🔒 Legal & Compliance
Privacy Policy
How we collect, use, and protect your personal information
Effective date: 1 January 2026 · Last updated: August 2026
1. Who We Are
JasonPay Financial Services Ltd ("JasonPay", "we", "us") is a digital financial services provider regulated by the Central Bank of Nigeria (CBN). We operate under CBN licensing requirements and adhere to the Nigeria Data Protection Act (NDPA) 2023 and the Nigeria Data Protection Regulation (NDPR).
✓ CBN Regulated
✓ NDPA 2023 Compliant
✓ FIRS Registered
Our registered office: Lagos, Nigeria. Data Protection Officer: dpo@jasonpaybank.com
2. Data We Collect
Identity & Account Data
- Full legal name, date of birth, gender
- Bank Verification Number (BVN) — required for CBN KYC Tier upgrade
- NIN (National Identity Number) for Tier 2 and above
- Phone number, email address
- Profile photograph (where provided)
Financial Data
- Account number, balance, and transaction history
- Beneficiary accounts and nicknames
- Reserve and Esusu participation records
- FX wallet balances (USD, CNY)
- Receipt and narration data for all transactions
Device & Technical Data
- Device fingerprint (non-reversible hash)
- IP address, operating system, browser/app version
- Session activity timestamps
AI Interaction Data
- Conversation logs with JAY (our AI Banking Officer)
- Voice input transcripts (processed in-session, not permanently stored)
- Language preference and interaction patterns
3. How We Use Your Data
We do not sell your personal data. Your information is used exclusively to provide and improve JasonPay's banking services.
- Processing payments, transfers, and bill payments
- Identity verification (KYC) as required by CBN
- Fraud detection and prevention
- Compliance with AML/CFT obligations
- Tax reporting under the 2026 Finance Act and FIRS requirements
- Improving JAY's AI responses (aggregated, de-identified)
- Customer support and dispute resolution
- Sending transaction notifications and account alerts
4. Sharing & Disclosure
We share your data only where legally required or necessary to provide the service:
- Regulated financial partners — licensed banks and payment processors (under CBN-approved agreements)
- NIBSS — for account name verification (NUBAN lookup)
- FIRS — for tax reporting obligations under the Finance Act 2026
- CBN — for regulatory reporting and examination
- Law enforcement — when required by Nigerian law or court order
We never share your data with advertisers, data brokers, or unregulated third parties.
5. Data Security
- All data transmitted using TLS 1.3 encryption
- Passwords and PINs stored using one-way cryptographic hashing — never in plain text
- Device fingerprinting using non-reversible hashes
- Immutable audit logs for all system events
- Session timeout after 5 minutes of inactivity
- Biometric authentication support on compatible devices
6. Data Retention
- Transaction records — 7 years (FIRS and CBN requirement)
- KYC documents — 5 years after account closure
- Account data — Duration of account plus 5 years
- AI conversation logs — 90 days, then automatically purged
- Device logs — 12 months rolling
7. Your Rights
Under the Nigeria Data Protection Act 2023, you have the right to:
- Access your personal data
- Correct inaccurate data
- Request deletion (subject to legal retention requirements)
- Restrict or object to processing
- Data portability (export your transaction history)
- Withdraw consent where processing is consent-based
To exercise your rights, contact: privacy@jasonpaybank.com
8. Cookies & Tracking
We use essential cookies only. No advertising cookies, no tracking pixels, no third-party analytics cookies. See our Cookie Policy for details.