This Privacy Policy explains how Doorade collects, uses, stores, and protects Personal Data in connection with the Services, in accordance with the Nigeria Data Protection Act 2023 (NDPA) and applicable regulations issued by the Nigeria Data Protection Commission (NDPC).
1. Data We Collect
- Identity data: name, date of birth, government ID, BVN, photograph, and biometric data collected for KYC purposes
- Business data: CAC registration details, TIN, beneficial ownership information, trade and import/export documentation
- Financial data: Transaction history, Wallet balances, payment instructions, and bank account details
- Technical data: device identifiers, IP address, log-in activity, and usage data from the Platform
- Communications data: support messages, including WhatsApp and email correspondence with Doorade
2. Lawful Basis for Processing
Doorade processes Personal Data on the basis of: performance of the contract between you and Doorade; compliance with a legal obligation (including AML/CFT and CBN requirements); your consent, where required (for example, for biometric identity verification); and Doorade's legitimate interests in preventing fraud and operating the Platform securely, balanced against your rights.
3. How We Use Personal Data
- To verify your identity and perform KYC/AML checks
- To process Transactions and provide the Services
- To detect, investigate, and prevent fraud and financial crime
- To comply with reporting obligations to the CBN, NFIU, and other regulators
- To communicate with you about your Account and Transactions
- To improve and develop the Platform
4. Sharing of Personal Data
Doorade may share Personal Data with licensed banking and payment partners, correspondent banks, cloud service providers, compliance and identity-verification vendors, professional advisers, regulators, and law enforcement agencies, in each case only to the extent necessary for the purposes described in this Policy.
5. International Data Transfers
Where Personal Data is transferred outside Nigeria (for example, to a cloud provider or a correspondent bank involved in processing a cross-border payment), Doorade will ensure the transfer takes place under a mechanism recognized by the NDPA, such as an adequacy decision, contractual safeguards, or another lawful transfer mechanism.
6. Data Retention
Doorade retains Personal Data for as long as your Account remains active, and thereafter for the period required by the CBN, the Money Laundering (Prevention and Prohibition) Act 2022, and other Applicable Laws, after which it is securely deleted or anonymized.
7. Your Rights
Subject to the NDPA, you have the right to request access to, correction of, or deletion of your Personal Data, to object to certain processing, and to withdraw consent where processing is based on consent (without affecting the lawfulness of processing carried out before withdrawal). Requests can be made to hello@doorade.com.
8. Security
Doorade applies commercially reasonable technical and organizational measures, including encryption, access controls, and monitoring, to protect Personal Data. No system can guarantee absolute security, and you should also take the precautions described in Section 15 (Cybersecurity and Fraud Allocation) of the Terms and Conditions.