Privacy Policy

Effective Date: June 23, 2026 | Version v1.1

Jadegate Tech Limited ("Jadegate", "we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and safeguard your information when you use our mobile application, website, wallet, payment, marketplace, notification, support, and related services.

1. Information We Collect

Account and Profile Information

We collect information that you provide when you register, use our services, or interact with us. This may include:

• First name, last name, username, email address, and phone number
• Gender, profile picture, and other profile details you choose to provide
• Password, transaction PIN, reset activity, and authentication status, stored in protected form where applicable
• Terms and Privacy Policy acceptance records, including version, timestamp, IP address, and user agent where recorded

Identity, KYC, and Compliance Information

• Bank Verification Number (BVN)
• National Identification Number (NIN)
• Liveness verification results, provider references, and session status
• Proof of address details, including state, LGA, city, street, document type, and uploaded documents where required
• Government-issued or identity documents submitted for verification
• KYC status, account tier, verification history, rejection reasons, and re-verification flags
• Sanitized identity provider metadata, audit records, and compliance review notes

Wallet, Payment, Conversion, and Bill Information

• Wallet balance, dedicated virtual account details, payment references, and deposit metadata
• Transaction details, ledger entries, conversion requests, exchange rates, and payment status
• Alipay contacts, Chinese bank recipient names, bank names, and encrypted or masked bank card details where applicable
• Saved beneficiaries, including Alipay or Chinese bank recipient information
• Bill payment details such as phone number, meter number, smartcard or customer ID, service ID, variation ID, amount, order IDs, tokens, and provider responses

Marketplace, Chat, and Support Information

• China agent request details, item descriptions, notes, quotes, images, status, and agent assignment information
• Support or marketplace chat messages, read receipts, image attachments, file metadata, and conversation status
• Customer support messages, email correspondence, complaint details, dispute records, and account deletion requests

Device, Notification, and Usage Information

We may automatically collect certain technical and usage information when you use our Platform, including:

• IP Address
• Device information, device ID, platform, operating system, app version, browser type, and user agent
• Push notification tokens and notification preference settings
• Login, logout, refresh token, session, security, and account activity records
• App usage data, interactions, pages visited, and time spent

2. How We Use Your Information

We use your information for the following purposes:

To Provide and Improve Our Services

• To create, secure, and manage your account
• To verify your email, process password resets, manage transaction PINs, and enforce sessions
• To set up and operate wallets, dedicated virtual accounts, deposits, balance checks, and transaction histories
• To process currency conversions (NGN to RMB), beneficiaries, Alipay and Chinese bank receiving details
• To facilitate bill payments, including airtime, data, electricity, TV subscriptions, and provider status checks
• To enable access to our China marketplace service, including sourcing goods, procurement assistance, and agent communication
• To provide support chat, image attachments, notifications, and customer service
• To improve user experience and platform performance

For Security and Compliance

• To verify your identity through KYC processes, including BVN, NIN, address, documents, and liveness checks
• To prevent fraud, unauthorized access, and illegal activities
• To apply account tiers, transaction limits, fraud controls, reconciliation, and risk reviews
• To comply with legal, regulatory, AML (Anti-Money Laundering), and KYC requirements
• To investigate security events, disputes, chargebacks, failed payments, refunds, and suspicious activity

For Communication

• To send important updates, alerts, and transaction notifications
• To send KYC, security, chat, account, policy, and service messages
• To provide customer support
• To send promotional messages where permitted and subject to your choices

3. How We Share Your Information

We do not sell or rent your personal information. However, we may share your information where needed to operate the Platform, comply with law, protect users, or deliver a service you requested.

Service Providers

We may share your data with trusted third-party providers, including:

• Payment processors and virtual account providers, including Flutterwave or similar partners
• KYC and identity verification providers, including Prembly or similar partners
• Bill payment and VTU providers
• Cloud hosting, database, file storage, and image storage providers, including Cloudinary or similar providers
• Email, OTP, push notification, SMS, analytics, logging, and communication service providers

These parties are contractually obligated to protect your data.

China Marketplace Agents and Partners

To facilitate our China marketplace services, we may share relevant information (such as product requests, images, contact details, chat content, quote details, and transaction-related data) with verified agents, admins, suppliers, or partners assisting in sourcing, procurement, manufacturing, support, or logistics.

Legal and Regulatory Authorities

We may disclose your information:

• When required by law
• To comply with regulatory obligations
• To protect our rights, users, or platform
• To investigate suspected fraud, money laundering, security incidents, sanctions issues, or other unlawful activity

Business Transfers

In the event of a merger, acquisition, or sale, your data may be transferred as part of the business assets.

4. How We Protect Your Information

We implement security measures designed to protect your data:

• Protected credentials: Passwords, transaction PINs, and refresh tokens are stored in protected hashed form
• Sensitive identifiers: BVN, NIN, and bank card details are hashed, encrypted, masked, or minimized where appropriate for the relevant workflow
• Access control: Only authorized personnel and service providers can access information needed for their role
• Monitoring and audits: We maintain audit logs, security events, rate limits, reconciliation checks, and fraud controls
• Secure infrastructure: We use trusted cloud, storage, database, and payment infrastructure providers

No method of transmission or storage is completely secure. You are responsible for keeping your password, OTP, transaction PIN, device, and email account secure.

5. Your Rights and Choices

You have the following rights:

Access and Update

You can review and update your information through your account settings.

Data Portability

You may request a copy of your data in a structured format.

Data Deletion

You can request account and data deletion through the Jadegate app or by following the process on our Delete Account page.

We may retain certain information where required for legal, AML, tax, accounting, fraud prevention, dispute resolution, payment settlement, security, or regulatory purposes.

Notification and Marketing Choices

You may opt out of marketing messages and certain push notification categories where available in the app. Transaction, account, security, and legally required service messages may remain enabled because they are necessary to operate and protect your account.

6. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Improve functionality
• Analyze usage
• Enhance user experience

You can control cookies through your device or browser settings.

7. Data Retention and Account Deletion

We keep personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law, regulation, payment partner rules, AML obligations, fraud prevention, tax, accounting, dispute resolution, or security requirements.

If you request account deletion and the request is accepted, Jadegate may schedule deletion after a grace period. During this period, you may be able to cancel deletion. Final deletion may be blocked if you still have wallet funds, pending transactions, pending conversions, processing bill payments, open disputes, or compliance obligations.

After final account deletion, we may delete your user profile and wallet records, anonymize or archive KYC records, and retain transaction, ledger, bill payment, conversion, audit, security, marketplace, support, notification, and compliance records where required or reasonably necessary. Financial and compliance records may be retained for up to 5 years or any longer period required by applicable law or regulators.

8. International and Third-Party Processing

Some service providers, payment partners, identity verification providers, cloud providers, agents, or support partners may process information outside your state or country. Where this occurs, we take steps designed to ensure that your information remains protected according to this Privacy Policy and applicable law.

9. Children's Privacy

Jadegate services are not intended for individuals under 18 years of age. We do not knowingly collect data from minors.

10. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Updates will be posted within the app or website, and the effective date or version will be revised accordingly. Where required, you may be prompted to accept the updated Privacy Policy before continuing to use the Platform.

11. Contact Us

If you have any questions or concerns:

12. Governing Law

This Privacy Policy shall be governed by and interpreted in accordance with the laws of the Federal Republic of Nigeria.