Privacy Policy

Betaling Africa ("Betaling", "we", "our", or "us") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, disclose, transfer, retain, and otherwise process your personal information when you access or use our websites, mobile applications, APIs, digital platforms, payment infrastructure, Treasury Network, OTC Desk, Wallet services, customer support channels, and any other products or services we provide (collectively, the "Services").

This Privacy Policy also explains:

the categories of personal information we collect;
the legal bases on which we process your information;
how we share your information;
how we protect your information;
how long we retain your information;
your privacy rights; and
how you may contact us regarding your personal information.

Please read this Privacy Policy together with our Terms of Service, Cookie Policy, and any product-specific privacy notices that may apply to particular Services. By accessing or using the Services, you acknowledge that your personal information will be processed in accordance with this Privacy Policy.

Because Betaling provides regulated payment, wallet, treasury, and foreign exchange services, certain processing activities are required by applicable law, including laws relating to anti-money laundering (AML), counter-terrorist financing (CTF), sanctions compliance, fraud prevention, financial crime prevention, tax reporting, payment regulations, and other legal and regulatory obligations. Where processing is required by law, your consent may not be required.

1. Who we are

Betaling Africa operates through the following legal entities:

Betaling Africa Tech Limited — a company duly incorporated under the laws of the Federal Republic of Nigeria (RC 1885537); and
Betaling Africa Inc — a company incorporated under the laws of Delaware, United States of America, with registered office at 8 The Green, Ste A, Dover, DE 19901.

Depending on your country of residence, the Service you use, applicable regulatory requirements, and our operational structure, one or more Betaling entities may act as the Data Controller (or equivalent legal concept under applicable privacy laws) responsible for processing your personal information. References in this Privacy Policy to "Betaling," "we," "our," or "us" refer to the relevant Betaling entity acting as the controller of your personal information.

Where Betaling processes personal information solely on behalf of another organisation, Betaling acts as a Data Processor in accordance with applicable law. If you are uncertain which Betaling entity processes your information, you may contact us using the contact details provided in Section 11.

2. Scope of this Privacy Policy

This Privacy Policy applies to all individuals whose personal information is processed in connection with the Services, including individual customers; business customers; merchants; institutional clients; Treasury Network and OTC Desk participants; company directors; shareholders; Ultimate Beneficial Owners (UBOs); authorised signatories; employees authorised to operate business accounts; payment beneficiaries; suppliers; payers; website visitors; mobile application users; prospective customers; individuals making enquiries; job applicants (where applicable); and any other individuals whose personal information is provided to Betaling.

It applies to all Services provided by Betaling — including cross-border payments, local payments, wallet services, multi-currency wallets, the Treasury Network, the OTC Desk, foreign exchange services, APIs, merchant services, corporate treasury solutions, customer support, websites, and mobile applications — and to any future products or services unless a separate privacy notice applies. This Privacy Policy does not apply to third-party websites or services that may be linked through our platform.

3. Information we collect

The categories of personal information we collect depend upon the Services you use, your relationship with Betaling, applicable legal requirements, and the information you choose to provide.

3.1 Identification information

Full name; previous names; date of birth; nationality; gender (where required); government-issued identification numbers; passport information; driver's licence information; National Identity Number (NIN); Bank Verification Number (BVN); Tax Identification Number (TIN); Social Security Number (where applicable); photographs; biometric verification data (where legally permitted); and signatures.

3.2 Contact information

Residential address; business address; postal address; email address; telephone numbers; and emergency contact information (where applicable).

3.3 Business information

For business and institutional customers: company name; registration number; tax registration details; regulatory licences; constitutional documents; ownership structure; shareholder, director, Ultimate Beneficial Owner, and authorised signatory information; business activities; source of funds; expected transaction volumes; financial statements (where required); and other corporate due diligence documentation.

3.4 Financial information

Bank account information; wallet information; payment card information (processed securely through approved providers); account balances; transaction history; foreign exchange transactions; payment instructions; beneficiary and supplier information; and settlement records.

3.5 Compliance information

Information relating to KYC and KYB checks; AML and CTF requirements; sanctions screening; Politically Exposed Person (PEP) status; adverse media searches; fraud prevention checks; enhanced due diligence; source of wealth and source of funds; regulatory investigations; and suspicious transaction monitoring.

3.6 Technical information

IP address; browser type; operating system; device identifiers; mobile device information; language settings; time zone; network information; application version; crash reports; session information; and authentication logs.

3.7 Usage information

Pages viewed; Services accessed; features used; clicks; searches; navigation behaviour; login history; transaction frequency; communication preferences; and customer support interactions.

3.8 Communications

Records of communications between you and Betaling, including emails, live chats, telephone calls (which may be recorded where permitted by law), customer support tickets, surveys, complaints, feedback, and correspondence.

3.9 Information from third parties

We may obtain information from banks; payment processors; identity verification providers; sanctions screening providers; fraud prevention agencies; regulators; law enforcement agencies; public registers; credit reference agencies (where applicable); business information providers; data analytics providers; and publicly available sources.

3.10 Cookies and similar technologies

We use cookies, pixels, web beacons, SDKs, and similar technologies to authenticate users, improve security, remember preferences, analyse website usage, measure performance, prevent fraud, and improve the functionality of the Services. Further information is available in our Cookie Policy.

3.11 Information you choose to provide

You may voluntarily provide additional information when completing forms, contacting customer support, participating in promotions, attending events, responding to surveys, applying for products, or communicating with Betaling. Please ensure that any personal information you provide is accurate, complete, and up to date.

Summary of the data we process

Category	Examples	Typically collected from
Identity and contact	Full name, date of birth, nationality, residential address, email address, phone number, photograph or selfie.	You, during registration and KYC
Government identifiers	Bank Verification Number (BVN), National Identification Number (NIN), passport, national ID, or driver's licence details, and tax identification number.	You, and verification partners
Verification media	Images of identity documents (front and back) and a selfie used for a liveness check to confirm you match your ID.	You, and verification partners
Business and KYB	Registered company name, registration number (for example CAC or CIPC), memorandum and articles of association, status report, proof of business address, board resolutions, nature of business, and details of directors and ultimate beneficial owners.	Business users and their representatives
Financial and transaction	Transaction amounts, source and destination currencies, exchange rates, fees, supplier and beneficiary details (including beneficiary name, address, bank details, and SWIFT/BIC), wallet balances, payment method, settlement account details, and transaction history.	You, and payment partners
Compliance	Source of funds and source of wealth information, expected transaction volume, counterparty types, countries involved, results of sanctions and politically exposed person (PEP) screening, and the risk category assigned to your account.	You, and screening partners
Supporting documents	Invoices, packing lists, and other documents you upload to support a transfer.	You
Institutional (Treasury Network)	Trading limits, authorised signatory details, user roles, order and quote data, and settlement instructions.	Institutional members
Technical and usage	Device information, IP address, browser type, log data, approximate location, and information collected through cookies and similar technologies.	Automatically
Communications	Records of your contact with our support team, including in-app chat, email, and messages, and your notification and marketing preferences.	You

We do not knowingly collect special category data (such as health or biometric data) beyond the facial image and liveness data used for identity verification, which we process only to confirm your identity and prevent fraud.

4. How we collect your information

4.1 Information you provide directly

We collect information directly from you when you create an Account; complete KYC or KYB verification; complete onboarding questionnaires; upload identification documents; provide business documentation; add payment methods; fund a Wallet; initiate or receive transactions; convert currencies; use the Treasury Network or OTC Desk; contact customer support; submit complaints; complete surveys; participate in promotions; attend events; communicate with us by telephone, email, chat, or other channels; or otherwise interact with our Services.

4.2 Information collected automatically

When you access or use the Services, we automatically collect certain technical and usage information using cookies and similar technologies, including device identifiers; IP address; browser information; operating system; device type; language preferences; authentication logs; session identifiers; pages visited; clickstream information; error logs; application performance data; security events; and fraud detection information. Further details are contained in our Cookie Policy.

4.3 Information from third parties

We may obtain personal information from trusted third-party sources, including identity verification and electronic KYC providers; banks; payment processors; correspondent banks; card networks; mobile money operators; credit reference agencies (where applicable); sanctions screening providers; anti-fraud databases; PEP databases; adverse media screening providers; public corporate registries; government agencies; regulatory authorities; law enforcement agencies; business information providers; analytics providers; and publicly available sources. We collect such information only where legally permitted and for legitimate business, regulatory, or compliance purposes.

4.4 Information from other users

Where another user provides your details as part of a transaction (for example, as a beneficiary, supplier, authorised signatory, or company director), we may collect and process that information to provide the requested Services or comply with applicable legal obligations.

5. How we use your information and our legal bases for processing

Betaling processes personal information only where there is an appropriate legal basis under applicable data protection laws, including the Nigeria Data Protection Act (NDPA), the EU General Data Protection Regulation (GDPR), the UK GDPR, and other applicable privacy laws. Depending on the circumstances, we rely on one or more of the following legal bases: your consent; performance of a contract with you; compliance with a legal obligation; protection of your vital interests or those of another person; performance of a task carried out in the public interest (where applicable); or Betaling's legitimate business interests, provided those interests are not overridden by your fundamental rights and freedoms.

Purpose	What this involves	Legal basis
Providing the Services	Creating and managing your account, processing transfers, locking exchange rates, settling funds, and operating wallets and the Treasury Network.	Performance of a contract
Identity and business verification	Carrying out KYC and KYB checks, including BVN/NIN lookups, document verification, and liveness checks.	Legal obligation; performance of a contract
Anti-money laundering and sanctions	Screening users and transactions against sanctions, PEP, and watchlists, monitoring for unusual activity, and reporting where required.	Legal obligation
Fraud prevention and security	Detecting, investigating, and preventing fraud, unauthorised access, and other unlawful activity, and securing our systems.	Legitimate interests; legal obligation
Communications and support	Responding to enquiries, sending transaction and service notifications, and providing customer support.	Performance of a contract; legitimate interests
Marketing	Sending you updates, offers, and product information where you have opted in.	Consent
Improving the Services	Analysing usage to maintain, improve, and develop our products.	Legitimate interests; consent where required for cookies
Legal and regulatory	Complying with applicable laws, responding to lawful requests, and establishing or defending legal claims.	Legal obligation; legitimate interests

6. Compliance, monitoring, and automated decision-making

As a regulated provider of payment, wallet, treasury, and foreign exchange services, Betaling is required to implement robust compliance, fraud prevention, anti-money laundering (AML), counter-terrorist financing (CTF), sanctions compliance, anti-bribery, anti-corruption, and financial crime prevention measures in accordance with applicable laws and regulatory requirements.

To fulfil these obligations, we monitor Accounts, transactions, and user activity on an ongoing basis and may process your personal information to:

verify and authenticate your identity and Account;
perform KYC, KYB, Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD) checks;
verify Ultimate Beneficial Owners (UBOs), directors, authorised representatives, and signatories;
conduct sanctions screening against applicable domestic and international sanctions lists;
identify Politically Exposed Persons (PEPs), their family members, and close associates;
conduct adverse media and reputational screening;
assess customer risk profiles;
monitor transactions for suspicious, unusual, or potentially unlawful activity;
detect and prevent fraud, identity theft, account takeover, cybercrime, money laundering, terrorist financing, tax evasion, and other financial crimes;
comply with court orders, regulatory directives, and legal obligations;
investigate complaints, disputes, and suspected policy violations;
protect the integrity, security, and reliability of the Services; and
maintain accurate audit trails for regulatory, legal, and operational purposes.

These activities may continue throughout your relationship with Betaling and, where required by law, after your Account has been closed.

6.1 Automated monitoring and fraud detection

Betaling uses automated technologies, artificial intelligence, machine learning models, behavioural analytics, fraud detection systems, and risk assessment tools to assist in protecting customers and complying with applicable laws. These systems may automatically screen transactions against sanctions, embargo, and watchlists; assign transaction and customer risk scores; identify unusual transaction patterns; detect potentially fraudulent or suspicious behaviour; analyse device fingerprints and login behaviour; monitor IP addresses, browser information, and device characteristics; identify duplicate or synthetic identities; monitor velocity limits and transaction frequency; identify potential account compromise; detect unusual changes in customer behaviour; categorise business customers according to their risk profile; identify transactions requiring enhanced due diligence; detect attempted circumvention of regulatory controls; and identify activity that may breach our Terms of Service or applicable law.

These automated tools are designed to assist — not replace — our compliance and risk management processes.

6.2 Human review

Where required by applicable law or where appropriate, significant decisions are reviewed by qualified members of our Compliance, Risk, Fraud, or Legal teams. For example:

Business Accounts undergo manual compliance review before activation.
High-risk transactions may require additional documentation before approval.
Enhanced Due Diligence reviews are conducted by compliance personnel.
Suspicious transaction reports are reviewed before submission to regulators where appropriate.
Decisions involving permanent account suspension or termination are subject to internal review.

Where legally permitted, you may contact us to request further information regarding decisions affecting your Account.

6.3 Consequences of compliance reviews

Compliance or fraud reviews may result in one or more of the following actions: requests for additional documentation or information; temporary delays in processing transactions; enhanced due diligence procedures; temporary account or wallet restrictions; refusal or cancellation of transactions; rejection of account registration; suspension of certain Services; freezing of funds where legally required; permanent account closure; reversal of transactions where legally permissible; or reporting to regulatory authorities, financial intelligence units, or law enforcement agencies where required or permitted by law.

6.4 Restricted disclosures

Applicable law may prohibit Betaling from disclosing the specific reasons why a transaction or Account has been delayed, restricted, frozen, reported, or declined. Where legally permitted, we will provide as much information as reasonably possible regarding the status of your transaction or Account. Nothing in this Privacy Policy requires Betaling to disclose confidential compliance methodologies, fraud detection systems, internal risk models, regulatory communications, or information whose disclosure may prejudice an investigation or violate applicable law.

7. Who we share your information with

Betaling treats all personal information as confidential and shares it only where necessary to provide the Services, comply with legal obligations, protect legitimate business interests, prevent fraud, or where you have authorised us to do so. All recipients are required to maintain appropriate technical, organisational, and contractual safeguards to protect your personal information.

7.1 Identity verification and compliance providers

Including providers that assist with identity verification; biometric verification; liveness detection; document authentication; address verification; sanctions and AML screening; fraud detection; adverse media searches; politically exposed person screening; beneficial ownership verification; and ongoing customer due diligence. Examples include Didit, YouVerify, ComplyAdvantage, and other equivalent compliance and identity verification providers.

7.2 Banking, payment, and settlement partners

To facilitate payments and settlements, we may share information with licensed banks; correspondent banks; acquiring institutions; payment processors and gateways; card networks; settlement providers; wallet infrastructure providers; liquidity providers; foreign exchange partners; virtual account providers; mobile money operators; and clearing and settlement systems. Examples include Paystack, Flutterwave, Anchor, Kora, Wema Bank, Providus Bank, MTN MoMo, Airtel Money, M-Pesa, and other regulated financial institutions involved in processing transactions.

7.3 Beneficiaries, counterparties, and financial institutions

Where necessary to complete transactions, we may disclose relevant information to beneficiaries; suppliers; receiving financial institutions; correspondent banks; settlement institutions; Treasury Network counterparties after trade matching; OTC counterparties; payment recipients; and other entities participating in the transaction. Only information reasonably necessary to process the transaction will be shared.

7.4 Technology and service providers

We engage trusted third-party providers for cloud hosting; cybersecurity; data storage; disaster recovery; software development; fraud prevention; identity verification; customer relationship management; communications; analytics; monitoring; logging; infrastructure; customer support; document management; email services; SMS messaging; and business continuity services. These providers process personal information solely on our documented instructions.

7.5 Professional advisers

Including auditors, accountants, lawyers, consultants, insurers, tax advisers, compliance advisers, and external investigators, who are subject to contractual or professional confidentiality obligations.

7.6 Regulators, government authorities, and law enforcement

Where required or permitted by law, we may disclose personal information to central banks; financial regulators; financial intelligence units; tax authorities; anti-corruption agencies; law enforcement authorities; courts; tribunals; arbitration panels; supervisory authorities; and other governmental bodies with lawful authority. Such authorities may include the Central Bank of Nigeria, the Nigerian Financial Intelligence Unit, the Nigeria Data Protection Commission, the South African Reserve Bank, the Capital Markets Authority of Kenya, and other competent authorities.

7.7 Corporate transactions

If Betaling undergoes a merger, acquisition, corporate restructuring, investment, financing, reorganisation, insolvency proceeding, or sale of assets, personal information may be transferred to the relevant parties, subject to appropriate confidentiality obligations and applicable data protection laws.

7.8 Protection of rights

We may disclose information where reasonably necessary to enforce our legal rights; protect the safety of customers; prevent fraud; investigate security incidents; protect Betaling's property; defend legal claims; or comply with judicial or regulatory proceedings.

7.9 No sale of personal information

Betaling does not sell, rent, or trade your personal information to third parties for their independent marketing purposes.

8. International transfers of personal information

Because Betaling operates internationally, your personal information may be transferred, stored, accessed, or processed outside your country of residence. Such transfers may occur between Betaling entities, banking partners, payment providers, cloud infrastructure providers, compliance partners, or other authorised service providers located in jurisdictions including Nigeria; the United States; the United Kingdom; member states of the European Economic Area; Canada; China; India; Turkey; the United Arab Emirates; Kenya; South Africa; and other jurisdictions where our partners operate. Data protection laws in those jurisdictions may differ from those applicable in your country.

Where required by applicable law, Betaling implements appropriate safeguards, including Standard Contractual Clauses (SCCs); International Data Transfer Agreements (IDTAs); adequacy decisions; contractual confidentiality obligations; encryption in transit and at rest; access controls; data minimisation principles; security assessments; and organisational safeguards. We continuously assess international transfers to ensure they remain lawful and appropriately protected. You may request further information regarding applicable safeguards by contacting us.

9. Data retention

Betaling retains personal information only for as long as necessary to provide the Services; fulfil contractual obligations; comply with applicable laws; satisfy regulatory requirements; resolve disputes; establish, exercise, or defend legal claims; prevent fraud; and protect the integrity of the financial system. Retention periods depend upon the type of information collected; the products or Services used; legal and regulatory obligations; contractual commitments; operational requirements; and legitimate business needs.

Unless a longer retention period is required by law, Betaling generally retains customer identification records; KYC and KYB documentation; transaction, payment, wallet, and foreign exchange records; communications and customer support correspondence; audit logs; device and security logs; sanctions screening records; fraud investigation files; compliance records; and regulatory reporting records for a minimum period of seven (7) years following the termination of the customer relationship or completion of the relevant transaction.

Where litigation, arbitration, investigations, audits, regulatory proceedings, or legal claims are pending or reasonably anticipated, we may retain information for a longer period until such matters have been fully resolved. Documents uploaded to support transactions or regulatory compliance generally cannot be deleted during the applicable retention period where retention is required by law.

At the end of the applicable retention period, Betaling will securely delete, anonymise, aggregate, or otherwise dispose of personal information using industry-standard technical and organisational measures, unless continued retention is required by applicable law or necessary for the establishment, exercise, or defence of legal claims.

10. Changes to this Privacy Policy

Betaling may amend, update, or revise this Privacy Policy from time to time to reflect changes in applicable laws, regulations, regulatory guidance, or industry standards; changes to our products, Services, technologies, or business operations; improvements to our security, compliance, or risk management processes; changes in how we collect, use, disclose, transfer, or retain personal information; or any other operational, legal, or commercial developments.

When we make material changes to this Privacy Policy, we will:

update the "Last updated" date appearing at the top of this page;
publish the revised Privacy Policy on our website and, where applicable, within our mobile applications;
provide notice by email, in-app notification, website banner, or any other reasonable communication method where required by applicable law; and
where legally required, obtain your consent before processing your personal information under materially different terms.

We encourage you to review this Privacy Policy periodically. Unless otherwise required by applicable law, any amendments become effective on the date specified in the updated Privacy Policy. Your continued access to or use of the Services after the effective date of an updated Privacy Policy constitutes your acknowledgement of the revised Privacy Policy. Where applicable law requires your express consent for certain changes, we will request such consent before those changes become effective. Nothing in this section limits any rights you may have under applicable data protection legislation.

11. Contact us

If you have any questions, concerns, complaints, or requests regarding this Privacy Policy, our privacy practices, or the manner in which we collect, use, disclose, transfer, or otherwise process your personal information, you may contact Betaling's privacy team at support@betaling-africa.com.

You may contact us to:

exercise your data protection rights;
request access to your personal information;
request correction or updating of inaccurate information;
request deletion of personal information where applicable;
object to or restrict certain processing activities;
withdraw consent where processing is based on consent;
request portability of your personal information where applicable;
report a suspected privacy or security incident;
make a complaint regarding our handling of your personal information; or
obtain additional information regarding our privacy practices.

Nigeria: Betaling Africa Tech Limited (RC 1885537)
United States: Betaling Africa Inc, 8 The Green, Ste A, Dover, DE 19901, United States

Complaints

If you believe that Betaling has not handled your personal information in accordance with applicable law, we encourage you to contact us first so that we may investigate and attempt to resolve your concerns promptly and fairly. Where applicable, you may also have the right to lodge a complaint with the relevant data protection authority, financial regulator, or supervisory authority in the jurisdiction where you reside or where the alleged infringement occurred. Nothing in this Privacy Policy limits your statutory rights to seek remedies from a competent regulatory authority, tribunal, or court where permitted by applicable law.

Response times

Betaling will endeavour to acknowledge privacy-related enquiries promptly and respond within the timeframes required under applicable data protection laws. Where your request is particularly complex or involves multiple requests, we may extend the response period where permitted by law; if this occurs, we will inform you of the reason for the extension and the expected response timeframe. For security purposes, we may request additional information to verify your identity before responding to certain requests or disclosing personal information.

Communications

Unless otherwise requested or required by law, communications relating to privacy matters may be sent electronically. You are responsible for ensuring that your contact details remain accurate and up to date so that we can communicate with you regarding your personal information, your privacy rights, and any material updates to this Privacy Policy.