Transferxo Privacy Policy

TransferXO empowers Africa by providing individuals a user-friendly platform to learn, transact, and invest.

Privacy

Transferxo is committed to protecting the privacy of its visitors. This Privacy Policy provides our visitors with an overview of the measures we have taken to how our commitment to this policy. It describes how Transferxo collects, uses, stores, shares, and protects your information whenever you use Transferxo.io (the "Transferxo site").

User Information

When you use Transferxo, we collect information sent to us through your computer, mobile phone, or other access devices. This includes personal data that you volunteer on forms that you submit to us and in emails that you send to us. In addition, we automatically gather details of browser types and IP addresses of the users who visit our site and face data strictly for identity verification and store it for up to 7 years. Also, we collect leads contact details from data privacy compliant telemarketing firms and independent contractors. We do not release this information to any outside party, except in suspected fraud cases.

Lawful Basis of Processing

Transferxo processes personally identifiable information under the following lawful basis:

Contractual
Consent based
Legitimate Interest
Legal obligation

If you create an account or use Transferxo Services, we may collect the following types of information:

Contact information - your name, phone number, email address, date of birth and other similar information; and
Financial information - your full bank account and/or debit card details that you input when you use Transferxo.

If you do not use Transferxo Services, you may opt-out of providing this information. When you use Transferxo, we collect information about your transactions and/or your other activities on our website and we may continuously collect information about your computer, mobile device, or other access devices for fraud prevention purposes, to monitor for possible breach of your Transferxo Account, and to identify any malicious software or other activity that may harm Transferxo or its users.

We use personal data for one or more of the following purposes:

To verify your identity in accordance with Know Your Customer (KYC), Anti-Money Laundering (AML), and sanctions screening requirements;
To manage and maintain your account with us;
To prevent fraudulent or unauthorised use of our products and services;
To better manage our business and your relationship with us;
To improve our products and services, and to develop new products and services;
To notify you about benefits and changes to the features of our products and services;
To provide you with personalized advertising and marketing;
To respond to your enquiries and to resolve disputes.

Where necessary to protect our legal rights and interest, or the interests of others, we also use personal data in relation to legal claims, compliance, audit, risk management and regulatory functions. We may also use personal data in connection with the acquisition, merger or sale of a business.

You may choose to provide us with access to certain personal information stored by third parties such as social media sites (such as Facebook and Twitter). The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. By associating an account managed by a third party with your Transferxo account and authorizing Transferxo to have access to this information, you agree that Transferxo may collect, store, and use this information in accordance with this Privacy Policy. Finally, we may collect additional information you may disclose to our customer support team.

Facial Images (Face Data) and Biometric Information

Facial Images and Biometric Information

As part of our Know Your Customer (KYC) identity verification process, TransferXO, through the TransferXO application, collects facial images ("face data") from users. During verification, users are required to capture a live image of their face and complete a facial liveness check by performing simple actions, such as looking at the camera and smiling, to confirm that they are physically present.

What Facial Images We Collect

We collect:

Live facial images captured during the identity verification process.
Facial images used for facial liveness detection.
Facial images used to compare the user's live image with the government-issued identity document submitted during KYC verification.

We do not collect or use face data for facial recognition across unrelated services, advertising, behavioural profiling, analytics, or marketing purposes.

How We Use Facial Images

Facial images are collected and processed solely for the following purposes:

To perform facial liveness detection and confirm that the person completing verification is physically present.
To verify the identity of users by comparing their live facial image with the identity document submitted during KYC.
To detect and prevent identity theft, impersonation, fraud, account takeover, and other fraudulent activities.
To comply with applicable Know Your Customer (KYC), Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and other legal and regulatory obligations.

Facial images are not used for any purpose unrelated to identity verification and regulatory compliance.

Sharing of Facial Images

Face data may be shared only with our trusted identity verification service provider, solely for the purpose of conducting identity verification and facial liveness checks on our behalf. Our service provider processes face data under contractual obligations requiring appropriate technical and organisational safeguards and may not use the information for any purpose other than providing identity verification services to TransferXO. We do not sell, rent, or disclose face data to advertisers, marketing companies, or other unrelated third parties.

Storage and Security of Facial Images

Facial Images are securely stored by TransferXO and/or our authorised identity verification service providers using industry-standard security measures, including encryption, access controls, and secure transmission protocols. Access to face data is limited to authorised personnel and service providers who require access to perform identity verification and fulfil legal and regulatory obligations.

Retention of Face Data

Face data is retained for a minimum of seven (7) years following the termination of the customer relationship, or for such longer period as may be required by applicable laws, regulations, legal proceedings, or regulatory investigations. Upon expiry of the applicable retention period, face data will be securely deleted or irreversibly anonymised in accordance with our Data Retention and Secure Disposal Policy.

Policy Statement

This Privacy Notice applies to Transferxo contact us page (https://transferxo.com/). Personal data collected include your name, email address, phone number, photograph or image, Bank Verification Number (BVN) and face data strictly for identity verification, to pursue our legitimate interest in ensuring security, providing our services to you and to fulfil our regulatory obligations. Your personal data may be lawfully disclosed to authorized third parties (such as law enforcement, regulatory bodies, or internal investigators) where necessary for security, legal, or compliance investigations. Personal data collected through this sign-up page will be retained for 7 years post relationship termination and may be archived securely beyond this period only when required for an ongoing or anticipated investigation, legal claim, or regulatory audit. Appropriate organizational and technical safeguards will be implemented to ensure the confidentiality and restricted access to Personal data. We do not carry out automated decision making or profiling. You can exercise all data subject rights except the right to object processing, and right to erasure to enable us to fulfil our regulatory obligations. By creating an account with Transferxo you consent to the processing of your personal data in line with this privacy notice and our privacy policy.

Cookie Policy

What Are Cookies

As is common practice with almost all professional websites this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This section describes what information they gather, how we use it and why we sometimes need to store these cookies.

How We Use Cookies

We intend to use cookies for a variety of reasons detailed below: We use cookies to collect data that helps us to:

track site usage and browsing and app behaviour;
allow you to sign in to your account and navigate through the website;
tailor our website's functionality to you personally by letting us remember your preferences;
improve how our website performs;
allow third parties to provide services to our website;
monitor the effectiveness of our promotions and advertising; and
mitigate risk, enhance security and help prevent fraud.

We shall encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of Transferxo Services. Disabling cookies will usually result in also disabling certain functionality and features of the this site. The help section of most browsers or browser add-ons provides instructions on blocking, deleting, or disabling cookies.

Third Party Cookies

In some special cases we also use cookies provided by trusted third parties. This section details which third party cookies you might encounter through this site. We use Google Analytics, which is one of the most widespread and trusted analytics solution on the web, to help us understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.

As we may eventually sell products it's important for us to understand statistics about how many of the visitors to our site actually make a purchase and as such this is the kind of data that certain cookies will track. This is important to you as it means that we can accurately make business predictions that allow us to monitor our advertising and product costs to ensure the best possible price. We intend to use several partners to advertise on our behalf and affiliate tracking cookies will simply allow us to see if our customers have come to the site through one of our partner sites so that we can credit them appropriately and where applicable allow our affiliate partners to provide any bonus that they may provide you for making a purchase. More Information If there is something you aren't sure you need or not, it's usually safer to leave cookies enabled in case it does interact with one of the features you use on our site. However, if you still need more information, please contact us.

Personal Information

Throughout this policy, we use the term personal information to describe information that can be associated with a specific person and can be used to identify that person. This Privacy Policy does not apply to personal information that has been anonymised so that it does not and cannot be used to identify a specific user. Transferxo takes reasonable precautions, as described herein, to protect your personal information from loss, misuse, unauthorised access, disclosure, alteration, and destruction. Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customised experience.

We may use your personal information to:

Provide Transferxo Services and customer support you request;
Process transactions and send notices about your transactions;
Resolve disputes, collect fees, and troubleshoot problems;
Prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms;
Customise, measure, and improve Transferxo Services and the content and layout of our website and applications;
Deliver targeted marketing, service update notices, and promotional offers based on your communication preferences; and
Verify your identity by comparing your personal information against third-party databases.

We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time, we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or from allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain features or Transferxo Services may not be available to you.

We store and process your personal and transactional information, including certain payment information, where Transferxo facilities or our service providers are located, and we protect it by maintaining physical, electronic, and procedural safeguards in compliance with applicable laws. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfil their job responsibilities. Full credit card data is securely transferred and hosted off-site by a payment vendor in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to Transferxo staff.

We store our customers' personal information securely throughout the life of the customer's Transferxo Account. Transferxo will retain your personal information for a minimum of five years or as necessary to comply with our legal obligations or to resolve disputes.