Effective Date: 30th April, 2025

1. Introduction

At SwiftXchange, we are committed to protecting your privacy and ensuring the security of your personal information.

As a digital asset and gift card trading company operating in Nigeria and other jurisdictions, SwiftXchange collects, processes, and stores personal data to provide our services effectively and comply with legal obligations.

This Privacy Policy explains how SwiftXchange collects, uses, shares, and protects your personal information. It also outlines your rights regarding your data and how you can exercise those rights. By using SwiftXchange’s platform, you consent to the practices described in this policy.

2. Scope of This Policy

This Privacy Policy applies to all users of SwiftXchange’s services, including customers, partners, and visitors to our website. It covers all personal data collected through:

• Our website (www.swiftxchange.ng).
• Mobile applications.
• Customer support interactions.
• Third-party integrations and partnerships.

This policy does not apply to third-party platforms or services that may be linked to SwiftXchange. We encourage you to review the privacy policies of those third parties before providing any personal information.

3. Information We Collect

SwiftXchange collects the following types of information:

a. Personal Information

Identity Information: Name, date of birth, gender, and government-issued identification documents (e.g., national ID card, international passport, or driver’s license).

Contact Information: Email address, phone number, and residential address.

Financial Information: Bank account details, payment card information, and transaction history.

Biometric Data: In some cases, we may collect biometric data (e.g., fingerprints or facial recognition) for identity verification.

b. Technical Information

Device Information: IP address, browser type, operating system, and device identifiers.

Usage Data: Pages visited, time spent on the platform, and interactions with our services.

Location Data: Approximate geographic location based on IP address or GPS data (if enabled).

c. Other Information

Customer Support Interactions: Records of communications with our support team.

Survey and Feedback Data: Responses to surveys or feedback forms.

4. How We Use Your Information

SwiftXchange uses your personal information for the following purposes:

a. Service Delivery

• To create and manage your account.
• To process transactions, including digital asset trades and gift card exchanges.
• To verify your identity and comply with legal obligations.

b. Customer Support

• To respond to your inquiries and resolve issues.
• To provide technical assistance and troubleshooting.

c. Security and Fraud Prevention

• To detect and prevent fraudulent activities.
• To monitor and protect the security of our platform.

d. Marketing and Communication

• To send you promotional offers, newsletters, and updates (with your consent).
• To notify you about changes to our services or policies.

f. Legal and Regulatory Compliance

• To comply with Nigerian laws, including the Money Laundering (Prohibition) Act 2022 and the Central Bank of Nigeria (CBN) guidelines.
• To respond to legal requests and enforce our terms of service.

g. Analytics and Improvement

• To analyze user behavior and improve our services.
• To conduct research and develop new features.

5. Legal Basis for Processing Personal Data

SwiftXchange processes your data based on the following legal grounds:

• Consent: When you provide explicit consent for specific purposes, such as marketing communications.
• Contractual Necessity: To fulfill our obligations under the terms of service.
• Legal Obligations: To comply with applicable laws and regulations.
• Legitimate Interests: To improve our services, prevent fraud, and ensure the security of our platform.

6. Sharing Your Information

SwiftXchange may share your personal information with the following parties:

a. Service Providers

• Payment processors, cloud storage providers, and IT support companies.
• Identity verification and fraud prevention services.

b. Regulatory Authorities

• Nigerian Financial Intelligence Unit (NFIU), Economic and Financial Crimes Commission (EFCC), and Central Bank of Nigeria (CBN).
• Law enforcement agencies in response to legal requests.

c. Business Partners

• Third-party platforms integrated with SwiftXchange’s services.
• Marketing and advertising partners (with your consent).

d. Affiliates and Subsidiaries

• Companies within the SwiftXchange group for operational and administrative purposes.

7. Data Security

SwiftXchange implements robust security measures to protect your personal information, including:

• Encryption of data in transit and at rest.
• Multi-factor authentication (MFA) for account access.
• Regular security audits and vulnerability assessments.
• Employee training on data protection best practices.

Despite these measures, no system is completely secure. We encourage you to take steps to protect your account, such as using strong passwords and enabling MFA.

8. Data Retention

SwiftXchange retains your personal information for as long as necessary to fulfill the purposes outlined in this policy or as required by law. Retention periods may vary depending on the type of data and legal obligations. For example:

• Transaction records are retained for at least five years to comply with Nigerian AML regulations.
• Marketing data is retained until you withdraw your consent or opt-out.

9. Your Rights and Choices

Under Nigerian data protection regulations, you have the following rights regarding your data:

a. Access

• You can request a copy of the personal data we hold about you.

b. Rectification

• You can request corrections to inaccurate or incomplete data.

c. Erasure

• You can request the deletion of your data, subject to legal obligations.

d. Restriction

• You can request restrictions on how we process your data.

e. Objection

• You can object to the processing of your data for specific purposes, such as marketing.

f. Data Portability

• You can request a transfer of your data to another service provider.

To exercise these rights, please contact us at help@swiftxchange.ng

10. International Data Transfers

SwiftXchange may transfer your data to third parties located outside Nigeria. In such cases, we ensure that adequate safeguards are in place to protect your data, such as standard contractual clauses or binding corporate rules.

11. Cookies and Tracking Technologies

SwiftXchange uses cookies and similar technologies to enhance your experience on our platform. Cookies are small text files stored on your device that help us:

• Remember your preferences.
• Analyze user behavior.
• Deliver targeted advertisements

You can manage your cookie preferences through your browser settings or our cookie consent tool.

12. Third-Party Links and Services

Our platform may contain links to third-party websites or services. SwiftXchange is not responsible for the privacy practices or content of these third parties. We encourage you to review their privacy policies before providing any personal information.

13. Children’s Privacy

SwiftXchange does not knowingly collect or process personal data from individuals under the age of 18. If we become aware that we have collected data from a minor, we will take steps to delete it promptly.

14. Nigerian Data Protection Regulations

SwiftXchange complies with the Nigerian Data Protection Regulation (NDPR) 2019, which governs the collection, processing, and storage of personal data in Nigeria. Our practices are designed to ensure transparency, accountability, and user control over personal data.

15. Updates to This Policy

SwiftXchange may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of significant updates through email or our platform. Your continued use of SwiftXchange’s services constitutes acceptance of the updated policy.

16. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Email: help@swiftxchange.ng

Phone:+2347013801253