Data Processing Policy

Pacepay Fintech Limited ("we", "our", "us") is a financial technology and digital commerce company operating multiple digital platforms and financial services, including:

• Pacearena – a digital marketplace enabling buyers, sellers, and agents to transact goods and services
• Pacearena Multipurpose Cooperative Society Limited – a modern digital cooperative platform enabling members to save, manage contributions, and access cooperative financial services both onsite and remotely through secure digital channels
• eSaver – a digital savings and financial management application designed to support secure daily and periodic savings activities

As part of our operations, we provide secure onboarding, identity verification, member management, payment processing, and Dedicated Virtual Account (DVA) creation services for users and cooperative members.

We are committed to protecting the privacy, security, confidentiality, and integrity of all personal data processed across our platforms in compliance with the Nigeria Data Protection Act (NDPA), Nigeria Data Protection Regulation (NDPR), and applicable financial compliance standards.

By accessing or using any of our platforms or services, you agree to the practices described in this Policy.

• Company Name: Pacepay Fintech Limited
• Platforms Covered:
  • Pacearena Marketplace
  • Pacearena Multipurpose Cooperative Society Limited
  • eSaver
• Website(s):
• https://esaver.vercel.app
• https://www.pacearena.store
• Contact Email: hi@pacearena.store

This Policy applies to:

• Digital savings services and cooperative contribution management
• Dedicated Virtual Account (DVA) provisioning for members and users
• Marketplace transactions and escrow-enabled commerce services
• User onboarding, KYC verification, and identity authentication
• Mobile applications, web platforms, APIs, payment infrastructure, and customer support systems
• Agent-assisted transactions and digital financial services

We collect only data reasonably necessary to provide our services, maintain security, comply with regulatory obligations, and improve platform operations.

4.1 Personal Identification Information

• First Name
• Last Name
• Email Address (verified via OTP)
• Phone Number (verified where applicable for account security and transaction authentication)
• Residential address where required for compliance purposes

4.2 Identity Verification Data (KYC)

To support financial compliance, fraud prevention, and secure onboarding, users or cooperative members may be required to provide:

• Bank Verification Number (BVN), or
• National Identification Number (NIN)

Important: Raw BVN or NIN data is not permanently stored on our systems unless required by law or regulated financial partners. Identity information may be securely transmitted to licensed third-party verification providers for validation and compliance checks.

4.3 Biometric & Liveness Verification Data

Where required by compliance partners or financial infrastructure providers:

• Facial verification and liveness checks may be conducted for identity verification and fraud prevention
• Device-based biometric authentication (such as fingerprint authentication) is processed locally on the user's device and is not stored on our servers

4.4 Financial & Cooperative Data

• Savings contributions and balances
• Cooperative contribution records
• Deposit and withdrawal history
• Dedicated Virtual Account (DVA) details
• Payment transaction records
• Wallet and settlement information
• Cooperative member transaction activities

4.5 Marketplace Data (Pacearena)

• Buyer and seller account details
• Product listings and descriptions
• Order and transaction history
• Delivery and fulfillment information
• Escrow transaction data
• Agent transaction activities

4.6 Technical & Usage Data

• Device information
• IP address
• Browser and application usage logs
• Session activity and interaction data
• Security and fraud monitoring logs

5.1 Cooperative & Savings Services

We process user and member data for:

• User and cooperative member onboarding
• Identity verification and KYC compliance
• Phone and email verification
• Dedicated Virtual Account (DVA) creation and management
• Savings contribution tracking and account management
• Deposit, withdrawal, and settlement processing
• Fraud detection, abuse prevention, and financial monitoring
• Cooperative administration and member management

5.2 Marketplace Services

We process data to:

• Manage buyer and seller accounts
• Enable secure marketplace transactions
• Support escrow payment processing
• Facilitate order fulfillment and dispute resolution
• Enable agent-assisted commerce services
• Improve platform trust and transaction security

5.3 General Platform Operations

We also process data for:

• Customer support and communications
• Security monitoring and system protection
• Analytics and service improvement
• Regulatory compliance and reporting obligations
• Prevention of unauthorized access, fraud, and abuse

We process personal data based on:

• User consent
• Contractual necessity
• Compliance with legal and regulatory obligations
• Legitimate business interests related to security, fraud prevention, and service operations

We may share limited user information with licensed and regulated third-party service providers strictly for operational and compliance purposes, including:

• Identity verification providers
• Payment processors and financial infrastructure providers
• Dedicated Virtual Account (DVA) partners
• Fraud prevention and security monitoring providers
• Cloud hosting and infrastructure providers

All third parties engaged by us are subject to confidentiality obligations and applicable data protection requirements.

We implement appropriate technical and organizational safeguards to protect user information, including:

• Encrypted transmission of sensitive data
• Access control restrictions
• Secure authentication mechanisms
• Fraud monitoring systems
• Secure cloud infrastructure and logging systems

We retain personal and financial data only for as long as necessary to:

• Provide our services
• Comply with legal and regulatory obligations
• Resolve disputes and enforce agreements
• Maintain fraud prevention and audit records

Subject to applicable laws, users may have the right to:

• Access their personal data
• Request correction of inaccurate data
• Request deletion of certain personal information
• Withdraw consent where applicable
• Request restriction of processing under specific circumstances

Company: Pacepay Fintech Limited

Email: hi@pacearena.store

By accessing or using Pacearena, Pacearena Multipurpose Cooperative Society Limited, or eSaver, you acknowledge and consent to the collection, processing, storage, and use of your information as described in this Data Processing Policy.