Effective Date: 1 January 2025
Last Updated: 1 April 2025
Version: 2.1
This Privacy Policy describes how QuickX Financial Services Ltd. ("QuickX", "we", "us", or "our"), a company registered in Nigeria at 12 Allen Way, Lagos, collects, uses, discloses, and safeguards your personal information when you use our website, mobile application, and currency exchange services (collectively, the "Platform").
By using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the terms described here, please do not use our services.
1. Information We Collect
1.1 Information You Provide Directly
When you register for an account or use our services, we collect information you voluntarily provide, including:
- Full legal name, date of birth, and nationality
- Email address, phone number, and residential address
- Government-issued identification documents (e.g., national ID, passport, driver's licence)
- Bank account details, wallet addresses, and payment information
- Business registration details (for business accounts)
- Communications you send to us, including support requests
1.2 Information Collected Automatically
When you access or use the Platform, we automatically collect certain technical information, including:
- IP address, browser type, device type, and operating system
- Pages visited, time spent, and features used
- Transaction data including amounts, currencies, timestamps, and recipient details
- Log data and error reports
- Cookies and similar tracking technologies (see Section 8)
1.3 Information from Third Parties
We may receive information about you from third parties, including:
- Identity verification providers for KYC purposes
- Fraud detection and anti-money laundering service providers
- Financial institutions and payment networks involved in processing your transactions
- Sanctions screening databases and credit reference agencies
2. How We Use Your Information
We use the personal information we collect for the following purposes:
- Account creation and management: To create and manage your QuickX account, verify your identity, and maintain account security.
- Transaction processing: To execute currency exchanges, process payouts, and facilitate transfers to the accounts you specify.
- Regulatory compliance: To comply with applicable laws including AML/CFT regulations, KYC requirements, and CBN guidelines.
- Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and security incidents.
- Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
- Service improvement: To analyse usage patterns, fix bugs, and improve the functionality of our Platform.
- Communications: To send transaction confirmations, security alerts, and — where you have consented — promotional materials about our services.
- Legal obligations: To comply with court orders, regulatory requests, and other legal obligations.
3. Legal Basis for Processing
We process your personal data on the following legal grounds:
- Contract performance: Processing necessary to provide you with the services you have requested.
- Legal obligation: Processing required to comply with applicable financial regulations.
- Legitimate interests: Processing for fraud prevention, security, and service improvement, where these do not override your fundamental rights.
- Consent: For marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time.
4. How We Share Your Information
We do not sell your personal information. We may share your information with the following categories of recipients:
- Service providers: Third-party vendors who assist with identity verification, payment processing, fraud detection, cloud hosting, and customer support — bound by confidentiality agreements.
- Financial partners: Banks, payment networks, and liquidity providers necessary to complete your transactions.
- Regulatory authorities: Government agencies, law enforcement, and financial regulators where we are required to do so by law.
- Business transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. You will be notified in advance.
- With your consent: We may share information with third parties when you have given explicit consent to do so.
5. Data Retention
We retain your personal information for as long as necessary to provide our services and comply with legal obligations. Specifically:
- Transaction records are retained for a minimum of 5 years following the completion of a transaction, as required by Nigerian AML regulations.
- Account information is retained for the duration of your account relationship and for a period of 5 years after account closure.
- Identity verification documents are retained for 5 years or as otherwise required by applicable law.
- Communications and support records are retained for 2 years.
6. Your Rights
Subject to applicable law, you have the following rights regarding your personal information:
- Access: You may request a copy of the personal data we hold about you.
- Correction: You may request that we correct inaccurate or incomplete information.
- Deletion: You may request deletion of your personal data, subject to our legal retention obligations.
- Portability: You may request that we provide your data in a commonly used, machine-readable format.
- Objection: You may object to processing based on legitimate interests or for direct marketing purposes.
- Restriction: You may request that we restrict processing in certain circumstances.
- Withdrawal of consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us at privacy@quickx.ng or write to us at our registered address. We will respond within 30 days.
7. Data Security
We implement industry-standard technical and organisational measures to protect your personal information, including:
- AES-256 encryption for data at rest
- TLS 1.3 for all data in transit
- Multi-factor authentication requirements for all internal system access
- Continuous security monitoring and intrusion detection
- Annual third-party penetration testing and security audits
- Staff training on data protection and security practices
8. Cookies and Tracking Technologies
We use cookies and similar technologies to operate the Platform, remember your preferences, and analyse usage. The types of cookies we use include:
- Essential cookies: Required for the Platform to function. These cannot be disabled.
- Functional cookies: Remember your preferences and settings to improve your experience.
- Analytics cookies: Help us understand how visitors interact with the Platform (e.g., Google Analytics).
- Marketing cookies: Used to deliver relevant advertisements. Only set with your consent.
9. International Data Transfers
QuickX operates primarily in Nigeria. However, some of our service providers and partners are located in other countries, which means your personal data may be transferred to and processed in countries outside Nigeria. Where such transfers occur, we ensure appropriate safeguards are in place, such as standard contractual clauses, to protect your data in accordance with applicable privacy laws.
10. Children's Privacy
Our services are not directed at individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a minor, please contact us immediately and we will take steps to delete such information.
11. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our Platform and, where appropriate, by sending you an email notification at least 14 days before the changes take effect.
12. Contact Us
If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact our Data Protection Officer:
- Email: privacy@quickx.ng
- Post: Data Protection Officer, QuickX Financial Services Ltd., 12 Allen Way, Lagos, Nigeria
- Phone: +234 123 456 7890