Privacy Policy

1. Introduction

Welcome to Cash-in App! We're committed to safeguarding your privacy and handling your data responsibly. This Privacy Policy explains how Macroblocs Limited, the company that owns and operates Cash-in App, collects, uses, and protects your personal data in line with the Nigeria Data Protection Act 2023. We also respect global privacy standards, including the General Data Protection Regulation (GDPR), to ensure transparency and user control over data. By using our services, you agree to the terms outlined here.

2. Data Collection

We collect different types of data to provide and improve our services, in compliance with the Nigeria Data Protection Act 2023 and other applicable regulations. The personal data we collect includes:

Identity Verification Data: Bank Verification Number (BVN), National Identification Number (NIN), selfie photographs, and all associated information available on government databases linked to these identifiers.
Personal Information: Your name, contact details (email address, phone number), date of birth, and residential address.
Financial Information: Bank account details, transaction history, and payment information.
Transactional Data: Details of your crypto-to-naira conversions, including amounts, exchange rates, timestamps, and transaction statuses.
Technical Data: IP addresses, device information, browser type, operating system, and usage patterns collected through cookies and similar technologies.
Communication Data: Records of your interactions with our customer support team, including emails, chat logs, and support tickets.

Data is collected directly from you when you register, complete KYC verification, or transact on our platform. We also collect data automatically through cookies and similar technologies to ensure a smooth, secure user experience and to comply with regulatory requirements.

3. Purpose of Data Collection

We collect your information to fulfill essential functions on Cash-in App, in compliance with the Nigeria Data Protection Act 2023, the Money Laundering (Prevention and Prohibition) Act 2022, SCUML regulations, and other applicable Nigerian laws. The purposes for which we collect and process your data include:

Identity Verification and KYC Compliance: Verifying your identity using BVN, NIN, and selfie verification to comply with Know Your Customer (KYC) requirements under anti-money laundering regulations.
Transaction Processing: Processing your crypto-to-naira conversions and facilitating automated payouts to your nominated bank account through third-party payment fulfillers.
Regulatory and Legal Compliance: Fulfilling our obligations under the Money Laundering (Prevention and Prohibition) Act 2022, SCUML regulations, and other applicable laws, including reporting suspicious transactions to relevant authorities.
Fraud Prevention and Security: Detecting, preventing, and reporting fraudulent activities, money laundering, terrorism financing, and other financial crimes.
Law Enforcement Cooperation: Supporting law enforcement investigations when required by law or court orders.
Customer Support: Providing customer service, responding to inquiries, and resolving disputes.
Service Improvement: Enhancing service features, analyzing usage patterns, and improving the overall user experience.

We only collect data that is necessary and relevant for these purposes, in accordance with the principles of data minimization under the Nigeria Data Protection Act 2023.

4. How We Use Your Information

Your data is used mainly to improve our services, and to meet regulatory and legal obligations. This includes facilitating your transactions through our third party vendors, providing customer support, and providing tailored features based on your preferences. We adhere to legal standards and use data for fraud detection, suspicious activity reporting, fraud reporting, regulatory compliance, and secure user authentication. Based on this Privacy Policy, we may also use your contact information to send you service updates or promotional content. We ensure all data usage is compliant with privacy regulations and tailored for the proper functioning of our platform and respect for our users under the law.

5. Data Sharing and Disclosure

We respect your privacy and only share your data in specific circumstances, in compliance with the Nigeria Data Protection Act 2023. We may share your data with:

Third-Party Payment Fulfillers: We share your payment details (bank account information and transaction amounts) with third-party payment fulfillers whose sole function is to receive and execute fiat payment orders on our behalf. These fulfillers are contractually bound to maintain high data protection standards and use your data only for the purpose of processing payments.
Regulatory and Law Enforcement Authorities: We may disclose your information to regulatory authorities (including SCUML, CBN, and other relevant bodies), law enforcement agencies, or courts when required by law, court orders, or when we have reasonable grounds to suspect money laundering, terrorism financing, or other financial crimes.
Government Databases: We access and verify information from government databases (BVN, NIN databases) as part of our KYC verification process, in compliance with applicable regulations.

International Data Transfers: By using Cash-in App, you consent to the transfer of your personal data to servers located in Europe and the United States of America. We maintain servers in these jurisdictions to ensure reliable service delivery. When transferring data internationally, we ensure that appropriate safeguards are in place to protect your data in accordance with the Nigeria Data Protection Act 2023. We ensure that third parties receiving your data in these jurisdictions maintain adequate data protection standards.

Cash-in App does not sell or rent your data to third parties for any marketing or monetary benefit whatsoever. In case of legal or regulatory obligations, we reserve the right to disclose your information within or outside the borders of Nigeria if we deem it necessary to comply with court orders, legal requirements, or other procedures in line with the Nigeria Data Protection Act 2023 and other applicable laws.

6. User Rights and Choices

Under the Nigeria Data Protection Act 2023, you have several rights regarding your personal data:

Right of Access: You can request access to your personal data held by us.
Right to Rectification: You can request correction of inaccurate or incomplete data.
Right to Erasure: You can request deletion of your data, subject to legal and regulatory retention requirements.
Right to Data Portability: You can request your data in a structured, commonly used, and machine-readable format. Data requests are available in CSV format upon request.
Right to Object: You can object to certain processing activities, where applicable.
Right to Withdraw Consent: Where processing is based on consent, you can withdraw consent at any time.

To exercise these rights, please send an email to compliance@cash-in.app with your request. We will respond to your request within a reasonable timeframe, in accordance with the Nigeria Data Protection Act 2023.

Limitations on Rights: Your rights may be limited in certain circumstances, including:

When we are required to retain data for legal or regulatory compliance (e.g., AML/CTF requirements, tax obligations).
When data is subject to ongoing legal proceedings or investigations.
When disclosure would compromise our ability to prevent, detect, or investigate fraud, money laundering, or other financial crimes.

In the event where our attention is brought to the occurrence of suspicious activity, suspected fraud, investigations of fraud, or legal proceedings related to your data on Cash-in App by competent law enforcement bodies within or outside the borders of Nigeria, you shall not have the right to be notified by us prior to or after we have made any decisions regarding the sharing of your data with necessary law enforcement or regulatory bodies, as such notification may compromise ongoing investigations or legal proceedings.

7. Security Measures

We take the security of your data seriously and employ multiple safeguards to protect it. This includes encryption, secure storage, and regular audits of our security practices. We also restrict access to personal information to authorized employees only, who are bound by confidentiality obligations. Our infrastructure is regularly monitored to prevent unauthorized access, disclosure, or misuse. While we strive for high standards, we cannot guarantee complete security but are committed to protecting your information.

8. Data Retention

We retain your data only as long as necessary for the purposes outlined in this policy or as required by the laws of the Federal Republic of Nigeria, including:

KYC and Identity Verification Data: Retained for the duration of your account and for a minimum of 5 years after account closure, as required by anti-money laundering regulations (Money Laundering (Prevention and Prohibition) Act 2022 and SCUML requirements).
Transactional Data: Retained for a minimum of 7 years for audit, tax, and compliance purposes, as required by Nigerian law.
BVN and NIN Data: Retained in accordance with regulatory requirements and for as long as necessary to verify your identity and comply with KYC obligations.
Communication Records: Retained for a minimum of 3 years for customer support and dispute resolution purposes.

Once data is no longer needed for these purposes, we safely dispose of it using industry-standard secure deletion procedures. However, we may be required to retain certain data longer if it is subject to ongoing legal proceedings, regulatory investigations, or court orders. You can contact us at compliance@cash-in.app if you have specific concerns about data retention policies.

9. Cookies and Tracking Technologies

Our platform may use cookies and similar technologies to enhance functionality and analyze user interaction. Cookies help us improve user experience by remembering preferences and tracking performance. Some cookies are essential for service functionality, while others are optional and used for analytics. You can manage your cookie preferences in your browser settings. We respect your choice to enable or disable cookies as desired, but certain features may be limited without them.

10. Changes to the Privacy Policy

We may update this Privacy Policy at any time and without notice to reflect changes in our services, legal or regulatory requirements. When we make changes, each version will include an effective date. It is the responsibility of users to review the policy periodically to detect and stay informed of any changes. Your continued use of the app after any updates signifies your acceptance of the revised policy.

11. 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 Nigeria Data Protection Commission (NDPC) within 72 hours of becoming aware of the breach, in accordance with the Nigeria Data Protection Act 2023. The notification will include information about the nature of the breach, the categories of data affected, the likely consequences, and the measures we are taking to address the breach. We maintain robust security measures to prevent data breaches and have incident response procedures in place to address any security incidents promptly.

12. Children's Privacy

Cash-in App services are only available to users who are at least 18 years old. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that we have collected personal data from a minor, we will take steps to delete such information immediately. If you believe we have collected data from a minor, please contact us at compliance@cash-in.app.

13. Contact Information

For questions, concerns, or to exercise your privacy rights, please contact us at:

Macroblocs Limited (Cash-in App)
Compliance Email: compliance@cash-in.app
Support Email: support@cash-in.app

Note: Macroblocs Limited currently operates a remote-only business model and does not maintain a physical office. All communications should be directed to the email addresses provided above.

Our team is here to assist with any inquiries regarding data usage, privacy concerns, or to process data access requests related to Cash-in App. Data access requests can be made via email to compliance@cash-in.app, and data will be provided in CSV format.