Nazzahub Technologies Ltd. (“Nazza”, “We”, “Our”, “Us”) owners of Nazza and other virtual assets products have provided this Privacy Notice to inform customers (“You”,“Your”) of the types of data we collect, how we collect your data, why we collect your data, how we protect your data, and your rights as a data subject. Nazza is an online platform where you can purchase, sell, and exchange virtual assets, fast and secure, with zero fees.
Last Updated: January 2024
We collect your data at different points of your interaction with our platform. For visitors on our platform, we collect cookie data in accordance with our Cookie Notice and log IP addresses of website visitors.
For our customers and prospective customers, we collect personal data when you are completing our initial sign-up and onboarding form. In some cases, we may allow you import relevant data from other exchanges to enable you to exercise your right to data portability and reduce sign-up time.
For our customers, we collect business information, purchase details, travel rule information, customer complaints etc. from your frequent interaction on our platform.
We use your data to comply with applicable regulations. For instance, the law requires us to properly identify our customers. We use the personal data you provide to us to identify you and your transactions on our platform. We may also share your data with relevant law enforcement agencies on request where backed by applicable law.
In certain instances, we may need to conduct fraud investigations on certain customers on our platform when we detect suspicious activity. This is to help us determine that your activity is not fraudulent and that you remain in full control of your account.
We use your data to provide services to you, respond to your enquiries, customer support, improve our services, and manage our relationship with you. For instance, your login information is personal data to you which only you may use to access our services.
We use your data such as fingerprint, phone number and email address. to verify that the person truly accessing your profile on our platform is truly yourself.
We rely on appropriate legal bases determined by our compliance team and documented in accordance with the extant data protection laws. In appropriate circumstances, the following are our lawful bases;
When you use our website, mobile application or any of our platforms through which we provide our service, you automatically agree to our Terms of Service. This is our contract with you and we would require your data at different intervals of the provision of our service to you.
For instance, we have to request personal data to complete your orders with us. We also need personal data to identify you and your activity on our platform and resolve any issues you may be encountering with the use of our platform.
We are required under different laws and financial regulations to collect, process, and store your data when you use our platform to access financial services. Some of these laws include the Money Laundering (Prevention and Prohibition) Act 2022, Securities and Exchanges Commission’s Anti-Money Laundering, Combatting the Financing of Terrorism and Countering Proliferation Financing (“AML/CFT/CPF”) Regulations, 2022.
Processing your data is necessary for our legitimate interests or the legitimate interests of a third party, provided those interests are not outweighed by your rights and interests. These legitimate interests include but is not limited to;
In each case, these legitimate interests are only valid if they are not outweighed by your rights and interests.
On rare occasions, where our processing activity is not covered by the lawful bases above, we may rely on your consent to process your data. Where this is the case, we will inform you and seek your consent before such processing activity.
You have the right to refuse to consent or withdraw your consent at any time by contacting us at support@mynazza.com. However, we should mention that consent withdrawal will not affect the lawfulness of any processing carried out before you withdraw your consent.
If we collect or process your data, you are a data subject by definition of law. However, we do not offer our platform or any of our services to persons below 18. If at any point we discover we have provided our service to any person below 18, we will remove the personal data of such person and exit the customer. Tips or complaints related to this provision may be made compliance@mynazza.com
You have data protection rights. Loads of it actually. The following are your rights:
We do not store cookies or allow third-party requests on our website.
To exercise any of your rights as a data subject, you may contact us directly via email or complete our data subject access request form on our privacy portal. We will review and respond to your request within thirty (30) days of receipt. We also respond to subject access requests from third parties provided we are able to validate the request in accordance with our internal privacy policy.
We retain your data for the duration of the pendency of our relationship. However, we will also retain data, subject to relevant provisions of applicable laws. One of such law is the Nigerian Money Laundering Act 2022 which requires us to retain your data for at least five (5) years after the termination of our business relationship.
Upon the termination of our relationship, we would archive and stop actively using any personal data about you within 6 months from the last time of our relationship unless required for compliance purposes, to defend a legal issue or with your consent.
The Data Protection Officer may grant exceptions to certain sections of this policy having regard to factors including applicable law, inherent risk, residual risk, potential recurrence, proportionality, and such other factors prescribed by international standards for situations similar to that under review. The exceptions shall be well documented and the risk shall be explained to senior management and accepted before being granted.
We are very particular about preserving your privacy and protecting your data. Therefore, to avoid the loss, theft, misuse and unauthorised access, disclosure, alteration, and destruction of your information, we have put in place a range of technical and organizational measures. We briefly highlight some of these measures below;
Data Encryption
We use encryption technologies to protect your data during transmission and storage, ensuring that unauthorized parties cannot access or intercept it.
Access Controls
Our systems incorporate strict access controls, ensuring that only authorized personnel have access to your personal information based on a need to know and need to use.
Regular Security Audits
We are on course to implement regular security audits and assessments to identify and address potential vulnerabilities in our systems and infrastructure.
Incident Response Plan
In the event of a data breach or security incident, we have a well-defined incident response plan in place to minimize the impact and notify relevant authorities and individuals promptly.
Employee Training
Our employees undergo periodic data protection training to ensure they understand the importance of data protection and are equipped to handle personal information responsibly.
Data Protection Contact (DPC)
We have appointed a Data Protection Contact who oversees our data protection practices, ensures compliance, and acts as a point of contact for data subjects and supervisory authorities.
Privacy by Design
We integrate privacy considerations into our product and service development processes from the outset, adhering to the principle of privacy by design.
Data Minimization
We only collect and process the personal data necessary for the specific purposes outlined in this Privacy Notice, practicing data minimization principles.
Security of your data requires joint efforts from yourself and Nazza, Despite our organisational and technical measures, we cannot completely guarantee the security of any information you transmit via our online channels, as the internet is not an entirely secure place. As such, we encourage you to keep your sensitive information such as your login information private.
Additionally, due to the nature of the blockchain, your transaction history may be visible to any person aware of your wallet address or transaction hash. Where you have reasons to believe your wallet address has been compromised, you may contact us for a change of wallet address. However, we can not always guarantee the creation of a new wallet address unless such request is backed by cogent and credible information. The decision to approve a new wallet address shall be solely at the discretion of the compliance officer.
We will continually assess our data protection practices to ensure that your rights are guaranteed. To this end, we may amend this Privacy Notice at any time. In the event that changes are made, we will indicate at the top of this Privacy Notice when it was most recently updated or send you a notification that the Notice has been updated.
Please be assured that we will not use any previously collected personal data, to the extent that it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected.
No. 14D, Sheri Hills Cres. Imperial Vista Estate, Life Camp, Abuja compliance@mynazza.com
We will never spam you or sell your information.
