Privacy Policy

1.1 Information you provide to us

• Phone number - account identifier, login, and OTP verification.
• Name - personalising your account and support.
• Email address - account verification, receipts, and service notices.
• Transaction PIN - authorising wallet transactions. Stored only as a one-way hash; we never store your PIN in readable form.
• Recipient details - the phone number, network, meter/smartcard number, or biller account you top up or pay on behalf of yourself or others.
• Support messages - any messages, questions, or attachments you send us via WhatsApp, email, or our website.

1.2 Information we collect automatically

• Usage and transaction data - records of your airtime, data, bill payment, and wallet activity, including amount, network/biller, timestamps, and status.
• Technical data - limited information needed to operate and secure the Service, such as your IP address (for rate-limiting and fraud prevention) and strictly necessary session and CSRF cookies. We do not use third-party advertising or tracking cookies, and we do not collect device fingerprints, location, or behavioural advertising data.

1.3 Information we receive from third parties

• Payment providers (Paystack, Monnify)- when you fund your wallet, we receive confirmation of your payment and, where a dedicated virtual account is issued to you, the virtual account number and bank name. We never receive, process, or store your full card number, CVV, or card expiry - all card entry happens on the payment provider’s own secure hosted page.
• WhatsApp / Meta Platforms - when you contact us on WhatsApp, we receive your WhatsApp phone number and the content of the messages you send, as provided through the WhatsApp Business Platform.

We process your personal data for the following purposes:

1. To provide the Service - creating and maintaining your account and wallet, processing airtime, data, and bill purchases, and delivering the products you buy.
2. To process payments - funding your wallet, verifying transactions, issuing receipts, and handling refunds, chargebacks, and disputes.
3. To verify your identity and secure your account - one-time password (OTP) verification of your phone and email, PIN authorisation, fraud detection, and rate-limiting.
4. To operate our WhatsApp assistant - the messages you send on WhatsApp may be processed by an AI language model (see Section 3) so we can understand your request and complete your transaction.
5. To communicate with you - sending transactional messages such as receipts, verification codes, and important service notices.
6. To provide customer support - responding to your questions and resolving issues.
7. To comply with legal and regulatory obligations - including anti-fraud, financial record-keeping, and data-protection requirements under applicable Nigerian law (such as the Central Bank of Nigeria framework and the Nigeria Data Protection Regulation / Nigeria Data Protection Act).

Lawful basis. We process your data primarily to perform our contract with you (to provide the Service you request), to comply with our legal obligations, and for our legitimate interest in keeping the Service safe and preventing fraud.

We do not sell your personal data, and we do not use your data for third-party advertising.

We share personal data only as needed to run the Service, and only with providers who are bound to protect it:

• Payment providers (Paystack, Monnify) - your name, email, phone, and transaction amount, to fund your wallet and verify payments.
• Top-up / bill fulfilment providers (e.g. GSubz) - the recipient phone number, network, meter/biller reference, and amount, to deliver the airtime, data, or bill payment you request.
• WhatsApp / Meta Platforms - your WhatsApp phone number and message content, to deliver our service over WhatsApp.
• AI language-model provider (e.g. Google Gemini or OpenAI) - the content of your assistant messages, to interpret your requests and respond. Messages are sent only to complete your request.
• Email provider - your email address and message content, to send receipts and notices.
• Legal / regulatory authorities - information required by law, to comply with lawful requests, court orders, and regulatory obligations.

We may also share information in connection with a merger, acquisition, or sale of assets, in which case we will require the recipient to honour this Privacy Policy.

• We keep your account and personal data for as long as your account is active and for as long as needed to provide the Service.
• Financial and transaction records are retained for at least 5 years after the transaction, as required by Nigerian financial regulation, even after account closure.
• Where we no longer need your data, we delete it or irreversibly anonymise it.

You may ask us to delete your personal data at any time. To make a request:

• Email us at admin@datadawg.xyz, or
• Message us on WhatsApp through the DataDawg assistant and ask to delete your data, or
• Use the contact form on https://datadawg.xyz.

Please send the request from the phone number or email associated with your account so we can verify your identity.

What happens when you request deletion: we will erase or irreversibly anonymise your personal information (name, phone, email, and PIN). We may retain anonymised financial transaction records where we are legally required to keep them (see Section 4). We will confirm once your request has been completed.

Subject to applicable Nigerian data-protection law, you have the right to:

• Access the personal data we hold about you and request a copy of it;
• Correct inaccurate or incomplete data;
• Delete your personal data (see Section 5);
• Object to or restrict certain processing;
• Withdraw consent where processing is based on consent; and
• Lodge a complaint with the Nigeria Data Protection Commission (NDPC).

To exercise any of these rights, contact us using the details in Section 10.

We apply technical and organisational safeguards appropriate to the sensitivity of the data, including:

• Encryption of data in transit (HTTPS/TLS);
• One-way hashing of transaction PINs - they are never stored in readable form;
• No storage of card numbers, CVV, or card expiry data;
• Verification of all payment provider notifications before they are processed;
• Rate-limiting and distributed locks to prevent abuse and fraud;
• Redaction of phone numbers, emails, and transaction references from our internal logs;
• Access controls limiting who can view personal data.

No method of transmission or storage is completely secure, but we work to protect your data and to notify you and the relevant authorities of a confirmed data breach within the timeframe required by law (72 hours under Nigerian data-protection rules).

The Service is not directed to children under 18, and we do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date above and, where changes are significant, provide additional notice. The current version is always available at this page.

If you have questions about this Privacy Policy or how we handle your data, contact us at:

• Email: admin@datadawg.xyz
• WhatsApp: through the DataDawg assistant
• Website: https://datadawg.xyz
• Postal address: DataDawg Services, Plot 11 Zone B, Liadi, Maya, Ikorodu, Lagos State, Nigeria