Welcome to PayXchange, a digital payment platform owned and operated by Shiifa Limited ("Shiifa Limited", "PayXchange", "we", "our" or "us").
This Privacy Policy explains how Shiifa Limited collects, uses, stores, protects, shares and otherwise processes personal information when you access or use the PayXchange mobile application, website, application programming interfaces (APIs), customer support channels and any related products or services (collectively, the "Platform").
Your privacy is important to us. We are committed to handling your personal information responsibly, transparently and securely while complying with applicable Nigerian data protection laws and internationally recognized privacy principles.
This Privacy Policy applies to all individuals and organizations who interact with PayXchange, including but not limited to:
This Policy applies whenever personal information is collected through the Platform or in connection with the Services provided by PayXchange.
This Privacy Policy forms an integral part of the PayXchange Terms and Conditions.
By registering for, accessing or using PayXchange, you acknowledge that you have read and understood this Privacy Policy. Where you do not agree with the practices described in this Privacy Policy, you should discontinue use of the Platform.
PayXchange is a payment facilitation platform that enables Customers to make secure digital payments to Merchants without manually entering traditional bank account details.
To provide these Services, Shiifa Limited works with regulated financial institutions and licensed payment infrastructure partners.
Depending on the circumstances, Shiifa Limited may process personal information:
Shiifa Limited is committed to ensuring that personal information is processed:
Privacy protection is integrated into the design, development and operation of the PayXchange Platform.
Shiifa Limited intends to operate the PayXchange Platform in accordance with applicable data protection and privacy laws, including, where applicable:
Where legal requirements change, Shiifa Limited may update this Privacy Policy accordingly.
When processing personal information, Shiifa Limited aims to follow principles including:
These principles guide the manner in which personal information is collected, used and protected throughout the lifecycle of the PayXchange Services.
PayXchange is not intended for use by individuals who are legally incapable of entering into binding contracts under applicable Nigerian law.
Shiifa Limited does not knowingly collect personal information directly from children except where expressly permitted or required by applicable law.
Where Shiifa Limited becomes aware that personal information has been collected inappropriately from a child, reasonable steps may be taken to delete or otherwise handle such information in accordance with applicable law.
Shiifa Limited may revise or update this Privacy Policy from time to time to reflect:
Where material changes are made, Users may be notified through appropriate communication channels, including:
The revised Privacy Policy shall become effective on the date specified in the updated version.
By creating an Account, accessing or using the PayXchange Platform, you acknowledge and agree that:
c. You consent to the processing of your personal information where consent is the appropriate legal basis under applicable law;
d. You understand that certain information must be processed to provide payment services, comply with legal obligations and protect the security of the Platform;
e. You agree that your continued use of PayXchange following updates to this Privacy Policy constitutes acceptance of those updates, to the extent permitted by applicable law.
If you have questions regarding this Privacy Policy, you may contact Shiifa Limited using the official support channel below:
Shiifa Limited PayXchange Email: schiiphatech@gmail.com
This Chapter defines the key terms used throughout this Privacy Policy.
Unless the context otherwise requires, the following definitions shall apply whenever these terms are used in this Privacy Policy. Words importing the singular include the plural and vice versa, and references to one gender include all genders where the context permits.
For the purposes of this Privacy Policy:
"Account" Means a registered PayXchange user account created by a Customer, Merchant or other authorized User to access the Platform and its Services.
"Applicable Law" Means all laws, regulations, regulatory guidelines, directives, codes of practice and judicial decisions applicable to the processing of Personal Information and the operation of the PayXchange Platform, including those of the Federal Republic of Nigeria.
"Authentication" Means any process used to verify the identity of a User before granting access to an Account or authorizing a Transaction, including passwords, one-time passwords (OTPs), biometric verification, PINs or other approved security methods.
"Customer" Means an individual or organization that uses PayXchange to make payments to Merchants through the Platform.
"Data Controller" Means the natural or legal person who determines the purposes and means of processing Personal Information, as defined under applicable data protection laws. Where applicable, Shiifa Limited may act as a Data Controller.
"Data Processor" Means a person or organization that processes Personal Information on behalf of a Data Controller. Depending on the nature of the Service provided, Shiifa Limited or a Licensed Partner may act as a Data Processor.
"Data Subject" Means an identified or identifiable individual whose Personal Information is processed by Shiifa Limited.
"Device Information" Means technical information collected from a User's device, including but not limited to:
"Funding Source" Means a bank account, Wallet, debit instrument, Virtual Account or any other approved payment source linked to a User's PayXchange Account.
"KYC" Means "Know Your Customer" procedures conducted for identity verification and regulatory compliance. For PayXchange, KYC requirements may include those implemented by Shiifa Limited and those required by its Licensed Partners.
"Licensed Partner" Means any bank, payment service provider, financial institution, payment gateway, payment switch or other regulated entity that provides financial infrastructure enabling PayXchange to
offer its Services. At the Effective Date of this Privacy Policy, Nomba serves as PayXchange's primary Licensed Partner. Shiifa Limited may appoint additional Licensed Partners from time to time.
"Merchant" Means an individual, business or organization registered on PayXchange to receive digital payments from Customers.
"PayXchange" Means the digital payment platform owned and operated by Shiifa Limited that enables Customers to make secure payments to Merchants without manually entering traditional bank account details.
"Personal Information" or "Personal Data" Means any information relating to an identified or identifiable natural person. This may include, without limitation:
"Platform" Means the PayXchange mobile application, website, APIs, software systems, customer support channels and all related digital services operated by Shiifa Limited.
"Processing" Means any operation performed on Personal Information, whether by automated or manual means, including:
"Privacy Policy" Means this PayXchange Privacy Policy, including any amendments made from time to time.
"Services" Means all payment-related and technology services made available through the PayXchange Platform, including:
"Shiifa Limited" Means Shiifa Limited, a company incorporated in the Federal Republic of Nigeria under RC Number 9655738, being the owner and operator of PayXchange.
"Transaction" Means any payment, debit, credit, refund, reversal, settlement or other financial activity processed through the PayXchange Platform.
"User" Means any individual or organization accessing or using the PayXchange Platform, including Customers, Merchants, prospective Users and authorized representatives.
"Virtual Account" Means a unique account number assigned through a Licensed Partner for the purpose of facilitating payments on the PayXchange Platform. A Virtual Account does not necessarily constitute a traditional bank account.
"Wallet" Means a payment facility made available through PayXchange or its Licensed Partners that enables eligible Users to hold, receive or transfer value in accordance with applicable laws and regulatory requirements.
Unless the context otherwise requires:
Unless expressly stated otherwise, definitions used in this Privacy Policy shall have the same meanings as those contained in the PayXchange Terms and Conditions.
Where any inconsistency exists solely in relation to the processing of Personal Information, this Privacy Policy shall prevail to the extent of that inconsistency.
Where Shiifa Limited introduces new Services, technologies or payment functionalities that involve the processing of Personal Information, references in this Privacy Policy shall be interpreted to include those Services unless otherwise stated.
Additional definitions may be introduced through future updates to this Privacy Policy.
By using PayXchange, you acknowledge and agree that:
b. Capitalized terms shall have the meanings assigned to them unless the context requires otherwise;
d. The interpretation of this Privacy Policy shall promote transparency, lawful processing and the protection of Personal Information.
This Chapter explains the categories of Personal Information that Shiifa Limited may collect in connection with the operation of the PayXchange Platform.
Shiifa Limited collects only the information that is reasonably necessary to provide secure, reliable and legally compliant payment services, prevent fraud, comply with regulatory obligations and improve the quality of the Platform.
The categories of information collected may vary depending on the Services used, the User's level of verification and applicable legal or regulatory requirements.
Shiifa Limited may collect Personal Information that you voluntarily provide when you:
Depending on the Services you use and the verification level required, we may collect identity information including:
We may collect contact information including:
This information enables Shiifa Limited to communicate with Users regarding Accounts, Transactions, security notifications and customer support.
To facilitate payment services, we may collect financial information including:
Important: PayXchange is designed to facilitate payments without requiring Customers to manually enter a Merchant's bank account details at the point of payment. However, certain financial information is still required behind the scenes to securely authorize and complete Transactions through our Licensed Partners.
Shiifa Limited may collect information relating to Transactions conducted through the Platform, including:
Transaction records are essential for payment processing, fraud prevention, reconciliation, customer support and regulatory compliance.
To comply with applicable laws and regulatory obligations, Shiifa Limited and its Licensed Partners may collect:
The extent of information collected depends on the applicable KYC tier and regulatory requirements.
Where you register as a Merchant, Shiifa Limited may collect additional business information including:
When you access the PayXchange Platform, certain technical information may be collected automatically, including:
This information helps us maintain Platform security, improve performance and investigate technical issues.
Shiifa Limited may collect information regarding how Users interact with the Platform, including:
Usage information assists us in improving the functionality, reliability and usability of PayXchange.
Subject to your device settings and applicable law, we may collect location-related information including:
Location information may be used to:
Where you communicate with Shiifa Limited, we may retain records of:
Such communications assist in quality assurance, dispute resolution and customer support.
For security purposes, Shiifa Limited may collect:
Shiifa Limited may receive Personal Information from Licensed Partners and authorized third parties, including:
Such information is collected only where legally permitted and necessary for the provision of the Services.
Shiifa Limited does not intentionally collect Personal Information that is unnecessary for providing the Services.
We also do not intentionally collect:
Users are encouraged not to submit unnecessary Personal Information through the Platform or Customer Support channels.
Users are responsible for ensuring that the Personal Information they provide is:
Failure to provide accurate information may affect the availability of certain Services, delay Transactions or result in Account restrictions in accordance with the PayXchange Terms and Conditions.
As PayXchange introduces new products, payment technologies and regulatory features, Shiifa Limited may collect additional categories of Personal Information where reasonably necessary and permitted by applicable law.
Where required, Users will be informed through updates to this Privacy Policy or other appropriate notices.
By using PayXchange, you acknowledge and agree that:
a. Shiifa Limited collects Personal Information necessary to provide secure payment facilitation services;
b. The categories of information collected may vary depending on the Services you use and your verification level;
c. Certain information is required to comply with applicable laws, regulatory obligations and Licensed Partner requirements;
e. Shiifa Limited will process Personal Information in accordance with this Privacy Policy and applicable law.
This Chapter explains the various ways in which Shiifa Limited collects Personal Information in connection with the operation of the PayXchange Platform.
Personal Information may be collected directly from Users, automatically through the Platform, from Licensed Partners, or from other lawful and authorized sources where necessary to provide the Services, comply with applicable laws, prevent fraud and protect the integrity of the Platform.
Shiifa Limited is committed to collecting Personal Information in a lawful, fair and transparent manner.
Shiifa Limited collects Personal Information that you voluntarily provide when you:
You are responsible for ensuring that all information provided is accurate, complete and up to date.
When you register for PayXchange, Shiifa Limited may collect information necessary to establish and administer your Account, including:
Certain information may be mandatory before an Account can be activated.
Whenever you use PayXchange to facilitate a payment, Shiifa Limited may automatically collect information relating to that Transaction, including:
This information enables Shiifa Limited and its Licensed Partners to process, reconcile and secure Transactions.
When you access or use the Platform, certain information may be collected automatically through the operation of our systems.
Such information may include:
Automatic collection assists in maintaining Platform performance, detecting fraud and improving user experience.
Subject to your device settings and permissions, PayXchange may collect information from your device, including:
Shiifa Limited does not collect information from your device beyond what is reasonably necessary for the Services or permitted by applicable law.
Because PayXchange operates through regulated financial infrastructure, Shiifa Limited may receive Personal Information from Licensed Partners involved in providing payment services.
This may include information relating to:
At the Effective Date of this Privacy Policy, Nomba serves as PayXchange's primary Licensed Partner. Shiifa Limited may engage additional Licensed Partners in the future.
Where necessary to facilitate payment services, Shiifa Limited may receive information from banks or other regulated financial institutions regarding:
Such information is processed only for legitimate operational and regulatory purposes.
To comply with applicable laws and KYC obligations, Shiifa Limited or its Licensed Partners may obtain verification information from authorized identity verification providers.
Such information may include:
Only information reasonably necessary for identity verification shall be collected.
Where you interact with a Merchant through PayXchange, Shiifa Limited may receive information relating to:
PayXchange receives only the information necessary to facilitate the payment transaction and related support services.
Where you contact Customer Support, Shiifa Limited may collect information contained in:
This information assists in resolving issues, improving service quality and maintaining accurate records.
Where permitted or required by applicable law, Shiifa Limited may obtain information from:
Such information is collected only where relevant to legal compliance, fraud prevention or identity verification.
Shiifa Limited continuously monitors Platform activity to identify:
Information generated through such monitoring forms part of our security and fraud prevention programme.
As you continue using PayXchange, additional information may be generated, including:
This information assists Shiifa Limited in improving Platform functionality, enhancing security and complying with regulatory obligations.
Shiifa Limited does not intentionally collect Personal Information through deceptive, unlawful or covert means.
Where Personal Information is collected automatically, such collection occurs only through technologies reasonably necessary for the operation, security and improvement of the Platform or as otherwise permitted by applicable law.
Where you provide Personal Information relating to another individual—for example, an authorized representative of a Merchant—you represent that you have the legal authority to provide such information and that the individual has been informed, where required, about its intended use.
Shiifa Limited may process such information in accordance with this Privacy Policy and applicable law.
As PayXchange introduces new technologies, features or Services, Shiifa Limited may adopt additional lawful methods of collecting Personal Information.
Where such changes materially affect the processing of Personal Information, this Privacy Policy will be updated and Users will be notified where required by applicable law.
By using PayXchange, you acknowledge and agree that:
a. Shiifa Limited may collect Personal Information directly from you, automatically through the Platform and from authorized third parties;
b. Information may also be received from Licensed Partners, banks, identity verification providers and regulators where necessary to provide the Services or comply with applicable law;
c. Personal Information is collected only for legitimate business, operational, security and regulatory purposes;
e. Shiifa Limited collects Personal Information in accordance with this Privacy Policy and applicable data protection laws.
This Chapter explains the purposes for which Shiifa Limited processes Personal Information collected through the PayXchange Platform.
Shiifa Limited processes Personal Information only where there is a legitimate business, operational, contractual or legal reason to do so and in accordance with applicable data protection laws.
The information processed is limited to what is reasonably necessary to provide secure, efficient and compliant payment facilitation services.
Shiifa Limited uses Personal Information to provide and manage the PayXchange Platform, including to:
Personal Information is processed only to the extent necessary to perform these functions.
Personal Information is processed to:
The level of verification performed depends on the applicable KYC tier and regulatory obligations.
Shiifa Limited processes Personal Information to facilitate payment Transactions between Customers and Merchants.
This includes processing information necessary to:
PayXchange's primary function is to facilitate secure digital payments between Customers and Merchants without requiring Customers to manually enter a Merchant's bank account details during the payment process.
Protecting Users and the Platform is one of Shiifa Limited's primary objectives.
Personal Information may be processed to:
Automated monitoring tools may be used to identify activities that present elevated security risks.
Shiifa Limited processes Personal Information to comply with legal and regulatory obligations, including obligations relating to:
Compliance with applicable law is essential to the operation of the PayXchange Platform.
Personal Information is used to:
Support records may also be used for quality assurance and training purposes.
Shiifa Limited may use Personal Information to communicate with Users regarding:
Marketing communications will only be sent where permitted by applicable law and, where required, with the User's consent.
Users may opt out of promotional communications while continuing to receive essential service- related notifications.
Shiifa Limited continually seeks to improve the PayXchange Platform.
Personal Information may be analyzed to:
Where practicable, aggregated or anonymized information may be used for these purposes.
Personal Information may be processed to:
Such processing helps protect Customers, Merchants, Licensed Partners and Shiifa Limited.
Where applicable, Personal Information may be processed to:
Shiifa Limited maintains records necessary to:
Records are retained only for as long as necessary or as required by applicable law.
Personal Information may be processed to understand how Users interact with the Platform.
This may include analysis relating to:
Analytics help Shiifa Limited improve the reliability and effectiveness of PayXchange.
Personal Information may be processed to:
These activities help ensure the continued availability and resilience of the Platform.
Where appropriate and permitted by law, Shiifa Limited may use aggregated or anonymized information to:
Such information will not be used to identify individual Users unless otherwise permitted by applicable law.
As PayXchange expands its range of Services, Shiifa Limited may process Personal Information for additional purposes that are compatible with the original purposes of collection or otherwise permitted by applicable law.
Where required, Users will be notified before any materially different processing activities begin.
Shiifa Limited will not process Personal Information for purposes that are incompatible with this Privacy Policy unless:
By using PayXchange, you acknowledge and agree that:
a. Shiifa Limited processes Personal Information only for legitimate, specified and lawful purposes;
b. Your Personal Information is used to facilitate secure payment services, comply with regulatory obligations and protect the Platform;
c. Personal Information may also be used to improve services, prevent fraud and provide customer support;
d. Where required by law, your consent will be obtained before processing Personal Information for additional purposes;
e. Shiifa Limited remains committed to processing Personal Information fairly, transparently and in accordance with applicable data protection laws.
This Chapter explains the legal grounds upon which Shiifa Limited processes Personal Information through the PayXchange Platform.
Shiifa Limited processes Personal Information only where there is a lawful basis for doing so under applicable data protection laws, including the Nigeria Data Protection Act, 2023 (NDPA) and other applicable legislation.
Different legal bases may apply depending on the type of Personal Information processed, the Services being provided and the specific circumstances of the processing.
Shiifa Limited processes Personal Information where such processing is necessary to perform its contractual obligations to Users under the PayXchange Terms and Conditions.
This includes processing necessary to:
Without processing certain Personal Information, Shiifa Limited may be unable to provide the requested Services.
Shiifa Limited processes Personal Information where required to comply with applicable laws, regulations or lawful directives issued by competent authorities.
This includes compliance with obligations relating to:
Where processing is legally required, Shiifa Limited may process Personal Information without obtaining additional consent where permitted by applicable law.
Shiifa Limited may process Personal Information where such processing is necessary for its legitimate interests or those of its Licensed Partners, provided that such interests do not override the fundamental rights and freedoms of Users.
Legitimate interests may include:
Before relying on legitimate interests, Shiifa Limited shall assess whether the processing is fair, necessary and proportionate.
Where required by applicable law, Shiifa Limited will obtain a User's consent before processing Personal Information.
Consent may be requested for activities including:
Where processing is based on consent, Users may withdraw their consent at any time, subject to legal and contractual limitations.
Withdrawal of consent shall not affect the lawfulness of processing carried out before the withdrawal.
Shiifa Limited may process Personal Information where necessary to protect the vital interests of a User or another individual.
Such circumstances may include:
Where permitted or required by applicable law, Shiifa Limited may process Personal Information in the public interest, including processing necessary for:
Shiifa Limited has a legitimate interest and, where applicable, a legal obligation to process Personal Information for fraud prevention and security purposes.
Such processing may include:
Certain security decisions may involve automated processing, supported by human review where appropriate.
Some Personal Information is processed by Licensed Partners to enable payment services and comply with regulatory obligations.
Licensed Partners may process Personal Information under their own legal obligations or on behalf of Shiifa Limited, depending on the nature of the Service provided.
At the Effective Date of this Privacy Policy, Nomba serves as PayXchange's primary Licensed Partner.
Shiifa Limited may process and disclose Personal Information where necessary to:
Such processing shall be limited to what is reasonably necessary for the relevant legal purpose.
Certain Personal Information may be processed using automated systems to:
Shiifa Limited implements appropriate safeguards to reduce the risk of unfair or inaccurate automated decisions.
Where required by law, Users may request further information regarding significant automated processing affecting them.
Regardless of the legal basis relied upon, Shiifa Limited shall process only the Personal Information reasonably necessary to achieve the relevant purpose.
Information that is no longer required shall be retained or deleted in accordance with applicable legal requirements and Shiifa Limited's data retention practices.
Where the purpose for processing Personal Information changes materially, Shiifa Limited shall assess whether an alternative legal basis is required.
Where consent becomes necessary under applicable law, Shiifa Limited shall obtain such consent before commencing the new processing activity.
Users will be informed of material changes through appropriate communication channels.
Shiifa Limited is committed to ensuring that Users understand:
This Privacy Policy is intended to provide clear and transparent information regarding Shiifa Limited's data processing activities.
By using PayXchange, you acknowledge and agree that:
c. Certain processing is necessary to perform contractual obligations, comply with legal requirements and protect the security of the Platform;
d. Where consent is the applicable legal basis, you may withdraw that consent in accordance with applicable law;
e. Shiifa Limited will process Personal Information fairly, lawfully and transparently while respecting your rights under applicable data protection legislation.
This Chapter explains the circumstances under which Shiifa Limited may disclose, transfer or otherwise share Personal Information with third parties.
Shiifa Limited recognizes the confidential nature of Personal Information and is committed to limiting disclosures to those that are lawful, necessary and proportionate for the operation of the PayXchange Platform.
Personal Information is never sold to third parties for their independent marketing purposes.
Shiifa Limited shall disclose Personal Information only where such disclosure is:
Every disclosure shall be limited to the minimum amount of Personal Information reasonably necessary for the intended purpose.
Because PayXchange operates using regulated financial infrastructure, Shiifa Limited may disclose Personal Information to its Licensed Partners where necessary to:
At the Effective Date of this Privacy Policy, Nomba serves as PayXchange's primary Licensed Partner.
Shiifa Limited may appoint additional Licensed Partners as the Platform evolves, and Personal Information may be shared with such partners where necessary to provide the Services.
Where necessary to facilitate payment services, Personal Information may be shared with regulated banks and financial institutions for purposes including:
Such disclosures are limited to information required for the relevant financial transaction.
Shiifa Limited may share Personal Information with payment infrastructure providers involved in the processing of Transactions, including:
These entities process Personal Information solely for the purpose of providing payment-related services.
To comply with Know Your Customer (KYC) and regulatory requirements, Shiifa Limited may disclose Personal Information to authorized identity verification providers for purposes including:
Only information reasonably necessary for verification purposes shall be disclosed.
Shiifa Limited may engage trusted third-party service providers to perform functions on its behalf.
Such service providers may include those providing:
Service providers shall process Personal Information only in accordance with contractual obligations and appropriate confidentiality and security requirements.
Shiifa Limited may disclose Personal Information where required by applicable law or lawful regulatory directives.
Such disclosures may be made to competent authorities including:
Shiifa Limited shall disclose only the information reasonably necessary to satisfy the relevant legal requirement.
Where legally required or reasonably necessary to investigate fraud, financial crime or other unlawful activities, Shiifa Limited may disclose Personal Information to:
Such disclosures shall be made in accordance with applicable law.
If Shiifa Limited undergoes:
Personal Information may be transferred as part of that transaction, provided appropriate safeguards are implemented and applicable legal requirements are satisfied.
Users shall be notified where required by applicable law.
Where no other lawful basis applies, Shiifa Limited shall seek the User's consent before disclosing Personal Information.
Consent-based disclosures may include:
Users may withdraw such consent at any time, subject to applicable legal and contractual limitations.
Shiifa Limited may share Personal Information with Licensed Partners, financial institutions and fraud prevention organizations where reasonably necessary to:
Such disclosures support the security of both Users and the wider financial system.
Where Personal Information is transferred outside Nigeria, Shiifa Limited shall take reasonable steps to ensure that appropriate legal, contractual and technical safeguards are implemented in accordance with applicable data protection laws.
Further information regarding international data transfers is provided in Chapter 10 of this Privacy Policy.
All third parties receiving Personal Information from Shiifa Limited are expected to maintain appropriate confidentiality, privacy and security standards.
Where appropriate, Shiifa Limited shall require such parties to:
Except as described in this Privacy Policy or required by applicable law, Shiifa Limited does not:
As PayXchange expands its Services, Shiifa Limited may engage additional Licensed Partners or service providers.
Where new categories of recipients materially affect the processing of Personal Information, this Privacy Policy shall be updated and Users shall be notified where required by applicable law.
By using PayXchange, you acknowledge and agree that:
a. Shiifa Limited may disclose Personal Information where necessary to provide the Services, comply with legal obligations or protect the security of the Platform;
b. Personal Information may be shared with Licensed Partners, including Nomba, banks, payment infrastructure providers, identity verification providers, regulators and trusted service providers;
c. Shiifa Limited does not sell Personal Information to third parties for independent marketing purposes;
e. All disclosures are made in accordance with this Privacy Policy and applicable data protection laws.
This Chapter explains the measures implemented by Shiifa Limited to safeguard Personal Information against unauthorized access, disclosure, alteration, loss, misuse or destruction.
Recognizing that digital payment platforms process sensitive financial and identity information, Shiifa Limited is committed to maintaining appropriate administrative, technical and physical safeguards designed to protect the confidentiality, integrity and availability of Personal Information.
While no security system can guarantee absolute protection, Shiifa Limited continuously reviews and improves its security practices to address evolving threats.
Shiifa Limited is committed to implementing reasonable and appropriate security measures consistent with:
Security controls are reviewed periodically to ensure their continued effectiveness.
Shiifa Limited maintains administrative measures designed to protect Personal Information, including:
Access to Personal Information is restricted to personnel whose duties reasonably require such access.
Shiifa Limited employs appropriate technical safeguards, which may include:
These safeguards are intended to reduce the risk of unauthorized access or compromise.
To protect User Accounts and Personal Information, Shiifa Limited implements authentication and access control measures that may include:
Users are responsible for safeguarding their authentication credentials and must not disclose them to unauthorized persons.
Given PayXchange's role as a payment facilitation platform, Shiifa Limited implements measures designed to protect payment-related information throughout the transaction lifecycle.
These measures may include:
At no time should Users share confidential authentication credentials, such as PINs or OTPs, with any person claiming to represent PayXchange.
Shiifa Limited employs systems and procedures intended to identify and prevent fraudulent activities.
These may include:
Where suspicious activities are identified, Shiifa Limited may temporarily delay, restrict or decline Transactions pending further review.
Shiifa Limited maintains security logs and audit records to:
Access to audit logs is restricted to authorized personnel.
Shiifa Limited maintains procedures for responding to actual or suspected security incidents.
Such procedures may include:
Incident response activities are designed to minimize potential harm to Users and the Platform.
Users also play an important role in protecting their Personal Information.
Users should:
Failure to follow reasonable security practices may increase the risk of unauthorized access to an Account.
Employees, contractors and authorized representatives of Shiifa Limited who have access to Personal Information are required to:
Appropriate disciplinary measures may be taken where confidentiality obligations are breached.
Where Shiifa Limited engages Licensed Partners or service providers that process Personal Information, reasonable steps are taken to ensure that such parties implement appropriate security measures consistent with applicable legal and contractual requirements.
Shiifa Limited, however, is not responsible for security failures arising solely from the independent systems of third parties that are outside its reasonable control.
Shiifa Limited takes reasonable measures to help ensure that Personal Information remains:
Users are encouraged to promptly update their Account information whenever changes occur.
Cybersecurity threats continue to evolve.
Accordingly, Shiifa Limited regularly reviews and enhances its security controls, technologies and procedures to strengthen the protection of Personal Information and improve the resilience of the PayXchange Platform.
Although Shiifa Limited employs commercially reasonable safeguards, no electronic storage system, internet transmission or information technology environment can be guaranteed to be completely secure.
Accordingly:
a. Users acknowledge the inherent risks associated with electronic communications and digital payment services;
b. Shiifa Limited does not warrant that unauthorized access, cyberattacks or security incidents will never occur;
c. Shiifa Limited shall not be liable for security incidents resulting from circumstances beyond its reasonable control, except where liability arises under applicable law or from its proven negligence or wilful misconduct.
Nothing in this Section limits any rights that Users may have under applicable data protection or consumer protection laws.
By using PayXchange, you acknowledge and agree that:
a. Shiifa Limited implements reasonable administrative, technical and physical safeguards to protect Personal Information;
c. Users are responsible for safeguarding their authentication credentials and promptly reporting suspected security incidents;
e. Despite reasonable safeguards, no electronic system can guarantee absolute security, and Personal Information will be protected in accordance with applicable law and this Privacy Policy.
This Chapter explains how Shiifa Limited retains, archives and securely disposes of Personal Information processed through the PayXchange Platform.
Shiifa Limited recognizes that retaining Personal Information for longer than necessary increases privacy and security risks. Accordingly, Personal Information is retained only for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with applicable laws, resolve disputes, enforce legal rights and satisfy regulatory obligations.
Shiifa Limited shall retain Personal Information only for the period reasonably necessary to:
When Personal Information is no longer required, it shall be securely deleted, anonymized or otherwise disposed of in accordance with applicable law.
Personal Information relating to User Accounts may be retained:
Account is closed.
Closure of an Account does not automatically require immediate deletion of all Personal Information.
Shiifa Limited may retain Transaction records, including payment references, settlement records and related information, for periods required to:
Transaction records may therefore be retained after a User ceases using the Platform where required by law.
Identity verification information collected during Know Your Customer (KYC) procedures may be retained for periods required under applicable laws governing:
Such information may continue to be retained after an Account has been closed where legally required.
Communications with Customer Support, including emails, complaint records, support tickets and related correspondence, may be retained to:
Retention periods may vary depending on the nature of the enquiry or complaint.
Security-related information, including authentication logs, audit logs and fraud monitoring records, may be retained for as long as reasonably necessary to:
Where Shiifa Limited becomes aware of:
Personal Information relevant to such matters may be retained beyond normal retention periods until the matter has been fully resolved.
Where appropriate, Personal Information that is no longer actively required for operational purposes may be securely archived.
Archived information shall remain subject to:
Archived information shall be accessed only where reasonably necessary.
When Personal Information is no longer required, Shiifa Limited shall take reasonable steps to securely dispose of it.
Secure disposal methods may include:
Shiifa Limited aims to prevent unauthorized recovery of disposed Personal Information.
Where Personal Information has been permanently anonymized so that individuals can no longer be identified, Shiifa Limited may retain and use such information for legitimate purposes including:
Anonymized information is not treated as Personal Information once it can no longer reasonably identify an individual.
Users may request the deletion of certain Personal Information where permitted under applicable law.
Shiifa Limited may decline or delay such requests where retention remains necessary to:
Where deletion cannot be carried out immediately, Shiifa Limited shall inform the User where required by applicable law.
Shiifa Limited periodically reviews the Personal Information it retains to determine whether continued retention remains necessary.
Information that no longer serves a legitimate operational, contractual or legal purpose shall be securely deleted or anonymized where appropriate.
Certain Personal Information may also be retained by Licensed Partners in accordance with their own legal and regulatory obligations.
At the Effective Date of this Privacy Policy, Nomba serves as PayXchange's primary Licensed Partner.
Retention periods applied by Licensed Partners may differ where required by applicable financial regulations.
Users are encouraged to:
By using PayXchange, you acknowledge and agree that:
a. Shiifa Limited retains Personal Information only for as long as reasonably necessary to provide the Services and comply with applicable law;
b. Certain information, including Transaction records and KYC information, may be retained after Account closure to satisfy legal and regulatory obligations;
c. Personal Information that is no longer required shall be securely deleted, anonymized or otherwise disposed of using appropriate methods;
d. Deletion requests may be limited where continued retention is required by law or necessary to protect the legitimate interests of Shiifa Limited, its Licensed Partners or other Users;
e. Shiifa Limited remains committed to responsible data retention practices that balance operational needs, regulatory compliance and the protection of Users' privacy.
This Chapter explains the circumstances under which Personal Information processed by Shiifa Limited may be transferred to, accessed from or processed outside the Federal Republic of Nigeria.
Shiifa Limited recognizes that the use of modern payment infrastructure, cloud technologies and specialized service providers may require certain Personal Information to be processed across national borders.
Where such transfers occur, Shiifa Limited is committed to ensuring that Personal Information continues to receive an appropriate level of protection in accordance with applicable laws and recognized international privacy standards.
Shiifa Limited shall take reasonable steps to ensure that any international transfer of Personal Information:
International transfers shall not be undertaken solely for convenience where a less intrusive alternative is reasonably available.
Personal Information may be transferred outside Nigeria where reasonably necessary for purposes including:
Such transfers shall occur only where appropriate safeguards have been implemented.
Shiifa Limited may engage Licensed Partners, technology providers or service providers that process Personal Information from locations outside Nigeria.
Where this occurs, Shiifa Limited shall take reasonable steps to ensure that such organizations:
At the Effective Date of this Privacy Policy, Nomba serves as PayXchange's primary Licensed Partner. Additional Licensed Partners may be engaged in the future where necessary to expand or improve PayXchange's Services.
Where Personal Information is transferred internationally, Shiifa Limited shall implement appropriate safeguards, which may include:
These measures are intended to provide a level of protection comparable to that required under Nigerian law.
Before transferring Personal Information internationally, Shiifa Limited may consider factors including:
Transfers shall be undertaken only where Shiifa Limited reasonably believes that appropriate protection can be maintained.
To reduce risks associated with cross-border processing, Shiifa Limited may implement security measures including:
These safeguards help protect Personal Information while it is transmitted and processed.
Personal Information may be transferred outside Nigeria where required:
Such transfers shall be limited to the information reasonably necessary for the relevant legal purpose.
Where applicable under law, Users may request information regarding:
Shiifa Limited shall respond to such requests in accordance with applicable legal requirements and subject to any lawful limitations.
As PayXchange expands its operations, Shiifa Limited may introduce additional services involving international payment infrastructure, cross-border technology providers or international business operations.
Where these developments materially affect the international processing of Personal Information, Shiifa Limited shall update this Privacy Policy and notify Users where required by applicable law.
Shiifa Limited shall not knowingly transfer Personal Information internationally where doing so would:
International transfers shall always be proportionate to the intended purpose.
By using PayXchange, you acknowledge and agree that:
a. Certain Personal Information may be transferred to or processed in jurisdictions outside Nigeria where necessary to provide the Services;
b. Shiifa Limited shall implement reasonable legal, contractual, technical and organizational safeguards to protect Personal Information during international transfers;
c. International transfers may occur in connection with secure cloud services, payment infrastructure, cybersecurity, fraud prevention, technical support and other legitimate operational purposes;
d. Shiifa Limited remains committed to ensuring that Personal Information transferred internationally receives a level of protection consistent with applicable Nigerian data protection laws;
e. Where material changes occur regarding international data transfers, Shiifa Limited shall update this Privacy Policy and provide notice where required by applicable law.
This Chapter explains the rights available to Users regarding their Personal Information and the procedures for exercising those rights.
Shiifa Limited respects the privacy rights of its Users and is committed to ensuring that Personal Information is processed fairly, lawfully and transparently in accordance with the Nigeria Data Protection Act, 2023 (NDPA) and other applicable laws.
While certain rights may be subject to legal or regulatory limitations, Shiifa Limited will consider every valid request in good faith and respond within the timeframes required by applicable law.
Subject to applicable law, Users may exercise certain rights in relation to their Personal Information held by Shiifa Limited.
These rights are intended to provide Users with greater transparency, control and confidence regarding how their Personal Information is collected, used, stored and shared.
Users have the right to request confirmation as to whether Shiifa Limited processes their Personal Information.
Where applicable, Users may request access to information including:
Shiifa Limited may require reasonable verification of identity before providing access to Personal Information.
Users have the right to request that inaccurate, incomplete or outdated Personal Information be corrected or updated.
Where reasonably possible, Users may also update certain Account information directly through the PayXchange Platform.
Shiifa Limited may request supporting documentation where necessary to verify the accuracy of the requested correction.
Subject to applicable law, Users may request the deletion of certain Personal Information where:
Shiifa Limited may decline or defer deletion where retention is necessary to:
Where Personal Information is processed on the basis of consent, Users may withdraw that consent at any time.
Withdrawal of consent:
Where permitted by applicable law, Users may object to certain processing activities, particularly where processing is based on Shiifa Limited's legitimate interests.
Upon receiving such a request, Shiifa Limited shall assess whether compelling lawful grounds exist to continue the processing.
Where no such grounds exist, the processing shall cease to the extent required by applicable law.
Where applicable, Users may request that Shiifa Limited temporarily restrict the processing of Personal Information in circumstances including:
During the restriction period, Personal Information may continue to be stored but shall otherwise be processed only where permitted by law.
Where applicable under law and technically feasible, Users may request a copy of certain Personal Information in a structured, commonly used and machine-readable format.
This right applies only where:
Shiifa Limited reserves the right to apply reasonable technical limitations where permitted by law.
Users who believe that Shiifa Limited has processed their Personal Information unlawfully may:
supervisory authority where permitted by applicable law.
Shiifa Limited encourages Users to contact it first so that concerns may be investigated and, where appropriate, resolved promptly.
To protect Personal Information from unauthorized disclosure, Shiifa Limited may require Users to verify their identity before responding to privacy-related requests.
Verification measures may include:
Shiifa Limited reserves the right to decline requests where identity cannot be satisfactorily verified.
Certain privacy rights may be limited where necessary to:
Any limitation shall be applied only to the extent permitted by applicable law.
Shiifa Limited shall make reasonable efforts to acknowledge and respond to valid privacy requests within the timeframes prescribed by applicable law.
Where additional time is reasonably required due to the complexity or volume of requests, Shiifa Limited may extend the response period where permitted by law and shall notify the User accordingly.
Shiifa Limited shall not unlawfully discriminate against a User for exercising any privacy right available under applicable law.
However, where the exercise of a particular right makes it impossible to provide certain Services, Shiifa Limited may suspend or discontinue those Services to the extent reasonably necessary.
Users are responsible for:
Providing false or misleading information may affect Shiifa Limited's ability to process a request.
By using PayXchange, you acknowledge and agree that:
b. Shiifa Limited will make reasonable efforts to facilitate the exercise of those rights in accordance with applicable law;
d. Shiifa Limited may require reasonable identity verification before acting on privacy-related requests;
e. Shiifa Limited remains committed to respecting and protecting your privacy rights while maintaining the security, integrity and lawful operation of the PayXchange Platform.
This Chapter explains how Shiifa Limited uses cookies, mobile device identifiers and similar technologies in connection with the operation of the PayXchange Platform.
These technologies help provide secure, reliable and efficient Services, improve the performance of the Platform, detect fraudulent activities, remember User preferences and enhance the overall User experience.
As PayXchange primarily operates as a mobile application, certain technologies described in this Chapter may apply differently depending on whether a User accesses the Platform through the mobile application, website or other digital channels.
Cookies are small text files stored on a User's browser or device when visiting a website.
Because PayXchange is primarily a mobile application, Shiifa Limited may also use technologies functionally similar to cookies, including:
For the purposes of this Privacy Policy, these technologies are collectively referred to as "Cookies and Similar Technologies."
Shiifa Limited may use the following categories of technologies:
(a) Essential Technologies
These technologies are necessary for the operation of the Platform. They may be used to:
Without these technologies, certain Services may not function properly.
(b) Security Technologies
Security technologies help protect both Users and the Platform. They may be used to:
(c) Performance Technologies
Performance technologies help Shiifa Limited understand how the Platform operates by collecting information relating to:
This information assists in improving the stability and efficiency of the Platform.
(d) Functional Technologies
Functional technologies allow the Platform to remember User preferences, including:
These technologies improve convenience without fundamentally altering the operation of the Platform.
(e) Analytics Technologies
Where permitted by applicable law, Shiifa Limited may use analytics technologies to better understand how Users interact with the Platform.
Analytics information may include:
Where practicable, analytics information shall be aggregated or anonymized.
Cookies and Similar Technologies may collect information including:
These technologies are not intended to collect more Personal Information than is reasonably necessary for the purposes described in this Privacy Policy.
Shiifa Limited uses these technologies for purposes including:
Certain Licensed Partners or trusted service providers may use Cookies and Similar Technologies where necessary to provide services to PayXchange.
Such parties may include providers of:
Shiifa Limited requires such providers to process information only for authorized purposes and in accordance with applicable contractual obligations.
Users may control certain technologies through:
However, disabling certain essential technologies may limit or prevent access to some PayXchange Services, including secure authentication and payment functionality.
Depending on the features used, PayXchange may request permission to access certain device capabilities, including:
Permissions requested by the Platform are limited to those reasonably necessary for the provision, security and improvement of the Services.
Users may withdraw certain permissions through their device settings, although doing so may affect the availability or functionality of specific Services.
At the Effective Date of this Privacy Policy, PayXchange does not use Personal Information collected through Cookies and Similar Technologies for third-party behavioural advertising.
Should Shiifa Limited introduce advertising or promotional technologies in the future, Users will be notified through an updated Privacy Policy where required by applicable law.
Information collected through Cookies and Similar Technologies is protected using appropriate technical and organizational safeguards consistent with Shiifa Limited's information security programme.
Such safeguards may include:
As technology evolves, Shiifa Limited may introduce additional Cookies or Similar Technologies to improve the security, functionality and efficiency of the Platform.
Where such changes materially affect the processing of Personal Information, Shiifa Limited shall update this Privacy Policy and notify Users where required by applicable law.
By using PayXchange, you acknowledge and agree that:
a. Shiifa Limited uses Cookies, device identifiers and Similar Technologies to support the secure and efficient operation of the Platform;
b. These technologies assist in authentication, fraud prevention, payment processing, performance monitoring and service improvement;
c. Certain essential technologies are necessary for the proper functioning of the Platform and cannot be disabled without affecting core Services;
d. Users may manage certain permissions and settings through their devices or browsers, subject to the operational requirements of the Platform;
e. Shiifa Limited uses these technologies responsibly and in accordance with this Privacy Policy and applicable data protection laws.
This Chapter explains Shiifa Limited's approach to the collection, processing and protection of Personal Information relating to children.
PayXchange is designed as a financial technology platform for individuals and businesses who are legally capable of entering into binding agreements and using regulated financial services.
Shiifa Limited recognizes the importance of protecting the privacy of children and is committed to complying with applicable laws governing the processing of children's Personal Information.
The PayXchange Platform is intended for use by:
applicable law;
The Platform is not intentionally designed or marketed for use by young children.
Shiifa Limited does not knowingly collect Personal Information directly from children in violation of applicable law.
Where the Platform requires identity verification through Know Your Customer (KYC) procedures, Users must provide accurate information confirming their eligibility to use the Services.
If Shiifa Limited becomes aware that a User has created or is operating a PayXchange Account while not legally eligible to do so, Shiifa Limited may, without prior notice:
Such actions are intended to protect the child, comply with applicable regulations and safeguard the integrity of the Platform.
Despite reasonable verification measures, Shiifa Limited acknowledges that Personal Information relating to a child may occasionally be provided inadvertently.
Where Shiifa Limited becomes aware that such information has been collected unlawfully, it shall take reasonable steps to:
Where permitted under applicable law, a parent or legal guardian may contact Shiifa Limited to:
Shiifa Limited may require reasonable verification of the identity and legal authority of the requesting parent or guardian before acting on such requests.
If Shiifa Limited introduces products or services specifically intended for educational institutions, youth programmes or individuals below the ordinary eligibility age, this Privacy Policy may be supplemented by additional privacy notices or terms appropriate to those services.
Any such processing shall be conducted in accordance with applicable law and appropriate safeguards.
To reduce the likelihood of underage use of the Platform, Shiifa Limited and its Licensed Partners may implement identity verification measures including:
These measures assist in ensuring that the Platform is used only by eligible individuals.
Where Shiifa Limited lawfully processes Personal Information relating to a child, such information shall receive the same level of protection as other Personal Information processed through the Platform.
Additional safeguards may be implemented where required by applicable law or where the sensitivity of the information warrants enhanced protection.
Shiifa Limited shall process any Personal Information relating to children in accordance with:
If PayXchange introduces products or financial services specifically intended for younger users in the future, Shiifa Limited shall review and update this Privacy Policy to ensure that appropriate privacy protections and parental consent mechanisms are implemented where required by law.
By using PayXchange, you acknowledge and agree that:
a. The Platform is intended primarily for individuals who are legally eligible to use regulated financial services;
b. Shiifa Limited does not knowingly collect Personal Information from children in violation of applicable law;
c. Where Shiifa Limited becomes aware of unlawful collection of a child's Personal Information, appropriate corrective measures may be taken;
d. Parents and legal guardians may contact Shiifa Limited regarding the processing of a child's Personal Information where permitted by applicable law;
e. Shiifa Limited remains committed to protecting the privacy and Personal Information of children in accordance with applicable laws and regulatory requirements.
This Chapter explains how Shiifa Limited may amend, revise or update this Privacy Policy from time to time.
As PayXchange evolves, applicable laws change and new technologies are introduced, Shiifa Limited may find it necessary to modify this Privacy Policy to accurately reflect its data processing practices and legal obligations.
Shiifa Limited is committed to maintaining transparency whenever material changes are made.
Shiifa Limited reserves the right to amend, update, replace or revise this Privacy Policy at any time where reasonably necessary, including to:
Material changes may include, but are not limited to:
Where required by applicable law, Shiifa Limited shall provide appropriate notice before material changes become effective.
Shiifa Limited may also make non-material changes to improve the clarity, readability or organization of this Privacy Policy.
Examples include:
Such changes may become effective immediately upon publication.
Where appropriate, Shiifa Limited may notify Users of updates to this Privacy Policy through one or more of the following methods:
The method of notification may depend on the significance of the changes and applicable legal requirements.
Each version of this Privacy Policy shall indicate its effective date.
Unless otherwise stated, revisions become effective on the date specified in the updated Privacy Policy.
Where applicable law requires advance notice or consent before certain changes take effect, Shiifa Limited shall comply with those legal requirements.
Following the effective date of an updated Privacy Policy, continued access to or use of the PayXchange Platform may constitute acknowledgement of the revised Privacy Policy, to the extent permitted by applicable law.
Where applicable law requires express consent for particular changes, Shiifa Limited shall obtain such consent before relying upon the updated provisions.
Users are encouraged to periodically review this Privacy Policy to remain informed about how Shiifa Limited collects, uses, protects and shares Personal Information.
Failure to review updated versions of this Privacy Policy does not prevent revised provisions from applying where legally effective.
Shiifa Limited may retain previous versions of this Privacy Policy for:
Users may request information regarding previous versions where required by applicable law.
Where amendments are necessary to comply with:
Shiifa Limited may implement such changes as required to maintain legal compliance.
As PayXchange introduces new payment services, technologies or partnerships, Shiifa Limited may revise this Privacy Policy to address:
By using PayXchange, you acknowledge and agree that:
a. Shiifa Limited may amend this Privacy Policy from time to time to reflect changes in law, technology, business operations or the Services provided;
b. Material changes will be communicated through appropriate channels where required by applicable law;
c. Users are encouraged to review this Privacy Policy periodically to remain informed about how their Personal Information is processed;
d. Continued use of the PayXchange Platform after the effective date of an updated Privacy Policy may constitute acceptance of the revised Privacy Policy, to the extent permitted by applicable law;
e. Shiifa Limited remains committed to transparency and compliance whenever changes to this Privacy Policy are made.
This Chapter explains how Users may contact Shiifa Limited regarding this Privacy Policy, their Personal Information or any privacy-related concerns.
Shiifa Limited is committed to handling privacy enquiries, complaints and requests in a fair, transparent and timely manner. Users are encouraged to contact Shiifa Limited directly so that concerns may be investigated and, where appropriate, resolved efficiently.
At the Effective Date of this Privacy Policy, Users may contact Shiifa Limited using the following details:
Company Name: Shiifa Limited RC Number:
PayXchange Support Email: schiiphatech@gmail.com
As the PayXchange Platform develops, Shiifa Limited may publish additional contact channels, including a customer support telephone number, website, mobile application support centre or dedicated privacy contact.
Updated contact information will be made available through the official PayXchange communication channels.
Users may contact Shiifa Limited regarding matters including:
Shiifa Limited will make reasonable efforts to respond to enquiries within the timeframes required by applicable law.
Users may submit requests relating to their Personal Information, including requests to:
Requests should contain sufficient information to enable Shiifa Limited to identify the relevant User and assess the request.
Before responding to privacy requests, Shiifa Limited may require reasonable verification of the requester's identity.
Verification measures may include:
Shiifa Limited reserves the right to decline requests where identity cannot be adequately verified.
Users who believe that Shiifa Limited has processed their Personal Information in a manner inconsistent with this Privacy Policy or applicable law may submit a complaint.
Complaints should, where possible, include:
Shiifa Limited shall investigate complaints fairly and objectively.
Upon receiving a complaint, Shiifa Limited may:
Where corrective action is appropriate, Shiifa Limited shall take reasonable steps to implement such action.
If a User remains dissatisfied after Shiifa Limited has concluded its internal review, the User may, where permitted by applicable law, refer the matter to the appropriate supervisory authority, including the Nigeria Data Protection Commission (NDPC) or any other competent regulatory authority having jurisdiction over the matter.
Nothing in this Privacy Policy limits any statutory rights available to Users under applicable law.
Shiifa Limited may communicate with Users regarding privacy matters through:
Users are responsible for ensuring that their registered contact information remains accurate and up to date.
The current version of this Privacy Policy shall be made available through appropriate PayXchange channels, including, where applicable:
Previous versions may be retained for legal, regulatory or audit purposes.
At the Effective Date of this Privacy Policy, Shiifa Limited has not yet appointed a dedicated Data Protection Officer (DPO).
As the organization expands and where required by applicable law or business needs, Shiifa Limited may appoint a Data Protection Officer or another designated privacy representative.
Any such appointment and the relevant contact details shall be reflected in an updated version of this Privacy Policy.
Shiifa Limited may introduce additional communication channels, including:
Users should rely only on contact information published through official PayXchange channels.
Users are expected to submit privacy requests and complaints honestly and in good faith.
Shiifa Limited reserves the right to decline or limit responses to:
Such limitations shall be applied only where permitted by applicable law.
By using PayXchange, you acknowledge and agree that:
a. You may contact Shiifa Limited regarding any questions or concerns relating to this Privacy Policy or your Personal Information;
b. Shiifa Limited may require reasonable identity verification before responding to privacy-related requests;
c. Privacy complaints will be investigated fairly and in accordance with applicable legal requirements;
d. Where a complaint cannot be resolved internally, you may have the right to refer the matter to the Nigeria Data Protection Commission (NDPC) or another competent authority;
e. Shiifa Limited remains committed to maintaining open, transparent and effective communication regarding privacy matters.
This Chapter contains the final legal provisions governing the interpretation, application and administration of this Privacy Policy.
These provisions are intended to ensure that this Privacy Policy remains legally effective, enforceable and consistent with applicable laws while supporting the continued operation of the PayXchange Platform.
This Privacy Policy shall be governed by and interpreted in accordance with the laws of the Federal Republic of Nigeria, including but not limited to:
(NDPC);
and consumer protection.
Nothing in this Privacy Policy shall be interpreted as limiting any statutory rights available to Users under applicable law.
In interpreting this Privacy Policy:
limitation."
If any provision of this Privacy Policy is determined by a court of competent jurisdiction or another competent authority to be invalid, unlawful or unenforceable, that provision shall, to the extent necessary, be severed from this Privacy Policy.
The remaining provisions shall continue in full force and effect to the fullest extent permitted by applicable law.
Failure or delay by Shiifa Limited to exercise any right or remedy under this Privacy Policy shall not constitute a waiver of that right or remedy.
Any waiver shall be effective only if made expressly in writing by Shiifa Limited.
A waiver of any particular right shall not constitute a waiver of any other right or any future exercise of the same right.
This Privacy Policy constitutes the complete statement of Shiifa Limited's privacy practices relating to the PayXchange Platform as of its Effective Date.
It should be read together with:
Where inconsistencies arise, any mandatory requirements imposed by applicable law shall prevail.
Shiifa Limited intends to operate the PayXchange Platform in compliance with applicable legal and regulatory requirements.
Where any provision of this Privacy Policy conflicts with a mandatory legal obligation, Shiifa Limited shall interpret and apply this Privacy Policy in a manner consistent with applicable law.
Nothing in this Privacy Policy shall be interpreted as permitting conduct prohibited by law.
Shiifa Limited may assign or transfer its rights and obligations under this Privacy Policy as part of:
Where required by applicable law, Users shall be notified of such changes.
PayXchange provides payment facilitation services through regulated financial infrastructure operated by Licensed Partners.
Accordingly:
their own privacy policies and legal obligations;
with the PayXchange Platform;
services are utilized.
At the Effective Date of this Privacy Policy, Nomba serves as PayXchange's primary Licensed Partner.
The provisions of this Privacy Policy that by their nature are intended to survive the closure of a User Account or termination of the Services shall continue in effect after such closure or termination.
These include, without limitation, provisions relating to:
This Privacy Policy becomes effective on 3 July 2026 and shall remain in effect until amended or replaced by Shiifa Limited in accordance with Chapter 14 (Changes to this Privacy Policy).
The version number and effective date shall be updated whenever material revisions are made.
By creating a PayXchange Account, accessing or using the PayXchange Platform, you acknowledge and agree that:
b. You understand how Shiifa Limited collects, uses, stores, protects and shares your Personal Information;
d. You acknowledge that certain Personal Information may be processed by Licensed Partners where necessary to provide the Services;
e. You agree that Shiifa Limited may process your Personal Information in accordance with this Privacy Policy and applicable law;
f. Where your consent is required under applicable law, such consent shall be obtained before the relevant processing activity is undertaken;
g. If you do not agree with this Privacy Policy, you should discontinue use of the PayXchange Platform.
Shiifa Limited appreciates the trust placed in PayXchange by its Users.
Protecting the privacy, confidentiality and security of Personal Information is fundamental to the operation of the Platform. Shiifa Limited remains committed to maintaining high standards of data protection, transparency, accountability and regulatory compliance while continuously improving its payment services.
As PayXchange evolves, Shiifa Limited will continue to review and enhance its privacy practices to ensure that Users' Personal Information is handled responsibly, securely and in accordance with applicable laws and internationally recognized privacy principles.