Last Updated: October 16, 2025

1. Introduction

KINEMPAY ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform and services. Please read this policy carefully to understand our practices regarding your personal data.

2. Information We Collect

2.1 Personal Information You Provide

• Full name
• Email address
• Phone number
• Password (encrypted)
• Transaction recipient details (phone numbers, meter numbers, smartcard numbers)

2.2 Payment Information

• Payment card details (processed securely by Flutterwave - we do not store full card details)
• Transaction history and amounts
• Wallet balance information
• Bank account details (if provided for verification purposes)

2.3 Automatically Collected Information

• IP address
• Browser type and version
• Device information (type, operating system)
• Log data (access times, pages viewed, errors encountered)
• Cookies and similar tracking technologies
• Location data (with your permission)

2.4 Transaction Information

• Transaction type (airtime, data, electricity, cable TV)
• Transaction amount and date
• Transaction status and reference numbers
• Service provider details

3. How We Use Your Information

We use the collected information for the following purposes:

• To process your transactions and deliver requested services
• To create and manage your account
• To send transaction confirmations and receipts
• To provide customer support and respond to inquiries
• To detect and prevent fraud and security threats
• To improve our services and user experience
• To send promotional offers and updates (with your consent)
• To comply with legal obligations and regulatory requirements
• To analyze usage patterns and platform performance
• To personalize your experience on our platform

4. Legal Basis for Processing (NDPR Compliance)

Under the Nigeria Data Protection Regulation (NDPR), we process your personal data based on:

• Consent: You have given explicit consent for processing your data
• Contract: Processing is necessary to fulfill our service agreement with you
• Legal obligation: We are required by law to process certain data
• Legitimate interests: Processing is necessary for our business operations while respecting your rights

5. How We Share Your Information

We may share your information with:

5.1 Service Providers

• Payment processors (Flutterwave)
• Network providers (MTN, Airtel, Glo, 9mobile)
• Cable TV providers (DStv, GOtv, Startimes)
• Electricity distribution companies
• API service providers (Nellobytesystems)

5.2 Legal Requirements

• Law enforcement agencies when required by law
• Regulatory bodies (NITDA, CBN, NCC)
• Courts or tribunals pursuant to legal proceedings

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to the same privacy protections.

6. Data Security

We implement robust security measures to protect your data:

• SSL/TLS encryption for data transmission
• Encrypted storage of sensitive information
• Secure password hashing (bcrypt)
• Regular security audits and updates
• Access controls and authentication mechanisms
• Firewall protection and intrusion detection systems
• Regular backups and disaster recovery procedures

However, no method of transmission over the internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

7. Data Retention

• Account information: Retained while your account is active
• Transaction records: Retained for 7 years for legal and accounting purposes
• Support communications: Retained for 3 years
• Marketing data: Until you withdraw consent or request deletion
• Log data: Retained for 90 days for security purposes

8. Your Privacy Rights

Under NDPR and other applicable laws, you have the right to:

• Access: Request a copy of your personal data we hold
• Rectification: Request correction of inaccurate or incomplete data
• Erasure: Request deletion of your data (subject to legal obligations)
• Restriction: Request limitation of processing in certain circumstances
• Data portability: Receive your data in a structured, commonly used format
• Objection: Object to processing based on legitimate interests
• Withdraw consent: Withdraw consent for marketing communications at any time
• Lodge a complaint: File a complaint with NITDA if you believe your rights have been violated

To exercise these rights, contact us at support@kinempay.com with your request.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Maintain your session and keep you logged in
• Remember your preferences and settings
• Analyze platform usage and performance
• Provide personalized content and advertisements

You can control cookies through your browser settings. However, disabling cookies may affect the functionality of our platform.

10. Third-Party Links

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

11. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected data from a child, please contact us immediately for deletion.

12. Marketing Communications

• We may send promotional emails about new services, offers, and updates
• You can opt-out of marketing emails by clicking "unsubscribe" in any promotional email
• We will continue to send transactional emails (receipts, account notifications) even if you opt-out of marketing
• SMS notifications about transactions and account security will continue regardless of marketing preferences

13. International Data Transfers

Your data is primarily stored and processed in Nigeria. If we transfer data outside Nigeria, we will ensure adequate safeguards are in place to protect your information in compliance with NDPR requirements.

14. Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant authorities (NITDA) within 72 hours of becoming aware of the breach, as required by NDPR.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by:

• Posting the updated policy on our website
• Sending an email notification to registered users
• Displaying a notice on the platform

Your continued use of KINEMPAY after changes constitutes acceptance of the updated policy.

16. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

• Email: admin@kinemlabs.com
• Phone: +234 901 967 3953
• Address: 29 Adewumi Layout, Ibadan North, 200132, Oyo, Nigeria
• Data Protection Officer: dpo@kinemlabs.com

17. Regulatory Compliance

KINEMPAY is committed to complying with:

• Nigeria Data Protection Regulation (NDPR) 2019
• Nigeria Data Protection Act (NDPA) 2023
• Guidelines and directives from the National Information Technology Development Agency (NITDA)
• Central Bank of Nigeria (CBN) regulations on electronic payments