Privacy Policy
Last updated: 5 July 2026
1. Who we are
NoCut.ng Ltd ("we", "us") is the data controller for personal information collected through the NoCut.ng platform. This policy explains what we collect, why, and the rights you have under the Nigeria Data Protection Act 2023 (NDPA) and its regulations (NDPR).
2. What we collect
- Account information: display name, email, phone number, password (stored hashed, never in plain text).
- Identity verification (KYC): BVN or NIN, submitted only when you choose to verify your identity. These are encrypted at rest and never returned in any API response or shown in the app once submitted.
- Financial activity: wallet balance, deposits, withdrawals, positions taken, and transaction history — needed to operate your account and required for financial recordkeeping.
- Usage data: device, browser, and access logs, used for security and to diagnose issues.
3. Why we process your data
We process personal data to: create and secure your account; verify your identity and age as required by our compliance obligations; process deposits, positions, and withdrawals; prevent fraud and enforce self-exclusion; and communicate with you about your account. Our legal bases are performance of our contract with you (the Terms of Service), compliance with legal obligations (KYC/AML), and legitimate interest in keeping the Platform secure.
4. Who we share it with
We share the minimum necessary data with:
- Payment processors (Paystack, Flutterwave) to process deposits and withdrawals.
- Identity verification providers (e.g. Smile Identity, or the Paystack Identity API) solely to confirm BVN/NIN validity.
- Regulators or law enforcement where required by Nigerian law.
We do not sell personal data to third parties.
5. How we protect your data
BVN and NIN are encrypted at rest and are never included in API responses. Passwords are hashed, never stored in plain text. All privileged financial operations run through server-side functions with an audit trail; direct client writes to wallet balances or market data are not possible.
6. Data retention
We retain account and transaction data for as long as your account is active and for a period afterward as required for financial recordkeeping and dispute resolution. You may request erasure per Section 7, subject to any records we are legally required to keep.
7. Your rights under the NDPA/NDPR
You have the right to:
- Access the personal data we hold about you.
- Correct inaccurate or incomplete data.
- Request erasure of your data, subject to our legal recordkeeping obligations.
- Object to or restrict certain processing.
- Request a copy of your data in a portable format.
To exercise any of these rights, contact us at the address in Section 9.
8. Children's privacy
The Platform is restricted to users 18 and older. We do not knowingly collect data from anyone under 18.
9. Contact us
For privacy questions or to exercise your data rights, contact privacy@nocut.ng.
10. Changes to this policy
We may update this policy from time to time. Material changes will be notified in-app or by email before they take effect.