AltPay Privacy Policy

Welcome to AltPay.

This privacy policy ("Policy") applies to the AltPay mobile application(s) (hereinafter referred to as "AltPay") provided by The Alternative Bank Limited ("AltBank", "we", "us", "our"), and other products/services of The Alternative Bank. This Policy discloses our data protection practices on our Sites, products and subscriber-based services ("Services"), inclusive of the type of personal data that we collect, our method of collection of personal data, use of personal data and procedures for sharing personal data with third parties.

We are committed to protecting your personal data (i.e. any information you provide to us through which you can be identified) in accordance with the provisions of the Nigeria Data Protection Act 2023 and other applicable data protection laws ("Data Protection Laws").

By using AltPay, you agree to the terms of this Privacy Policy.

In compliance with the provisions of Data Protection Laws, we process your personal data in line with the following legal basis:

Consent: where you have consented to our processing of your personal data for one or more specific reasons. Such consent is given by you through your continuous use of the Services and the Sites.
Performance of a contract: in order to perform a contract we have with you or a contract to which you are a party to and to take necessary steps at your request prior to entering into such a contract.
Legal obligation: where processing of personal data is required by law. We are required by law to retain certain account opening information and personal data of our customers beyond the date such customers cease to carry on business with us.
Legitimate interest: to protect legitimate interests of data subjects, and in order to carry out the purposes of our business, such as account opening, and processing financial transactions. In addition to this, we have a legitimate interest to prevent fraud, money laundering and to verify identity of data subjects, to protect our customers and business, to understand how people interact with our Sites, to provide communication which we think will be of interest to you and to determine the effectiveness of promotional campaigns and advertising.
Vital interest: to process data for data subjects when they are in critical life- threatening situations where they may not be able to provide consent for data processing, and which may be vital for the subject's survival.
Public interest: such processing is necessary for the performance of a task carried out in the interest of the public on in exercise of an official public mandate vested on us.

1. Information We May Collect From You

When you use AltPay, we collect the following types of information:

a. Information You Provide

Account Information: Full name, phone number, email address, and linked ATM card details.
Identity Verification: Government-issued ID, date of birth, and other documents as required by law (e.g., for Know-Your-Customer (KYC) compliance).
Merchant Profile Information: Business name, address, business type, and regulatory documents (for merchants).
Communication Information: Any correspondence between you and AltBank (e.g., customer support).

b. Information Collected Automatically

Transaction Information: Details about your P2M and P2P transactions including amount, date, time, recipient information, and payment method.
Device Information: Device model, operating system, app version, device identifier (e.g., IMEI, IP address).
Geolocation Information: Your approximate or precise location, collected when you use location-based features (e.g., merchant proximity services).

c. Information from Third Parties

Financial Institutions: To validate your ATM card details and transaction information.
Public Databases and Identity Verification Services: For compliance and fraud prevention purposes

Our primary goal in collecting the above stated personal data is to provide you with a safe, efficient, smooth and customised experience. This allows us to provide services and features that most likely meet your needs.

2. How We Use Your Information

We use your information to:

Create and manage your AltPay account.
Facilitate and process payments.
Provide you with location-based merchant services and rewards.
Offer customer support and respond to your inquiries.
To resolve disputes and troubleshoot problems.
To improve our services by implementing aggregate customer preferences.
To manage and protect our information technology infrastructure.
To monitor traffic patterns and usage of the Sites to help to improve the Sites design and layout.
Personalise your AltPay experience (e.g., show merchants near you).
Verify your identity and fulfill legal obligations (e.g., Anti-Money Laundering (AML) regulations).
Send service-related updates and marketing communications.
Detect, prevent, and investigate fraud, unauthorized activities, and security breaches.
To send you important information regarding the services and/or other technical notices, updates, security alerts, support and administrative messages.
To poll your opinions through surveys or questionnaires.

4. Your Choices and Rights

Your personal data is protected by legal rights enshrined in Data Protection Laws. These rights include the following:

Right to be informed i.e. confirmation as to whether the data controller or a data processor operating on its behalf, is storing or otherwise processing personal data relating to the data subject;
Right to request a copy of data subject's personal data in a commonly used electronic format, except to the extent that providing such data would impose unreasonable costs on the data controller, in which case the data subject may be required by the controller to bear some or all of the costs;
Right to have correction or, if correction is not feasible or suitable, deletion of the data subject's personal data that is inaccurate, out of date, incomplete, or misleading;
Right for erasure of personal data concerning the data subject, without undue delay;
Right to withdraw, at any time, consent to the processing of personal data under the Nigeria Data Protection Act 2023;
Right to object to the processing of personal data concerning the data subject;
Right to object to any decisions based on the automated processing of your personal data, including profiling;
Right to data portability;
Right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

Please note that if you request for a copy of your personal data, you may be required to pay a fee if the requests are considered manifestly unfounded or excessive.

If you would like to exercise any of the above stated rights, please follow the following procedures:

put your request in writing and send it to us through your usual registered channel (e.g. by registered email) and specify the right you wish to exercise.

5. Data Security

In order to protect your personal data, we have put in place appropriate organisational and technical security measures. We implement technical and organizational security measures to protect your information, including:

End-to-end encryption for transactions.
Secure storage of personal and financial data.
Access controls and regular security audits.

Where you have a password which grants you access to specific areas on our site or to any of our services, you are responsible for keeping this password confidential. We request that you do not share your password or other authentication details (e.g. token generated codes) with anyone. As a user of AltPay, you understand and agree that you assume all responsibility and risk attached to safeguarding your account with us. You shall at no time whatsoever disclose your password to anyone, nor shall you allow anyone make use of your account.

Although we have taken measures to secure and keep your information confidential, because the security of your data is important to us, please be aware that no method of transmission over the Internet, or method of electronic storage can guarantee 100% security at all times. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security, you are responsible for securing and maintaining the privacy of your password and Account/profile registration information and verifying that the Personal Data we maintain about you is valid, accurate and up to date. If we receive instructions using your account login information, we will consider that you have authorized the instructions and process your instruction accordingly and without incurring any liability for doing so.

6. Privacy of Minors

AltPay is not intended for children under the age of 18. We do not knowingly collect names, email addresses, or any other personally identifiable information from children through the internet or any other touch points. We do not allow children under the age of 18 to open accounts nor provide online banking services for children less than 18 years of age without the consent of a guardian. If you are a parent or guardian and you are aware that your child has provided us with Personal Data without verification of parental consent, please promptly contact us.

7. Data Retention

We retain your personal information for as long as necessary to provide you with services, comply with legal obligations, resolve disputes, and enforce our agreements. We will not retain your personal data for longer than is necessary for the purposes for which such personal data is processed. This means that your personal data will only be retained for as long as it is still required to provide you with the Services or is necessary for legal reasons. When calculating the appropriate retention period of your personal data we consider the nature and sensitivity of the personal data, the purposes for which we are processing such personal data, and any applicable statutory/regulatory retention periods. Using these criteria, we regularly review the personal data that we hold and the purposes for which such is held and processed.

8. Updates to the Privacy Policy

We are constantly trying to improve our application and services, so we may need to change this Policy from time to time as well. We will alert you of material changes by, for example, placing a notice on the AltPay app and/or by sending you an email (if you have registered your e-mail details with us) when we are required to do so by applicable law. We reserve the right to update this Policy as we deem fit, from time to time, without any intimation to you and your continued use of AltPay will signify your acceptance of any amendment to these terms. It is your responsibility to check this Privacy Policy from time to time to verify such updates. Your continued use of AltPay after changes indicates your acceptance of the updated policy.

AltPay Privacy Policy