Privacy Policy

1. Introduction

Trilspay values your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, process, disclose, and protect your information when you use our website, mobile application, bill payment services, wallet services, reward services, and other related products.

This policy is prepared in line with applicable Nigerian data protection laws, including the Nigeria Data Protection Act, 2023, which established rules for responsible personal data processing in Nigeria.

By using Trilspay, you agree to the collection and use of your information in accordance with this Privacy Policy.

2. Information We Collect

We may collect the following types of information from you:

3. How We Use Your Information

We use your information to:

• Create and manage your Trilspay account
• Verify your identity
• Process airtime, data, electricity, TV, and other bill payment transactions
• Fund and manage your wallet
• Send transaction notifications and receipts
• Provide customer support
• Prevent fraud, unauthorized access, and financial abuse
• Improve our website, mobile app, and user experience
• Send service updates, promotions, and important notices
• Comply with legal, regulatory, tax, security, and audit obligations
• Resolve disputes and enforce our Terms and Conditions

4. Legal Basis for Processing Your Data

We process your personal information based on one or more of the following legal grounds:

• Your consent
• Performance of a contract with you
• Compliance with legal and regulatory obligations
• Legitimate business interests
• Protection of our platform, users, and financial systems
• Public interest or lawful requests from regulators and government agencies

5. Sharing Your Information

We may share your information with trusted third parties where necessary to provide our services, including:

• Payment processors
• Bill payment service providers
• Banks and financial institutions
• Identity verification providers
• Cloud hosting providers
• SMS, email, and notification service providers
• Customer support tools
• Fraud prevention and security partners
• Regulators, law enforcement agencies, or government authorities where legally required

We do not sell your personal information.

6. KYC and Identity Verification

As a fintech platform, Trilspay may be required to verify your identity before granting access to certain services or transaction limits.

This may involve collecting details such as your BVN, NIN, government-issued ID, selfie, date of birth, or other information required for Know Your Customer checks.

We collect and process this information only where necessary for account verification, fraud prevention, regulatory compliance, and secure financial service delivery.

7. Cookies and Tracking Technologies

Trilspay may use cookies and similar technologies to:

• Keep you logged in
• Remember your preferences
• Improve platform performance
• Understand user behavior
• Detect fraud or suspicious activity
• Improve marketing and analytics

You may disable cookies through your browser settings, but some parts of our website may not function properly if cookies are disabled.

8. Data Security

We take reasonable technical, administrative, and organizational measures to protect your personal information from unauthorized access, loss, misuse, alteration, or disclosure.

These measures may include:

• Data encryption
• Secure authentication
• Access control
• Firewalls
• Transaction monitoring
• Secure server infrastructure
• Staff confidentiality controls
• Regular system reviews

However, no digital platform can guarantee 100% security. You are responsible for keeping your login details, password, PIN, OTP, and device secure.

9. Data Retention

We retain your personal information only for as long as necessary to:

• Provide our services
• Maintain your account
• Resolve disputes
• Prevent fraud
• Comply with regulatory, legal, accounting, and reporting obligations
• Maintain transaction history as required by law

Where your data is no longer required, we may delete, anonymize, or securely archive it.

10. Your Privacy Rights

Subject to applicable law, you may have the right to:

• Request access to your personal data
• Request correction of inaccurate information
• Request deletion of your personal data, where legally allowed
• Withdraw consent where processing is based on consent
• Object to certain types of processing
• Request restriction of processing
• Request data portability where applicable
• Lodge a complaint with the relevant data protection authority

The NDPC is Nigeria’s data protection regulator established under the Nigeria Data Protection Act, 2023.

To exercise your rights, contact us at support@trilspay.com.

11. Marketing Communications

We may send you promotional messages, product updates, offers, and service announcements.

You may opt out of marketing communications at any time by using the unsubscribe option where available or contacting us directly.

Please note that even if you opt out of marketing messages, we may still send you important transaction, security, and account-related messages.

12. Children’s Privacy

Trilspay is not intended for use by children under the age of 18.

We do not knowingly collect personal information from children. If we discover that a child has provided us with personal information, we may delete such information from our records.

13. International Data Transfers

Some of our service providers or technology partners may process or store data outside Nigeria.

Where this happens, we will take reasonable steps to ensure that your personal information is protected in line with applicable data protection laws and recognized security standards.

14. Third-Party Links and Services

Our website or app may contain links to third-party websites, payment providers, or service partners.

We are not responsible for the privacy practices, security, or content of third-party platforms. We encourage you to read their privacy policies before using their services.

15. Fraud Prevention and Account Protection

To protect Trilspay and its users, we may monitor transactions, login activities, device information, and account behavior to detect and prevent fraud, unauthorized transactions, money laundering, abuse, or suspicious activity.

We may suspend, restrict, or review accounts where suspicious activity is detected.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements, technology, or business operations.

When we update this policy, we will revise the effective date above. Continued use of Trilspay after changes are published means you accept the updated policy.

17. Contact Us

For questions, requests, or complaints about this Privacy Policy or how we handle your personal information, contact us through: