Privacy policy

Who we are

zillipay is run by SOYSTEK LTD, a company registered in Nigeria (RC 7863262). Our registered office is Suite D15B, Emab Plaza, Aminu Kano Crescent, Abuja, FCT, Nigeria.

SOYSTEK LTD decides how and why your personal information is used in zillipay. In data protection terms, we are the data controller.

Your account number, wallet and payments are provided through Fincra and its partner banks. SOYSTEK LTD is not a bank. Fincra and the banks are regulated financial service providers with their own legal duties, so they also handle some of your information under their own privacy notices. "Who we share it with" explains this.

Questions about privacy: email contact@zillipay.com.

Who can use zillipay

• You must be at least 18 years old.
• zillipay is for people who live in Nigeria and have a Bank Verification Number (BVN).

We do not knowingly collect information from anyone under 18. If we learn that we have, we will close the account and delete what the law allows us to delete.

Information you give us

• Account details. Your first, middle and last name, email address, phone number, date of birth, country and password.
• Identity checks. Your BVN and home address. If you verify with an ID document, the document type (NIN, international passport, driver's licence or voter's card) and its number.
• Business details. For a business account: the business name, email, phone number and address, its Corporate Affairs Commission (CAC) number, and the director's full name and BVN.
• Your zilli_tag. The name other people can use to pay you.
• Your transaction PIN. Used to confirm payments and sign-ins on your device.
• Payment details. The bank account, amount and note for each payment you make.
• Support messages. Anything you send us by email, including complaints and deletion requests.

Information we create when you use zillipay

• Account number and wallet. Your naira account number, bank name, balance and verification status.
• Transactions. Deposits, transfers and payments to a zilli_tag: names and bank details of the people you pay or who pay you, amounts, fees, references, dates and status.
• Business activity. Payment approvals, autopay settings and their history, limits, blocked banks, notices, and the history of changes made on the business account.
• Device and security records. An ID we create for each app install, your sign-in sessions, and whether the device is an iPhone or Android phone. We count failed sign-in and PIN attempts for a short time to lock out guessing. Technical logs can include the IP address a request came from.
• Verification codes. We keep only a scrambled form (a hash) of each code, and a code stops working after 15 minutes.
• Notification records. Your push notification token, and a record of the emails, SMS and push notifications we sent you: when, how, the subject or title, and only part of your email address or phone number. These records do not contain the message text or any code.
• Account freezes. If your account is frozen, we keep a record of the freeze: when it happened, who froze or unfroze it (you or a zillipay staff member), the type (lost phone, suspected fraud, your request, or compliance) and the reason.

Information from other services

• Google or Apple sign-in. If you sign in with Google or Apple, we receive an account ID from that service and the email address it shares with us. With Apple, this can be a private relay address. For Apple, we also keep a token, encrypted, so we can cancel the link with Apple when you delete your account. We never receive your Google or Apple password.
• Fincra and banks. The account number issued to you, the status of your payments, the name on a bank account you are about to pay, and, for money you receive, the sender's name and bank and the payment note.
• Public blockchains (business accounts, optional). If you ask us to watch a USDT wallet address, we read the incoming transfers to that address from the public blockchain.
• Connected apps (business accounts, optional). If you connect an app to your business, we keep a record of the connection, the permissions you approved, and the requests the app makes, such as payouts and trades.
• Bybit (invited business accounts only). See "Bybit" below.

What we do not collect

• We do not show ads, and we do not track you across other companies' apps or websites.
• We do not sell your personal information.
• We do not read your contacts, photos or location.
• Face ID and fingerprint checks happen on your phone. We never receive your face or fingerprint data.
• The camera is used only to scan a QR code when you connect an app to your business. We do not save camera images.

How we use your information and why we are allowed to

The Nigeria Data Protection Act 2023 lets us use personal information only on a lawful basis. This is what we use it for, and the basis for each use:

• To open and run your account, sign you in, make and receive payments, show your history and receipts, and run business features you choose, such as approvals, autopay, connected apps and Bybit. Basis: our contract with you.
• To check your identity, keep records and report to authorities as anti-money laundering and financial services law requires. Our team reviews identity checks by hand today. We share your details with Fincra so it can issue your account number. Basis: our legal obligations.
• To send verification codes, receipts, alerts and service messages by email, SMS and push notification. Basis: our contract with you.
• To keep your account and our systems secure, prevent fraud, and find and fix errors. Basis: our legitimate interest in a safe, working service, and our legal obligations where the law requires it.
• To answer your questions, complaints and requests. Basis: our contract with you and our legal obligations.
• Phone permissions such as notifications, camera and Face ID are your choice. You can turn them off in your phone settings at any time; the feature that needs them then stops working.

We do not send marketing messages. If we ever want to, we will ask you first and you will be able to stop them at any time. Where we rely on your consent, you can withdraw it at any time; this does not affect what we did before.

If we want to use your information for a new purpose that is not covered here, we will tell you first, and ask for your consent where the law requires it.

Automatic checks and decisions

Some things in zillipay happen automatically, following fixed rules. We do not use scoring or profiling to make decisions about you.

• Payments over your limit are refused. Personal limits depend on your verification level. Business limits are the ones you set within our maximums.
• For business payouts: blocked banks, your autopay mode and your limits, including night limits between 11pm and 8am Lagos time, decide whether a payout goes ahead, waits for your approval or is refused.
• When a connected app tells us the name it expects on a bank account, we compare it with the name the bank gives. If they do not match, the payout is refused.
• Too many wrong passwords, PINs or codes lock that sign-in for a short time.
• If an identical bank transfer is still waiting for a bank result, we refuse a repeat for up to 24 hours so you are not charged twice.

Our team, not a computer, decides on identity checks and account closures. If an automatic check affects you and you think it is wrong, email contact@zillipay.com and a person will review it.

Who we share it with

Payment providers with their own duties. These organisations receive information to provide the payment service, and also have their own legal duties, such as identity checks, fraud prevention and record keeping. They handle that information under their own privacy notices.

• Fincra and its partner banks: account numbers, wallets, deposits and transfers. We share your name, email address and BVN. For a business, we share the business name and email address, the director's BVN and the name on it. For each payment, we share the amount, the recipient's bank details and name, and the note.
• Receiving banks and payment networks: what is needed to complete a transfer you make, including the payer name the recipient sees.

Service providers acting for us. These providers process information only to provide their service to us, on our instructions.

• DigitalOcean: hosts our servers and databases.
• Mailgun: sends our emails.
• Termii: sends our SMS messages, such as verification codes.
• Expo: passes push notifications to Apple and Google for delivery. Expo receives your push token and the notification text, and does not keep the text after sending.
• Apple and Google: deliver push notifications to iPhones and Android phones.
• Grafana Labs: monitors the health of our systems. This includes technical logs.
• Public blockchain data services (TronGrid and PublicNode): only if you ask us to watch a USDT address. They receive the address we look up.

Services you choose to use. These have their own terms and privacy notices, which apply to what they receive.

• Google or Apple sign-in, if you choose it.
• Connected apps, such as Sendam, if you connect them to your business. See "Connected apps" below.
• Bybit, if your business is invited and connects its Bybit account. See "Bybit" below.

We also share information when the law requires it, for example with the Central Bank of Nigeria, the Nigerian Financial Intelligence Unit, a court or the police, or to protect you, other users or us from fraud.

We do not share your information with advertisers or data brokers.

Connected apps

A business owner can connect another app to the business, such as Sendam. The app shows a code, and you approve it in zillipay with your PIN. The app gets only the permissions you see on the approval screen:

• See the business: the business name, its zillipay ID and verification status, its balance, deposits (including each sender's name and bank, the amount and the payment note), payouts (including each recipient's name and bank details), trades, watched USDT transfers and, if Bybit is connected, its Bybit orders and advert. The app also receives a message each time one of these changes.
• Trades: create and manage trades, and check the name on a bank account.
• Payouts: ask for payouts from the business balance. Your autopay mode and limits decide what happens to each request.
• Adverts: ask to publish or change your Bybit P2P advert (each change waits for your PIN) and take it offline.

The connected app is responsible for how it uses and keeps what it receives, under its own terms and privacy policy. We are responsible for sending it only what you approved, and for keeping the connection secure.

You can disconnect an app at any time under Connected apps. It loses access to your business straight away and stops receiving messages. Payouts from that connection waiting for approval or still queued are stopped. Payments already being sent can still finish. If the outcome is unclear, we keep checking the existing payment rather than sending it again. Information the app already received stays with the app. We keep our records of the connection as transaction records.

Bybit

Bybit features are available only to business accounts we invite. Most zillipay users never use them. Bybit is a separate company and is not part of zillipay.

If an invited business connects its Bybit account, it creates an API key and secret on Bybit and gives them to us. We encrypt the key and secret before we store them and use them only to contact Bybit for that business. We also keep the last 4 characters of the key, so you can recognise it.

• From Bybit we receive your Bybit user ID, nickname and verified name, your P2P payment methods and adverts, and your P2P orders.
• Each order includes the other person's details: their Bybit nickname and name, their bank, and the last 4 digits of their account. For an order where you buy, it also includes the name, bank and last 4 digits of each account the seller can be paid to. These people are not zillipay users. We use their details only to match and record the order.

Imported orders are deleted 180 days after Bybit created them. Pausing Bybit keeps your key. Removing the key, deleting your account, or Bybit telling us the key is invalid, expired or has the wrong permissions erases it.

Where your information is processed

Our servers and databases are hosted by DigitalOcean in New York, United States. Our requests to Bybit and to Fincra go out through a DigitalOcean server in Frankfurt, Germany, so that they come from one fixed address.

Fincra and its partner banks are in Nigeria. Mailgun sends our emails from the United States. Expo is based in the United States. Grafana Labs, Termii, Apple and Google may process information in the United States, the European Union or other countries.

When we send information outside Nigeria, we do so on a ground the Nigeria Data Protection Act 2023 allows, for example because it is needed to provide the service you asked for. You can ask us which ground and safeguards apply to a provider.

How long we keep it

We keep information only as long as we need it for the reason we have it. While your account is open, we keep what we need to run it. These periods apply:

• Transaction records: payments, payouts, deposits, trades, approvals, autopay settings history and actions taken on Bybit for you. We keep them for 5 years after your account is closed. Nigerian anti-money laundering law requires records of each transaction for at least 5 years after it is completed, so this covers every transaction on the account.
• Identity check records: your BVN, ID document details, address, our review decisions and, for a business, its registration details and the director's name. We keep them for 5 years after your account is closed, as the same law requires for customer identification records after a customer relationship ends.
• Imported Bybit orders (invited businesses only): 180 days after Bybit created the order, whether or not your account is still open. A trade or payout we made for an order is a transaction record and is kept as above.
• Account freeze records: records of account freezes and unfreezes. We keep them for 5 years after your account is closed, with your other compliance records.
• Security and delivery records: records of the emails, SMS and push notifications we sent (with only part of your email address or phone number), and the record of your deletion request. We keep them for up to 2 years after your account is closed.
• Technical logs in our monitoring service: deleted automatically after a short rolling period, currently about two weeks.
• Support emails: 1 year after the conversation ends. If an email is part of a complaint, a dispute or a record the law requires, we keep it with that record instead.
• Everything else, including your profile details, password and PIN records, zilli_tag, Google or Apple sign-in link, push notification token, connected-app keys and Bybit key: deleted or made anonymous within 7 calendar days after we verify your deletion request.

When a period ends, we delete the information or make it anonymous.

Our database backups are kept by DigitalOcean for a short period and then replaced, so deleted information can remain in a backup until it is replaced. We do not use backups to bring back information that was deleted. If we ever have to restore a backup after a fault, we will reapply completed deletion requests and expired retention periods before reopening access.

We may keep information for longer only where the law, a court, a regulator, an investigation or a dispute requires it, and only for that purpose.

Copies held for us by our service providers are deleted or expire under their own settings and terms. Fincra, banks, Apple, Google, Bybit and connected apps keep what they received under their own rules.

Deleting your account

In the app, go to Profile > Delete account and confirm with your PIN. If you cannot use the app, email contact@zillipay.com from the email address on your account and we will help you.

• We email you when we receive the request. A zillipay admin then checks that it really comes from you.
• We complete the deletion within 7 calendar days after we verify the request, and email you when it is done.
• We cannot delete an account that still has money in it, payments still being processed, payouts waiting for approval, or open trades or Bybit orders. The app shows you what needs to be sorted first. Move any balance to a bank account in your name before you ask.
• You can cancel the request until we start deleting.
• Deleting signs you out on every device and removes your PINs. Connected apps lose their access, autopay is turned off and any Bybit key is erased.
• We keep the records described under "How long we keep it" in our privacy policy, for the periods shown there.
• Deleting the app from your phone does not delete your account.

Your choices

You can freeze your account at any time in the app (Profile > Security > Freeze my account). This signs out every device and stops sign-in and outgoing payments until zillipay support unfreezes it.

Your rights

Under the Nigeria Data Protection Act 2023, you can ask us to:

• tell you what personal information we hold about you and give you a copy
• correct information that is wrong or incomplete
• delete your information
• stop or limit how we use it, or object to a use based on our legitimate interests
• send your information to you or another company in a common format
• have a person review a decision made automatically

To make a request, email contact@zillipay.com. We will acknowledge it within 2 working days and aim to reply within 14 days. We may need to confirm it is you first. We do not charge for a request unless it is clearly unfounded or excessive.

The law may require us to keep some information after you ask us to delete it. "How long we keep it" above explains what and for how long.

You can also complain to the Nigeria Data Protection Commission (ndpc.gov.ng).

Keeping your information safe

• All connections between the app and our servers use HTTPS.
• Your password and PIN are stored only in a scrambled form (a hash). Verification codes are stored the same way.
• Your BVN, ID document numbers, Bybit API key and secret, and connected-app keys are encrypted before we store them.
• Admin tools are limited to authorised staff.
• If a breach puts your information at risk, we will tell the Nigeria Data Protection Commission and, where the risk to you is high, tell you, as the law requires.

Enter your password, PIN and verification codes only in the zillipay app. zillipay staff will never ask you for them by email, phone, chat or in person, and never need them to help you. Never send them to anyone, including us.

Changes to this policy

We may update this policy. We will change the date at the top of the page. If a change is important, we will tell you in the app or by email before it takes effect.

Contact us

Email contact@zillipay.com, or write to SOYSTEK LTD, Suite D15B, Emab Plaza, Aminu Kano Crescent, Abuja, FCT, Nigeria.