Privacy Policy

BANJEE lets you hold Naira and USDC, send money, buy and sell USDC, and pay bills such as airtime, data, TV subscriptions, electricity and betting top-ups. You can use it through a WhatsApp chat and through the BANJEE Wallets web app. Both use the same account, and this policy covers both.

BANJEE TECHNOLOGIES LLP is responsible for your information. Our registered address is [registered address].

We collect information you give us, information created when you use BANJEE, and limited technical information from your device. We only collect what we need to run the service, keep accounts secure and meet our legal obligations.

• Account details: your phone number, full name, username and, if you add it, your email address.
• Your PIN. We never store the PIN itself — only a one-way hash that can check a PIN but can't be turned back into it.
• Bank details: account numbers, bank names and account names you save or send money to.
• Recipients: BANJEE usernames, phone numbers and wallet addresses you send USDC to, phone numbers you buy airtime or data for, and meter, smartcard and betting account numbers you pay bills for.
• Messages you send to BANJEE on WhatsApp, including instructions such as amounts and recipients.
• Identity information, if verification is required for your account or a feature: for example your BVN or NIN, date of birth and address. BVN and NIN are stored encrypted.
• Anything you tell our support team.

• Balances and a record of every credit and debit on your Naira balance.
• Bank transfers, including amount, recipient, status and references from our payment providers.
• USDC purchases, sales and transfers, including the rate and any fee applied.
• Bill payments — airtime, data, TV, electricity and betting — including the provider, the phone, meter, smartcard or account number, the name the provider holds for it, any token issued, and the amount.
• Your USDC wallet addresses and blockchain transactions linked to them.

Transactions on the Stellar and Celo networks are recorded on public blockchains. Anyone can see a public transaction and the addresses involved, and we can't remove or change that record.

• Your IP address and browser or device type when you log in, stored with your session so you can see and end sessions.
• A device identifier or name, if your device sends one.
• Records of logins, failed PIN attempts and security events.
• Service logs that help us find and fix errors.

• To create and run your account, and to log you in.
• To carry out the transactions you ask for, including checking the account name before a bank transfer.
• To understand the messages you send in WhatsApp. We use automated processing, including an AI language model provided by a third party, to work out what you're asking BANJEE to do. You always confirm a transaction before it happens.
• To protect accounts — for example, locking an account after repeated wrong PINs, ending sessions and investigating suspicious activity.
• To verify identity where required.
• To send you receipts, status updates and service messages.
• To answer support requests and resolve disputes.
• To meet legal, regulatory, tax and reporting obligations.
• To keep BANJEE working reliably and improve it.

Our legal bases for this processing are [lawful bases — to be confirmed by counsel].

We don't sell your information. We share it only where it's needed to run BANJEE or where the law requires it:

• With service providers who help us deliver BANJEE (see the next section).
• With the people you pay. A bank transfer's note, and details shown by the recipient's bank, can be seen by the recipient.
• With public blockchain networks, when you send or receive USDC.
• With regulators, law enforcement or courts, when we're legally required to.
• With a buyer or successor, if BANJEE's business is sold or restructured, under the same protections as this policy.

We work with providers in these categories and share only the information each one needs to provide its service. Some, such as WhatsApp, also process information under their own terms and privacy policies.

• Messaging: WhatsApp, operated by Meta, to deliver messages between you and BANJEE.
• Payments: payment processors and partner banks that issue funding accounts, verify account names and send bank transfers.
• Bills: providers that deliver airtime, data, TV subscriptions, electricity tokens and betting top-ups, and confirm the name on a meter, smartcard or betting account.
• Identity verification: providers that check identity numbers where verification is required.
• AI language processing: a provider that helps interpret the text of messages you send to BANJEE.
• Blockchain infrastructure: services that connect BANJEE to the Stellar and Celo networks.
• Hosting and infrastructure: providers that host our servers, databases and the web app.

A current list of named providers is available on request at [provider list location or contact].

We keep your information while your account is open. After it closes, we keep transaction and identity records for as long as the law requires, and other information only as long as we need it to resolve disputes or protect against fraud.

Retention periods: [retention periods by category — to be confirmed by counsel].

• PINs are stored as one-way hashes, and BVN and NIN are stored encrypted.
• Accounts lock temporarily after repeated wrong PINs.
• You can end every session from the web app, and changing your PIN ends all sessions.
• If a session token is used twice, we treat it as stolen and end that session.

No system is completely secure. Keep your PIN private and tell us immediately if you think someone else has used your account.

Depending on the law that applies to you, including the Nigeria Data Protection Act 2023 where it applies, you may have the right to:

• Ask for a copy of the information we hold about you.
• Ask us to correct information that's wrong.
• Ask us to delete information, where we're not required to keep it.
• Object to, or ask us to restrict, some processing.
• Receive your information in a portable format.
• Withdraw consent where we rely on it.
• Complain to the Nigeria Data Protection Commission or another relevant authority.

To make a request: Email banjeetechnologies@gmail.com, or message BANJEE support on WhatsApp. We may need to confirm your identity first.

The BANJEE Wallets web app doesn't use advertising or analytics cookies, and doesn't include third-party tracking.

It uses your browser's local storage to keep you logged in, remember your light or dark theme, and remember whether you've chosen to hide balances. If you install the web app, a service worker stores the app's own files so it can open quickly and show an offline screen. It doesn't store your balances or transactions.

You can clear this storage at any time in your browser settings. You'll need to log in again afterwards.

Some of our service providers process information outside Nigeria. When that happens, we use the safeguards required by law: [transfer safeguards — to be confirmed by counsel].

BANJEE is not for anyone under [minimum age]. We don't knowingly collect information from children. If you believe a child has an account, contact us and we'll close it.

We'll update this policy when our practices change. The date at the top shows when it last changed. For significant changes, we'll tell you in the app or on WhatsApp before they take effect.

Questions about privacy? Email banjeetechnologies@gmail.com, or message BANJEE support on WhatsApp. Our data protection contact is [data protection officer or contact].