Privacy Policy

Who we are

This Privacy Policy explains how rtemmy.com.ng (“we”, “us”, “our”), operated by RTEMMYTECH of No 326, Agbokojo street, Oke-bola road, Ibadan , collects, uses, shares and protects your personal data when you use our website, dashboard, mobile web app and API (together, the “Platform”).

We are the data controller for the personal data described here. We process personal data in line with the Nigeria Data Protection Act 2023 (“NDPA”) and the regulations and guidance issued by the Nigeria Data Protection Commission (“NDPC”). By creating an account or using the Platform, you acknowledge this policy.

Personal data we collect

• Account data: full name, phone number, email address, password (stored in hashed form) and referral details.
• Transaction data: the services you buy, beneficiary details (phone numbers, meter numbers, smartcard or IUC numbers), amounts, wallet balances, references and the responses we receive from service providers.
• Wallet funding data: amount, payment reference, sender name and bank details shown on a transfer. We do not store your full card number or card PIN.
• Identity service data: where you use NIN or BVN services, the NIN, BVN, names, date of birth, phone number, address and any supporting documents (such as an affidavit or attestation) that you submit.
• Device and usage data: IP address, browser and device type, pages visited, log data and cookies.
• Communications: messages you send to our support team, including through WhatsApp.
• API data: for API users, request logs and activity linked to your API token.

How we use your data and why

We use your personal data only for the purposes below, relying on the legal basis shown:

• Provide the services you request, including processing purchases and funding your wallet (performance of a contract).
• Verify your identity and prevent fraud, money laundering and abuse (legal obligation and our legitimate interests).
• Provide support and resolve complaints and disputed transactions (contract and legitimate interests).
• Keep the Platform secure and improve its performance and features (legitimate interests).
• Send service messages such as receipts, alerts and security notices (contract and legitimate interests).
• Send promotions only where you have agreed to receive them. You can opt out at any time (consent).
• Comply with the law, including tax, anti-money laundering and requests from lawful authorities (legal obligation).

NIN and BVN information

Your NIN and BVN are sensitive and tightly linked to your identity. We process them only to carry out the service you ask for, and we limit access to staff and partners who need it for that purpose. We do not use them for marketing and we do not sell them.

If you submit a NIN, BVN or other personal data belonging to another person, you confirm that you have that person’s consent or other lawful authority to do so.

Who we share data with

We do not sell your personal data. We share it only where needed to deliver the Platform:

• Service providers and partners: mobile network operators, electricity distribution companies, cable TV providers, exam bodies, payment processors and banks, and partners that help us deliver NIN and BVN services.
• Technology vendors: hosting, SMS, email, analytics and security providers who process data on our instructions.
• Authorities: regulators, law enforcement, courts and other bodies where we are required by law or must protect our rights or users.
• Business transfers: a successor, if we merge with or transfer our business, who must continue to protect your data under this policy.

Where we use processors, we require them to protect your data and use it only for the purposes we specify.

Transfers outside Nigeria

Some of our vendors or hosting facilities may be located outside Nigeria. Where we transfer personal data abroad, we do so only as permitted by the NDPA, for example to countries or organisations with adequate protection, or with appropriate safeguards in place.

How long we keep your data

We keep personal data only for as long as needed for the purposes above, including to meet legal, tax, accounting and anti-money-laundering requirements and to handle disputes. When it is no longer needed, we delete or anonymise it. Transaction records are normally kept for longer than other data because of these legal requirements.

Security

We use measures such as encrypted connections, hashed passwords, access controls and activity monitoring to protect your data. No system is completely secure, so please keep your password, transaction PIN and API token confidential.

If a data breach is likely to put your rights at risk, we will notify the NDPC and affected people within the time and in the manner the law requires.

Your rights

Under the NDPA you have the right to:

• be informed about how we use your data and to access a copy of it;
• have inaccurate or incomplete data corrected;
• request deletion of your data, where we have no lawful reason to keep it;
• restrict or object to certain processing, including direct marketing;
• receive your data in a portable format, where applicable;
• withdraw your consent at any time, without affecting earlier processing; and
• not be subject to a decision based solely on automated processing that significantly affects you.

To exercise these rights, contact us at rtemmycare@gmail.com. We may ask you to verify your identity first, and we will respond within the time required by law. Some data must be kept to meet legal obligations, so we may not be able to delete everything on request.

If you are not satisfied with how we handle your data, you may complain to the Nigeria Data Protection Commission (ndpc.gov.ng).

Cookies

We use essential cookies to keep you logged in, protect your session and remember basic preferences. We may also use limited analytics cookies to understand how the Platform is used. You can block or delete cookies in your browser settings, but parts of the Platform may not work without essential cookies.

Children

The Platform is for people aged 18 and over. We do not knowingly collect personal data from children. If you believe a child has given us personal data, contact us and we will delete it.

Links to other sites

The Platform may link to third-party sites or services, such as WhatsApp. We do not control them and are not responsible for their privacy practices. Please read their policies before sharing your data.

Changes to this policy

We may update this policy from time to time. We will post the new version on this page with a new “last updated” date and, for significant changes, give you additional notice. Continued use of the Platform after an update means you accept the revised policy.

Contact us

For privacy questions or requests, contact our Data Protection Officer / privacy contact at rtemmycare@gmail.com, by phone on 08061686338, or by post at No 326, Agbokojo street, Oke-bola road, Ibadan .