The Nigerian Data Protection Regulation says we need to have a lawful basis for using your personal information. At least one of the following must apply: contractual or legal duty, legitimate interest, public interest, vital individual interest or consent.

We collect certain data from you to fulfil the contract we have with you, or to enter into a contract with you. We use this data to:

• Give you the services we agreed to in line with our terms and conditions.
• Send you messages about your account and other services you use if you get in touch, or we need to tell you about something.
• Exercise our rights under contracts we’ve entered into with you, like managing, collecting and recovering money you owe us.
• Investigate and resolve complaints and other issues.

We have to ensure we aren’t breaking any laws by banking you by preventing illegal activities like money laundering and fraud. To do this, we need your data to

• Confirm your identity when you sign up or get in touch.
• Prevent illegal activities like money laundering, tax evasion and fraud.
• Keep records of information we hold about you in line with legal requirements.
• Adhere to banking laws and regulations (these mean we sometimes need to share customer details with regulators, tax authorities, law enforcement or other third parties).

We have to ensure we aren’t breaking any laws by banking you by preventing illegal activities like money laundering and fraud. To do this, we need your data to

• Confirm your identity when you sign up or get in touch.
• Prevent illegal activities like money laundering, tax evasion and fraud.
• Keep records of information we hold about you in line with legal requirements.
• Adhere to banking laws and regulations (these mean we sometimes need to share customer details with regulators, tax authorities, law enforcement or other third parties).

In some instances, we need to use the data you supply us for our legitimate interests. This means we’re using your data in a way that you might expect us to, for a reason which is in your interest and doesn't override your privacy, interests or fundamental rights and freedoms.

For certain information, we’ll ask for your consent. We’ll ask for your consent to:

• Market and communicate our products and services. You can always unsubscribe from receiving these if you want to
• Help protect you against fraud by tracking the location of your phone if you’ve
• Help protect you against fraud by tracking the location of your phone if you’ve authorised it
• View your contact list for airtime purchases.

In some instances, we will share the information provided with some third parties that we do business with, like card producers and credit agencies, or with law enforcement agencies when required.

We keep your information as long as you are a Kuda customer and for any additional period as required under applicable law or regulations.

These retention requirements supersede any right to erasure requests under applicable data protection laws. We cannot therefore erase your data in relation to your Kuda Account until after this time period, however we can assure you that your data will be held safely and securely whilst under our supervision.

We are basically storing and processing your personal data only as long as it is necessary to perform our obligations under the agreement with you or as long as the law requires us to store it.

If you choose to delete your Kuda account, we will delete any data you have previously given us, including the video of your face uploaded during the liveness check.

You have the right to access and request the information that we have for you in our records. You may also ask us to delete our record of you, restrict the way in which we use your personal information, request a copy of the information we hold about you, ask that we update the personal information we hold about you or correct such personal information which you think is incorrect or incomplete, and we will grant this request as long as we’re legally allowed to. You also have the right to object to us using your information for our marketing purposes or any additional services we may be offering you. Lastly, you may also withdraw any consent you’ve previously given us.

At Kuda, we’re extremely committed to respecting and protecting your information. If you have any worries or reservations about your personal information, please contact our Data Protection Officer by:

• Sending a message via the app
• Emailing us at dpo@kuda.com
• Writing to us at 151 Herbert Macaulay Way, Yaba, Lagos

This document will be reviewed on a yearly basis by our Data Protection Officer. If we make any changes, we’ll add a note to this page and if they’re significant changes we’ll let you know by email.

This policy was last updated on 1 February 2021.