerian mobile telephone number, email address, and statutory identity numbers (Bank Verification Number - BVN, National Identity Number - NIN) verified directly against central NIBSS and NIMC clearing databases.
Dedicated 10-digit NUBAN account numbers, wallet balances, debit and credit transaction histories, counterparties, utility meter numbers (prepaid/postpaid), cable TV IUC/Smartcard numbers, and digitally signed payment receipts.
Android hardware model, operating system version, unique hardware identifiers, IP address, and Google Play Integrity API verification verdicts. Collected strictly to detect device rooting, emulator virtualization, and fraudulent SIM-swap takeovers.
Fingerprint and Face Unlock credentials are processed entirely on-device within the isolated Android Hardware Keystore (ARM TrustZone / StrongBox). AjePay never accesses, captures, stores, or transmits raw biometric templates to our servers.
Explicit Permission Justifications
In accordance with Google Play Developer Policies, AjePay explicitly discloses the technical runtime permissions requested by our Android mobile application and why they are required:
Optional. Used strictly when you scan QR codes to send transfers or capture identity documents for Tier 3 KYC verification. Never runs in the background.
Strictly optional. Only accessed if you explicitly choose to select a recipient from your address book during airtime or mobile data vending. Contacts are never synced, uploaded, or stored on external servers.
Used to dispatch instantaneous transaction confirmation alerts, 20-digit electricity tokens, credit/debit alerts, and critical security notices.
Used solely when you tap to download or export a structured PDF/image transaction receipt to your device's local Downloads directory.
Why We Process Your Data
1. Contract Performance: Executing real-time inter-bank transfers via NIBSS, generating 20-digit STS prepaid electricity tokens, dispensing telecom airtime and SME data, and updating wallet ledgers.
2. Statutory Compliance: Satisfying mandatory legal requirements imposed by the Central Bank of Nigeria (CBN), the Money Laundering (Prevention and Prohibition) Act, and the Nigeria Financial Intelligence Unit (NFIU).
3. Fraud Prevention & Platform Security: Protecting customer deposits through automated transaction anomaly detection, device fingerprinting, and hardware-enforced transaction PIN authorization.
4. Customer Concierge Support: Resolving transaction enquiries, disputed bill tokens, and technical assistance via our 24/7 client concierge desk.
Zero Monetization of Customer Data
AjePay strictly does NOT sell, rent, license, or monetize your personal, financial, or device data to any third-party advertising networks, data brokers, or marketing intermediaries.
Data is disclosed solely to authorized statutory bodies and clearing partners necessary to execute transactions:
- Nigerian Inter-Bank Settlement System (NIBSS) for NIP switch routing.
- Licensed Electricity Distribution Companies (DisCos) for meter token vending.
- Telecom carriers (MTN, Airtel, Glo, 9mobile) for data provisioning.
- Central Bank of Nigeria (CBN), NDIC, and NFIU under lawful statutory reporting.
Account Deletion & Data Erasure
You maintain the unequivocal right to close your AjePay account and request permanent deletion of your personal identifying data at any time. In compliance with Google Play User Data policies, AjePay provides both an in-app pathway and a direct web contact mechanism to request account deletion:
Open the AjePay Android App → Navigate to Settings → Select Security & Privacy → Tap Request Account Closure & Deletion → Authorize with your 4-digit PIN.
Send an email from your registered email address to privacy@ajepay.ng with the subject line "Account Deletion Request", including your registered mobile phone number.
Upon verified account closure, your active wallet is deactivated, dedicated NUBAN unlinked, and personal marketing profile purged within 7 business days. As a Central Bank of Nigeria (CBN) regulated financial institution, AjePay is statutorily required under the Money Laundering (Prevention and Prohibition) Act to retain financial transaction audit ledgers and KYC compliance records for a mandatory statutory period (5 to 6 years), after which all archived records are irreversibly destroyed.
Cryptographic Safeguards
1. Encryption in Transit: TLS 1.3 enforced across all API endpoints with strict HTTP Strict Transport Security (HSTS) and Perfect Forward Secrecy.
2. Encryption at Rest: AES-256-GCM authenticated encryption protecting all core database stores and ledger archives.
3. Hardware Keystore Isolation: Asymmetric cryptographic signature keys and transaction PIN verification hashes execute within isolated Android StrongBox hardware silicon.
Strict Age Eligibility
AjePay's mobile banking application and digital financial utilities are strictly intended for legal adults aged 18 years and older possessing valid national identity documentation. We do not knowingly collect, solicit, or maintain personal information from individuals under the age of 18.
Exercise Your Rights or Inquire
To exercise your statutory rights of access, rectification, or data portability under the Nigeria Data Protection Act (NDPA), or to address any privacy enquiries, contact our dedicated Data Protection Officer:
Email: privacy@ajepay.ng
Executive Concierge: concierge@ajepay.ng
Physical Address: Plot 14 Admiralty Way, Lekki Phase 1, Lagos State, Nigeria