ELNEXU CONSULTS LIMITED

1. Introduction and Scope

ELnexu Consults Limited ("ELnexu", "we", "us", or "our") is a Central Bank of Nigeria (CBN)-licensed Super Agent providing tailored payment solutions, including agency banking services, merchant services, POS device provisioning, fund transfers, bill payments, and related financial technology services.

We are committed to protecting your privacy in accordance with:

• Nigeria Data Protection Act (NDPA) 2023
• Nigeria Data Protection Regulation (NDPR) 2019
• CBN Guidelines for Agent Banking Operations
• CBN Cybersecurity Framework
• CBN Consumer Protection Framework
• NDPC Regulations and Standards
• Money Laundering (Prohibition) Act 2022
• Terrorism (Prevention and Prohibition) Act 2022
• NFIU Act and Directives
• All applicable Nigerian laws and regulations

2. Data Controller and Data Protection Officer

We have appointed a Data Protection Officer (DPO) in compliance with Section 32 of the NDPA 2023.

DPO Email: [email protected]

3. Personal Data We Collect

• Identity and Verification Data
• Contact Information
• Financial and Transaction Data
• Device and Technical Data
• Communication and Support Data
• Employment and Recruitment Data

4. How We Collect Your Data

• Directly from you
• Automatically through our platforms and devices
• From authorised third parties for KYC and compliance purposes

5. Legal Basis for Processing

• Consent
• Contractual Necessity
• Legal and Regulatory Obligation
• Legitimate Interest
• Public Interest

6. How We Use Your Data

• Service Delivery
• Regulatory Compliance
• Security and Fraud Prevention
• Business Operations and Improvement
• Marketing (with consent only)

7. Data Sharing and Disclosure

• Principal Banks and Financial Institutions
• Payment Processors and Switches
• Regulatory and Supervisory Bodies
• Identity Verification Providers
• Technology and Cloud Service Providers
• Professional Advisors
• Law Enforcement Agencies

We do not sell, rent, lease, or trade your personal data.

8. Cross-Border Data Transfers

Where it becomes necessary to transfer your data outside Nigeria, ELnexu Consults Limited ensures compliance with Section 43 of the NDPA 2023 and applicable safeguards.

9. Data Retention

We retain personal data only for as long as necessary to fulfil legal, regulatory and operational requirements.

10. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to improve user experience and website functionality.

11. Data Security

• AES-256 Encryption
• TLS 1.3 Secure Transmission
• Role-Based Access Controls (RBAC)
• Multi-Factor Authentication (MFA)
• PCI-DSS Compliant Environments
• Geo-Fencing for POS Devices
• Vulnerability Assessments and Penetration Testing

12. Your Rights as a Data Subject

• Right of Access
• Right to Rectification
• Right to Erasure
• Right to Restrict Processing
• Right to Data Portability
• Right to Object
• Right to Withdraw Consent

13. Children's Data

Our services are not directed at individuals under the age of 18.

14. Data Protection Impact Assessment (DPIA)

ELnexu Consults Limited conducts DPIAs before high-risk processing activities.

15. Data Protection Compliance Audit

We submit annual Data Protection Compliance Audit Returns to the NDPC.

16. Data Breach Notification

In the event of a reportable breach, we will notify the NDPC within 72 hours and affected data subjects where required.

17. Third-Party Links

Our platforms may contain links to third-party websites. We are not responsible for their privacy practices.

18. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our operations or legal obligations.

19. Complaints

• Nigeria Data Protection Commission (NDPC)
• Central Bank of Nigeria (CBN)

20. Contact Us