PRIVACY
POLICY

This Privacy Policy explains how EscrowLink Technologies Limited ("EscrowPay", "we", "us", or "our") collects, uses, stores, and protects personal data when you use the EscrowPay platform.

EscrowPay is a technology platform that facilitates escrow transactions between buyers and sellers, primarily via WhatsApp. We process personal data in accordance with the Nigeria Data Protection Act 2023 (NDPA) and applicable regulations.

By using EscrowPay, you agree to the collection and use of your data as described in this Policy.

This Policy outlines what personal data we collect, how we collect and use it, who we share it with, how long we retain it, and your rights under applicable law.

EscrowLink Technologies Limited is the data controller responsible for your personal data.

For all data protection matters, you may contact:

4.1 Sellers

• WhatsApp phone number
• Display name
• NIN (used only for verification and not stored in raw form)
• Date of birth (verification result only)
• Bank account number and bank code
• Verified name from NIN lookup
• KYC status
• Transaction history

4.2 Buyers

• WhatsApp phone number
• NIN (used only for verification and not stored in raw form)
• Date of birth (verification result only)
• Email address
• Delivery address
• Payment method details (processed by payment providers and not stored by EscrowPay)
• Purchase history

4.3 All Users

• Transaction references and timestamps
• WhatsApp message logs related to transactions
• Dispute evidence submitted
• Platform activity data

We collect data directly from you when you create or participate in a transaction. We also collect data from WhatsApp messages exchanged through the platform, from payment and verification processes handled by third-party providers, and from automated system logs generated through your use of the platform.

6.1 Identity Verification

We use your data to verify seller and buyer identity using NIN and date of birth through third-party providers.

6.2 Transaction Processing

We use your data to create, manage, and complete escrow transactions.

6.3 Communication

We use your data to send updates and notifications via WhatsApp and email.

6.4 Dispute Resolution

We use your data to review evidence and determine outcomes in disputed transactions.

6.5 Fraud Prevention

We use your data to detect and prevent fraud or misuse of the platform.

6.6 Legal and Regulatory Compliance

We use your data to comply with applicable legal and regulatory obligations.

• Contract, where processing is necessary to perform escrow transactions
• Legal obligation, where processing is required to comply with applicable laws
• Legitimate interests, including fraud prevention, platform security, and service improvement
• Consent, where required for specific processing activities

8.1 Identity Verification

NIN verification is conducted via third-party providers such as Prembly. Data shared includes NIN and date of birth for verification purposes only.

8.2 Payment Processing

Payments are handled by licensed payment processors engaged by EscrowPay from time to time. EscrowPay does not store card or bank payment details.

8.3 Cloud Hosting

Data is hosted on secure infrastructure providers such as Render.

8.4 Messaging Platform

Communication occurs via WhatsApp (Meta Platforms). Messages are subject to the provider's own privacy policies.

8.5 Banking Partner

Funds are held by EscrowLink Technologies Limited's licensed banking partner. Data shared includes verified identity information necessary to facilitate the holding and release of funds.

We implement appropriate technical and organisational measures to protect your data.

Verified names, KYC verification results, and related account verification records are stored in encrypted form within EscrowPay's database infrastructure, including secure PostgreSQL database environments hosted by authorised cloud service providers.

Personal data may be stored on secure cloud infrastructure located within or outside Nigeria, subject to applicable legal, contractual, technical, and organisational safeguards designed to ensure the protection of such personal data in accordance with applicable data protection laws.

Access to data is restricted to authorised personnel. While we take reasonable steps to protect your data, no system is completely secure.

We do not sell your personal data. We may share your data with service providers necessary to operate the platform, to comply with legal or regulatory obligations, or to prevent fraud and protect users and the platform.

Your data may be processed on servers located outside Nigeria through our service providers. Where this occurs, we take reasonable steps to ensure appropriate safeguards are in place in accordance with applicable data protection laws.

Where personal data is transferred outside Nigeria, EscrowPay shall ensure that such transfer is carried out in accordance with applicable data protection law and subject to appropriate contractual, technical, or organisational safeguards.

We may retain data for longer where required by law or for dispute resolution.

Subject to applicable data protection laws, you may have the following rights in relation to your personal data processed by EscrowPay:

• Right of AccessTo request access to the personal data we hold about you and obtain information regarding how such data is processed.
• Right to CorrectionTo request the correction of any personal data that is inaccurate, incomplete, or outdated.
• Right to DeletionTo request the deletion of your personal data, subject to any legal, regulatory, contractual, or operational obligations requiring retention.
• Right to Restriction of ProcessingTo request that we restrict the processing of your personal data in certain circumstances permitted by law.
• Right to Data PortabilityTo request that your personal data be provided to you, or transferred to another data controller, in a structured, commonly used, and machine-readable format where technically feasible.
• Right to ObjectTo object to the processing of your personal data where such processing is based on legitimate interests or is otherwise permitted by applicable law.
• Right to Withdraw ConsentWhere processing is based on your consent, to withdraw such consent at any time, without affecting the lawfulness of processing carried out prior to such withdrawal.
• Right to Lodge a ComplaintTo lodge a complaint with the Nigeria Data Protection Commission (NDPC) where you believe your personal data has been processed in breach of applicable data protection laws.

To exercise any of your rights, contact EscrowPay at:

EscrowPay may require verification of your identity before processing any request relating to your personal data.

If you believe your data has been handled improperly, you may contact us. You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

We may update this Privacy Policy from time to time. Updates will be posted on the Platform with a revised effective date. Continued use of EscrowPay constitutes acceptance of any updates.

For questions regarding this Privacy Policy or your personal data, contact: