Privacy Policy
Last updated: August 4, 2026 · Effective immediately
1. Introduction
At Fluxpa ("we," "our," or "us"), we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, store, share, and protect your data when you access or use our Platform, website, mobile applications, and related services (collectively, the "Platform").
By registering for an account, accessing, or using any part of our Platform, you consent to the practices described in this Privacy Policy. If you do not agree with this policy, please do not use our Platform.
We comply with the Nigeria Data Protection Regulation (NDPR) and other applicable data protection laws. We are committed to handling your data responsibly, transparently, and securely.
2. Information We Collect
We collect different types of information to provide and improve our services. This includes:
2.1 Personal Information
Information you provide directly when registering or using our Platform:
- Identity Data: Full name, date of birth, gender, and photograph (for avatar uploads).
- Contact Data: Email address, phone number, and residential address.
- Account Data: Username, password (encrypted), referral code, and account preferences.
- KYC Documents: Government-issued ID (National ID, Driver's License, International Passport, Voter's Card) and Bank Verification Number (BVN) where required.
- Financial Data: Wallet balance, transaction history, bank account details, virtual account numbers, and payout account information.
2.2 Transaction Information
Details about transactions you perform on our Platform:
- Service type (airtime, data, electricity, cable TV, betting, exam pins, etc.).
- Amount, date, time, and status of each transaction.
- Beneficiary details (phone numbers, meter numbers, smart card numbers, betting IDs).
- Transaction references and payment confirmations.
2.3 Technical & Usage Data
Information collected automatically when you use our Platform:
- Device Information: IP address, browser type and version, operating system, device model, and unique device identifiers.
- Log Data: Pages visited, time spent, clicks, navigation paths, and timestamps.
- Location Data: Approximate geographic location derived from your IP address.
- Cookies & Similar Technologies: See Section 6 for details.
2.4 Communication Data
Records of your interactions with us, including:
- Emails, chat messages, and support tickets.
- Phone call recordings (where legally permitted and with notice).
- Feedback, surveys, and reviews you submit.
3. How We Use Your Information
We use the information we collect for the following purposes:
- Account Management: To create and maintain your account, verify your identity, and provide customer support.
- Service Delivery: To process transactions, deliver purchased services (airtime, data, bills, exam pins), and manage your Wallet.
- Virtual Accounts: To generate and manage virtual account numbers for Wallet funding.
- Loan Services: To assess eligibility, process applications, disburse funds, and manage repayments.
- Security & Fraud Prevention: To detect, prevent, and investigate fraud, unauthorized access, money laundering, and other illegal activities.
- Communication: To send transaction confirmations, OTPs, security alerts, promotional offers, and service updates.
- Platform Improvement: To analyze usage patterns, troubleshoot issues, and enhance user experience.
- Legal Compliance: To comply with applicable laws, regulations, court orders, and requests from law enforcement or regulatory bodies.
- Referral Programs: To track referrals, calculate commissions, and process payouts to referrers.
4. Legal Basis for Processing
Under the Nigeria Data Protection Regulation (NDPR), we process your personal data based on one or more of the following legal grounds:
- Consent: You have given clear consent for us to process your personal data for specific purposes (e.g., marketing communications).
- Contract: Processing is necessary for the performance of a contract to which you are a party (e.g., processing a transaction you initiated).
- Legal Obligation: Processing is necessary for compliance with a legal obligation (e.g., KYC/AML requirements, tax reporting).
- Legitimate Interests: Processing is necessary for our legitimate interests, provided your rights and interests do not override those interests (e.g., fraud prevention, platform security).
7. Data Security
We take the security of your personal information seriously and implement appropriate technical and organizational measures to protect it, including:
- Encryption: All data transmitted between your browser and our servers is encrypted using TLS/SSL. Sensitive data such as passwords are hashed using industry-standard algorithms (bcrypt).
- Access Controls: Strict role-based access controls limit who can access your data within our organization.
- Firewalls & Intrusion Detection: Network security measures to prevent unauthorized access.
- Regular Audits: Periodic security assessments and vulnerability testing.
- Incident Response: A documented procedure for detecting, reporting, and responding to data breaches.
Despite our efforts, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security. You are responsible for keeping your login credentials confidential.
8. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including:
- Providing our services and maintaining your account.
- Complying with legal, tax, accounting, and regulatory requirements.
- Resolving disputes and enforcing our agreements.
Typically, we retain:
- Account Data: For the duration of your account plus 6 years after closure (for legal and regulatory compliance).
- Transaction Records: For a minimum of 6 years (as required by financial regulations).
- KYC Documents: For the duration of your account plus 5 years after closure (per AML/CFT guidelines).
- Communication Records: For 2 years after the last interaction.
- Log & Technical Data: For 12 months, after which it is anonymized or deleted.
When we no longer need your data, we will securely delete or anonymize it in accordance with our data retention schedule.
9. Your Data Protection Rights
Under the NDPR and other applicable data protection laws, you have the following rights regarding your personal information:
- Right to Access: You can request a copy of the personal data we hold about you.
- Right to Rectification: You can request that we correct inaccurate or incomplete data.
- Right to Erasure ("Right to be Forgotten"): You can request deletion of your personal data, subject to legal retention requirements.
- Right to Restrict Processing: You can ask us to limit how we use your data in certain circumstances.
- Right to Data Portability: You can request your data in a structured, machine-readable format.
- Right to Object: You can object to processing based on legitimate interests or for direct marketing purposes.
- Right to Withdraw Consent: Where processing is based on consent, you can withdraw it at any time.
- Right to Lodge a Complaint: You have the right to complain to the Nigeria Data Protection Bureau if you believe we have violated your privacy rights.
To exercise any of these rights, please contact us using the details in Section 13. We will respond to your request within 30 days. We may need to verify your identity before processing your request.
10. Protection of Minors
Our Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we discover that we have inadvertently collected data from a minor, we will take immediate steps to delete that information.
If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us immediately so we can take appropriate action.
11. International Data Transfers
Fluxpa operates primarily in Nigeria. However, some of our service providers may be located outside Nigeria (e.g., cloud hosting providers in the EU or US). When we transfer your data internationally, we ensure that appropriate safeguards are in place, such as:
- Standard contractual clauses approved by data protection authorities.
- Adequacy decisions where the destination country provides an adequate level of data protection.
- Binding corporate rules for intra-group transfers.
By using our Platform, you consent to the transfer of your information to countries outside Nigeria, which may have different data protection laws.
12. Third-Party Links
Our Platform may contain links to third-party websites, services, or applications that are not operated by us. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party sites you visit.
We are not responsible for the content, privacy practices, or security of third-party websites.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make material changes, we will:
- Post the updated policy on this page with a revised "Last updated" date.
- Notify you via email or through a prominent notice on the Platform at least 7 days before the changes take effect.
Your continued use of the Platform after any changes constitutes acceptance of the updated Privacy Policy. We encourage you to review this page periodically.
14. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer:
- Email: ozegbep80@gmail.com
- Phone: +2349068108146
- Address: OZ INTERGRATED SERVICES NIG, Lagos, Nigeria
- Response Time: We aim to respond to all privacy-related inquiries within 48 hours.
By using Fluxpa, you acknowledge that you have read and understood this Privacy Policy and agree to our collection, use, and disclosure of your information as described herein.