PRIVACY POLICY – FALCONPAY BUSINESS

Effective Date: 11th May, 2026

Last Updated: 11th May, 2026

1. INTRODUCTION

This Privacy Policy explains how FalconPay Limited ("FalconPay", "we", "our", or "us") collects, uses, stores, processes, discloses, transfers, and protects information obtained through FalconPay Business services, platforms, applications, APIs, websites, and related infrastructure (collectively, the "Services"). By accessing or using FalconPay Services, users consent to the collection and processing of their information in accordance with this Policy and applicable laws, including the Nigeria Data Protection Act and the Nigeria Data Protection Regulation (NDPR).

2. DEFINITIONS

For the purpose of this Policy: "Personal Data" means information capable of identifying an individual directly or indirectly. "Business Data" means information relating to a business entity, including corporate and operational records. "Processing" means any operation performed on data including collection, storage, use, disclosure, transfer, analysis, or deletion. Words used in this Policy shall carry their ordinary and literal meanings and, where ambiguity arises, recourse shall be made to the Nigeria Data Protection Act and other applicable laws.

3. INFORMATION WE COLLECT

FalconPay may collect identity information, contact details, business registration records, directorship and beneficial ownership information, tax identification records, proof of address documents, bank account details, payment and transaction records, technical information such as IP addresses and device logs, and compliance or risk-related information including fraud indicators, sanctions screening results, and AML monitoring data.

4. BUSINESS VERIFICATION AND KYC

To comply with anti-money laundering, Know Your Customer (KYC), and regulatory obligations, FalconPay may collect and verify Business registration documents, director information, beneficial ownership records, tax information, proof of address, source of funds details, and other compliance-related documentation. FalconPay reserves the right to request additional information or conduct enhanced due diligence where necessary.

5. PURPOSE OF PROCESSING

FalconPay processes information for purposes including account creation, payment processing, transaction settlements, fraud prevention, customer support, cybersecurity, compliance with legal and regulatory obligations, transaction monitoring, analytics, service improvement, dispute resolution, and enforcement of contractual rights.

6. DATA SHARING AND THIRD PARTIES

FalconPay may share information with banks, payment processors, infrastructure providers, cloud service providers, compliance vendors, regulators, auditors, law enforcement agencies, and other competent authorities where necessary for service delivery, compliance, fraud prevention, or legal obligations. This includes collaboration with Microfinance Banks and other financial institution partners involved in transaction processing, settlement administration, and custody of funds. FalconPay does not sell personal data for unauthorized commercial purposes.

7. DATA SECURITY

FalconPay implements reasonable administrative, technical, and organizational safeguards including encryption, secure servers, monitoring systems, audit logs, access controls, and cybersecurity measures designed to protect information against unauthorized access, misuse, alteration, or disclosure. While FalconPay adopts commercially reasonable security measures, no system can guarantee absolute security.

8. DATA RETENTION

FalconPay retains personal data and business information for as long as necessary to fulfill operational, legal, regulatory, compliance, fraud prevention, audit, dispute resolution, and security purposes. Data may be securely deleted, anonymized, or archived where retention is no longer required.

9. USER RIGHTS

Subject to applicable laws, users may request access to their personal data, correction of inaccurate information, deletion of data where legally permissible, or restriction of certain processing activities. FalconPay may decline requests where retention or processing is required for legal, regulatory, security, fraud prevention, or compliance purposes.

10. INTERNATIONAL DATA TRANSFERS

FalconPay may process or store information outside Nigeria where necessary for service delivery, cloud infrastructure, fraud prevention, analytics, or operational efficiency. Appropriate safeguards shall be implemented where international transfers occur.

11. COOKIES AND ANALYTICS

FalconPay may use cookies and similar technologies for analytics, security, fraud prevention, performance optimization, and user experience improvement. Users may disable cookies through browser settings, although certain platform features may be affected.

12. DATA BREACH MANAGEMENT

FalconPay maintains procedures for identifying, investigating, managing, and responding to data breaches or cybersecurity incidents. Where required by law, FalconPay may notify regulators, affected users, or competent authorities within applicable timelines.

13. POLICY UPDATES

FalconPay reserves the right to amend or update this Privacy Policy at any time to reflect changes in law, regulatory obligations, technology, operational practices, or business requirements. Updated versions shall become effective upon publication on FalconPay's website or other communication channels.

14. GOVERNING LAW AND PRE-ACTION NOTICE

This Policy shall be governed by the laws of the Federal Republic of Nigeria. No legal action shall be commenced against FalconPay in relation to this Policy unless a written Pre-Action Notice has first been issued to FalconPay and FalconPay has been granted three (3) months from receipt of the notice to investigate and attempt resolution of the dispute.

15. CONTACT INFORMATION

FalconPay Limited Email: support@falconpay.ng FalconPay Business Website