Privacy Policy

1. Introduction

This Privacy Policy explains how DE-NICK E-HUB LTD (“DE-NICK”, “the Company”, “we”, “us” or “our”), trading as DE-NICK SWAP, collects, uses, stores and shares personal information when you use our platform and related services. The Company seeks to process personal data in accordance with the Nigeria Data Protection Act 2023 (“NDPA”) and other applicable requirements.

2. Information We Collect

• Identity and verification information;
• Contact information;
• Account and transaction-security information;
• Transaction information, including transaction type, amount, asset, wallet/destination details and timestamps;
• Technical and security information such as device, IP address, browser and access logs where collected;
• Information supplied in customer-support or complaint communications.

3. How We Collect Information

We collect information directly from you when you register, use the platform, initiate transactions, complete verification or contact support. We may also receive information from service providers supporting the platform.

4. Identity Verification

The Company uses third-party identity-verification functionality, including Didit, for relevant customer verification and liveness checks.

5. How We Use Personal Information

• Create and administer customer accounts;
• Verify identity and eligibility;
• Process and support transactions;
• Provide customer support;
• Prevent and detect fraud and security threats;
• Conduct AML/CFT/CPF, sanctions and PEP screening;
• Monitor transactions and investigate unusual activity;
• Maintain records and meet legal or regulatory requests;
• Improve platform security and reliability;
• Communicate important service, security or policy information.

6. Legal Basis for Processing

Depending on the circumstances, processing may be based on contract, legal obligation, legitimate interests, consent where required, or another lawful basis recognised under applicable data-protection law.

7. AML/CFT/CPF, Fraud and Compliance

The Company may process information for customer due diligence, enhanced due diligence, sanctions and PEP screening, transaction monitoring, fraud prevention, suspicious-activity investigation and regulatory reporting where required.

8. Sharing Personal Information

• Quidax, for cryptocurrency transaction execution, liquidity and related infrastructure;
• KoraPay, for payment infrastructure, including virtual-account and Naira payout functions;
• Didit, for identity verification and liveness functionality;
• Professional advisers, auditors, consultants and service providers where necessary;
• Regulators, law-enforcement agencies, courts or competent authorities where required or permitted by law;
• Other parties where you authorise disclosure or it is otherwise lawful.

9. International Data Transfers

Some service providers or technology infrastructure may process information outside Nigeria. Where personal data is transferred across borders, the Company will seek to apply appropriate safeguards and comply with applicable requirements.

10. Data Security

The Company takes reasonable technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. Customers should also protect their account credentials and devices.

11. Data Retention

The Company retains personal data for as long as reasonably necessary for account administration, transaction records, dispute resolution, security, fraud prevention, legal and regulatory compliance and legal claims. Specific periods may vary according to information type and applicable requirements.

12. Your Data Protection Rights

Subject to applicable law and lawful restrictions, you may have rights to access, correction, deletion or restriction of processing, objection to certain processing and other rights provided by applicable data-protection law.

13. How to Exercise Your Rights

To make a data-protection request, contact the Company using the support details below. The Company may need to verify your identity before responding.

14. Cookies and Similar Technologies

The platform may use cookies or similar technologies for essential functionality, security, session management, analytics or other lawful purposes. Where required, appropriate information or consent will be provided.

15. Children’s Privacy

The platform is not intended for persons who are not legally permitted to use the services. We do not knowingly collect children’s personal information where collection is prohibited by applicable law.

16. Third-Party Websites and Services

Third-party websites and services may have their own privacy policies. Customers should review those policies where applicable.

17. Personal Data Breaches and Security Incidents

Where a personal-data breach occurs, the Company will assess and respond in accordance with applicable law, including notification obligations where applicable.

18. Customer Support

Privacy enquiries and data-protection requests: help.denickswap@gmail.com
WhatsApp: +234 805 028 7755

19. Changes to This Privacy Policy

The Company may update this Privacy Policy to reflect changes in services, technology, legal obligations or processing practices.

20. Governing Law

This Privacy Policy is governed by the laws of the Federal Republic of Nigeria, including applicable data-protection legislation.