At SureTrust (a flagship product of Emarkets24 Africa), the privacy of our (prospective) customers, users of our services, and their Personal Data is of utmost importance to us. In line with our resolution to foster trust in the Nigerian digital economy, we have developed this Privacy Policy to explain our privacy practices regarding how we collect, process, retain, share, and protect your Personal Data when you visit our website, use our marketplace, or engage with our digital platforms (collectively, "the Platform" or "Services").

1. Our Commitment to You

This Privacy Policy between Emarkets24 Africa ("the Company") and you constitutes our commitment to protecting user privacy and compliance with relevant data protection laws. We operate in full compliance with the Nigeria Data Protection Act (NDPA) 2023 and other applicable regulations to ensure that your financial and personal identifiers are shielded from unauthorized access.

2. Lawful Basis for Processing

Depending on your interaction with SureTrust, we process data based on:

• Performance of Contract: To fulfill your trade orders, escrow releases, or service subscriptions.
• Consent: When you voluntarily opt-in to our marketing or use location-based features.
• Legal Obligation: To comply with KYC (Know Your Customer) and AML (Anti-Money Laundering) regulations.
• Legitimate Interest: To prevent fraud and improve the security of our payment vaults.

3. Information We Collect to Serve You

To provide a high-performance ecosystem, we collect the following:

• Sign-up Information: Name, email, phone number, and address for account creation.
• E-Commerce & Trade Data: For features like China Bulk Buying and Dropshipping, we collect shipping addresses, product preferences, and supplier communication logs.
• Financial Utility Data: Meter numbers for Electricity payments, SmartCard numbers for Cable TV, and Exam details for WAEC/JAMB/NECO PIN generation.
• Osusu & Group Data: Participant identifiers for collaborative savings to ensure transparent fund rotation.
• CBT & Educational Data: Information required to generate unique access codes for Computer Based Testing platforms.
• Biometric & Image Data: Portraits and IDs for KYC verification to unlock higher transaction limits on your account.

4. The SureTrust Vault & Security Features

As a product of Emarkets24 Africa, SureTrust utilizes advanced encryption to protect your "Vault." We monitor geolocation and device signatures to ensure that when you pay for Airtime, Data, or Bulk Services, the transaction is initiated by you. Our Marketplace features use escrow-locking, meaning your data and money are held in a secure state until trade satisfaction is confirmed.

5. Information of Minors

SureTrust is primarily designed for entrepreneurs and adults. If you are under the age of 18, you are not eligible to use our services unless under the direct supervision and with the express consent of your parent or guardian, subject to Nigerian Law.

6. How We Share Your Information

We do not sell your data. We only share it with:

• Internal Entities: Other departments within Emarkets24 Africa to improve service delivery.
• Partners: Financial institutions like Flutterwave or Bank9ja to process your payments securely.
• Regulatory Bodies: When required by law to prevent financial crimes.
• Service Providers: Logistics partners for shipping items purchased via our marketplace or China bulk buying features.

7. Your Rights as a Data Subject

Under the NDPA 2023, you have the following rights:

• Right to Access: Request a copy of the data we hold about you.
• Right to Rectification: Ask us to update incorrect or outdated information.
• Right to Erasure: Request the deletion of your data when it is no longer necessary for our services.
• Right to Object: Opt-out of automated decision-making or direct marketing (e.g., promotional SMS/emails).
• Right to Portability: Request your data in a machine-readable format.

8. Data Retention Policy

We retain your Personal Data only for as long as necessary to provide our services and comply with legal obligations. Financial records, including Bulk Airtime purchases and Osusu history, are kept in accordance with Central Bank of Nigeria (CBN) regulations and anti-fraud policies.

9. Remedies for Violation

In the unlikely event of a data breach, our Data Protection Officer (DPO) will address the issue within 30 days. Remedies include data restoration, restriction of processing, and full disclosure of the incident as prescribed by the Nigeria Data Protection Commission (NDPC).

10. Contact Our Privacy Team