1. Overview
FavyXchange ("we," "our," or "us") operates the FavyXchange mobile application (the "App") available on Android and iOS platforms. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App and related services.
By downloading, installing, or using our App, you agree to the collection and use of information in accordance with this Policy. If you do not agree with our practices, please do not use our App.
Summary: We collect only what we need to provide our gift card exchange service. We never sell your data. You have the right to access and delete your information at any time.
2. Information We Collect
2.1 Information You Provide Directly
- Account Information: Full name, email address, phone number, and password (stored as a secure hash) when you register an account.
- Bank Account Details: Bank name, account number, and account holder name when you add a withdrawal account. Used solely for processing payouts.
- Gift Card Information: Card category, denomination, country of origin, and photos/images of the gift cards you submit for exchange.
- Identity Information: Profile photos, if voluntarily provided.
- Communications: Messages you send to our support team.
2.2 Information Collected Automatically
- Device Information: Device type, operating system version, unique device identifiers.
- Usage Data: App features used, transaction history, timestamps of activities.
- Log Data: IP address, app crash reports, error logs (for improving app stability).
- Push Notification Tokens: To deliver transaction updates and alerts to your device.
2.3 Information We Do NOT Collect
- We do not collect or store gift card PINs after verification is complete.
- We do not collect payment card (credit/debit card) numbers.
- We do not collect biometric data (fingerprints, face scans).
- We do not track your location.
3. How We Use Your Information
- Service Delivery: Process your gift card exchanges, verify card authenticity, calculate exchange rates, and credit your wallet.
- Payouts: Process withdrawals to your registered Nigerian bank account.
- Account Management: Create and manage your account, authenticate logins, and reset passwords.
- Security: Detect, prevent, and investigate fraudulent activities, unauthorized access, and violations of our Terms of Service.
- Communication: Send transaction confirmations, status updates, and support responses. We may also send promotional notifications, which you can opt out of at any time.
- Improvement: Analyze usage patterns to improve the App's features, performance, and user experience.
- Legal Compliance: Comply with applicable Nigerian laws and regulations, including anti-money laundering (AML) requirements.
- Rewards Programme: Track your trading activity to calculate and award loyalty points and leaderboard rankings.
4. Information Sharing and Disclosure
We do not sell, trade, or rent your personal information to third parties. We may share your information only in the following limited circumstances:
4.1 Service Providers
- Google Firebase / Firestore: Authentication, database, and cloud storage (Google LLC, USA). Governed by Google's Privacy Policy and GDPR-compliant data processing agreements.
- Firebase Cloud Messaging: Push notification delivery.
- Email Service Providers: For sending transactional emails (password resets, verification codes).
4.2 Legal Requirements
We may disclose your information if required by law, court order, or governmental authority, including compliance with the Nigerian Financial Intelligence Unit (NFIU) requirements, cooperation with law enforcement investigations, and prevention of fraud or financial crime.
4.3 Business Transfer
If FavyXchange is acquired, merged, or undergoes a significant business change, user data may be transferred to the new entity. You will be notified before any such transfer and given the option to delete your account.
4.4 With Your Consent
We will share your information with any other third party only with your explicit consent.
5. Data Security
- Encryption: All data is transmitted over HTTPS/TLS. Data stored in Firebase Firestore is encrypted at rest.
- Authentication: Firebase Authentication with secure password hashing. PIN verification required for sensitive actions.
- Access Control: Only authorized FavyXchange staff and systems can access user data, governed by strict Firestore security rules.
- No Sensitive Storage: Gift card images and details are only retained as long as needed for verification purposes.
While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. We will notify you promptly if a data breach occurs that affects your information.
6. Data Retention
- Account Data: Retained until you request account deletion.
- Transaction Records: Retained for a minimum of 5 years for regulatory compliance.
- Gift Card Images: Deleted after the transaction is completed or rejected.
- Support Communications: Retained for up to 2 years.
You may request deletion of your account and associated data at any time by contacting support@favyxchange.com.ng. Note that some transaction records may be retained for legal compliance purposes even after account deletion.
7. Children's Privacy
FavyXchange is not intended for use by persons under the age of 18. We do not knowingly collect personal information from children under 18. If you believe your child has provided us with personal information without your consent, please contact us at support@favyxchange.com.ng and we will promptly delete such information.
8. Your Rights and Choices
- Access: Request a copy of the personal data we hold about you.
- Correction: Update or correct inaccurate information through the app's Profile settings or by contacting support.
- Deletion: Request deletion of your account and personal data (subject to legal retention obligations).
- Data Portability: Request your data in a machine-readable format.
- Opt-Out: Unsubscribe from marketing notifications at any time via app Settings → Notifications.
- Withdraw Consent: Where processing is based on consent, you may withdraw it at any time. This will not affect prior processing.
To exercise any of these rights, contact us at support@favyxchange.com.ng. We will respond within 30 days.
9. Third-Party Services and Links
Our App may contain links to external websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will send a push notification to the App, display a prominent notice within the App, and update the "Last Updated" date at the top of this Policy. Your continued use of the App after changes are posted constitutes your acceptance of the revised Policy.
