Built on Trust, Secured by Design

Effective Date: August 1, 2025

Last Updated: August 1, 2025

QASHR Technologies Ltd (“QASHR”, “we”, “us”, or “our”) is committed to protecting your personal data and respecting your privacy rights. This Privacy Policy outlines how we collect, use, store, disclose, and safeguard your information when you use our services, website, and mobile application.

1. Legal Basis for Data Collection

This Policy is in compliance with the Nigeria Data Protection Regulation (NDPR) and any other applicable laws within the Federal Republic of Nigeria. Where applicable, it aligns with international best practices including the General Data Protection Regulation (GDPR).

2. Information We Collect

We collect the following categories of personal and transactional information:

• a. Personal Identifiable Information (PII):
  • Full name
  • Phone number
  • Email address
  • BVN or NIN
  • Date of birth
  • Residential address
  • Government-issued ID (e.g., voter’s card, driver’s license, national ID)
• b. Device and Technical Data:
  • IP address
  • Device ID
  • Device type and OS
  • Browser type
  • Location data (if permitted)
• c. Transactional Data:
  • Wallet activity
  • Bank account details
  • Cash-in/cash-out history
  • P2P transaction metadata
  • SoftPOS payment records
• d. Behavioral and Usage Data:
  • Log files
  • In-app interactions
  • Ratings and feedback

3. How We Use Your Information

• To register and verify your identity (KYC)
• To provide our core services: P2P cash exchange, SoftPOS payments, escrow wallet
• To enable real-time liquidity matching
• To process payments and withdrawals
• To prevent fraud and comply with AML/CTF regulations
• To personalize your user experience
• To communicate service updates or marketing offers
• To meet legal, regulatory, and compliance requirements

4. Lawful Basis for Processing

• Consent: When you explicitly grant us permission
• Contract: Where processing is necessary to deliver the services
• Legal obligation: For KYC, AML, and regulatory compliance
• Legitimate interest: To improve our services and security systems

5. Data Sharing and Disclosure

We do not sell your personal information. However, we may share your data with:

• Licensed payment processors and financial institutions
• Identity verification partners (e.g., KYC providers like Dojah)
• Regulatory authorities (upon lawful request)
• Fraud detection agencies or law enforcement (if required by law)
• Internal service providers, subject to strict confidentiality agreements

6. Data Storage and Security

We store your information on secure servers located in Nigeria and/or within approved jurisdictions.

• We use encryption, firewalls, two-factor authentication, and access control
• Only authorized personnel can access sensitive data
• Regular audits and vulnerability assessments are performed

7. Data Retention

We retain your information only for as long as necessary:

• As required to fulfill the purpose for which it was collected
• As mandated by financial or legal obligations (typically 5–7 years)
• Upon account closure, data may be retained for dispute resolution, fraud prevention, or regulatory compliance

8. Your Rights (as a Data Subject)

Under the NDPR, you have the right to:

• Access your personal data
• Correct inaccurate or incomplete data
• Withdraw consent at any time
• Request deletion (where legally permissible)
• Restrict processing in specific situations
• Lodge a complaint with NITDA or the appropriate Data Protection Authority

You can exercise these rights by contacting us at: privacy@qashr.com

9. Cookies and Tracking Technologies

Our website and app may use cookies or similar technologies to:

• Analyze traffic and usage patterns
• Store user preferences
• Improve service performance

You may disable cookies through your browser settings, but this may affect functionality.

10. Children’s Privacy

QASHR is not intended for use by individuals under 18 years of age. We do not knowingly collect or store personal data from minors.

11. International Data Transfers

If data is transferred outside Nigeria, it will only be to countries with adequate data protection laws or under legally binding agreements, in compliance with NDPR guidelines.

12. Changes to This Policy

We may update this Privacy Policy from time to time. All changes will be communicated via in-app notification or email. Continued use of the platform implies your acceptance of the updated policy.

13. Contact Us

• Email: privacy@qashr.com
• Address: 8 Providence Street, Lekki Phase 1, Lagos, Nigeria
• Website: www.qashr.com