Privacy Policy

This Privacy Policy explains how Kivo collects, uses, stores, protects and discloses personal data when you use the Kivo website, mobile application or related services.

The Policy is intended to apply across the Kivo website and mobile application so that substantially the same document can be used for the relevant App Store and Google Play privacy disclosures.

The relevant data controller is: PAYAZA/ASTERIC/KIVO

Where Kivo processes personal data on behalf of another entity, Kivo may act as a data processor or other authorised data-handling party, as applicable.

Depending on your interaction with Kivo, we may collect:

Personal data may be processed for:

• Account creation and administration
• Identity verification
• KYC/CDD and regulatory compliance
• Processing transactions and instructions
• Provision of investment or financial services
• Fraud prevention and detection
• AML/CFT/CPF compliance
• Sanctions screening
• Customer support
• Platform security
• System improvement
• Communication with users
• Legal and regulatory reporting
• Dispute resolution
• Other lawful purposes communicated to you

Personal data will be processed on an applicable lawful basis, which may include:

• Performance of a contract
• Compliance with a legal or regulatory obligation
• Consent
• Legitimate interests, where applicable
• Protection of vital interests where legally applicable

Consent will be sought where consent is the appropriate legal basis.

Kivo may use cookies, SDKs, analytics tools and similar technologies to:

• Maintain sessions
• Remember preferences
• Improve functionality
• Analyse Platform usage
• Monitor security
• Improve user experience

Where required, users will be provided with appropriate choices concerning non-essential cookies.

Kivo may disclose personal data where reasonably necessary to:

• Regulated financial institutions
• Payment processors
• Technology and cloud service providers
• Identity-verification providers
• Professional advisers
• Auditors
• Regulators and government authorities
• Law-enforcement agencies
• Affiliated entities
• Other service providers necessary to deliver the Platform

Kivo may disclose information where required to comply with applicable Nigerian law, regulatory requirements, court orders, lawful governmental requests, AML/CFT obligations, fraud prevention requirements or other legal obligations.

We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, loss or destruction.

However, no internet transmission or electronic storage system can be guaranteed to be completely secure.

Personal data will be retained for as long as reasonably necessary for the purposes for which it was collected, including compliance with applicable legal, regulatory, accounting, audit and record-retention requirements.

Where personal data is transferred outside Nigeria, Kivo will take steps required under applicable data protection law to ensure that the transfer is lawful and that appropriate safeguards are implemented.

Subject to applicable law, you may have rights relating to your personal data, including rights to:

• Request access to personal data
• Request correction of inaccurate information
• Request deletion where legally applicable
• Object to or restrict certain processing
• Request portability where applicable
• Withdraw consent where consent is the legal basis
• Lodge a complaint with the relevant data protection authority

The Platform and the investment services provided through it are not intended for direct use by persons who are not legally eligible to independently access or utilise such services.

Kivo does not knowingly collect or process personal data directly from children or minors except where such processing is lawful and necessary in connection with an investment or account established on their behalf by a duly authorised parent, legal guardian or trustee.

Where an investment is made or maintained in the name of a minor, the relevant parent, legal guardian or trustee shall be responsible for providing the required information, completing the applicable KYC and verification requirements, and providing instructions on behalf of the minor in accordance with applicable law and the terms governing the investment.

Kivo reserves the right to request appropriate documentation to verify the identity and authority of any person acting on behalf of a minor.

We may update this Privacy Policy periodically.

The updated version will be published on the Platform together with the applicable effective date.