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Privacy Policy

Effective Date: April 29, 2026

1. INTRODUCTION

Dr. Bills Exchange, a subsidiary of Dr. Bills Online Trading Academy Limited ("we," "us," or "our"), respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and digital asset services.

2. DATA WE COLLECT

To provide our services and comply with Nigerian financial regulations (CBN/NFIU), we collect the following:

  • Identity Data: Full name, date of birth, gender, and nationality.
  • Government-Issued Identifiers: Bank Verification Number (BVN), National Identification Number (NIN), and copies of your International Passport, Driver’s License, or Voter’s Card.
  • Contact Data: Email address, phone number, and residential address.
  • Financial Data: Bank account details, wallet addresses, and transaction history.
  • Technical Data: IP address, device type, operating system, and app usage patterns.
  • Biometric Data: Facial "selfie" images for identity verification (KYC).

3. HOW WE USE YOUR DATA

We process your information for the following purposes:

  • Service Delivery: To facilitate crypto-to-fiat exchanges, issue virtual dollar cards, and process gift card trades.
  • Identity Verification: To perform mandatory KYC (Know Your Customer) and AML (Anti-Money Laundering) checks.
  • Security: To detect and prevent fraud, money laundering, and unauthorized access.
  • Communication: To send transaction receipts, security alerts, and customer support updates.
  • Legal Compliance: To fulfill reporting obligations to the Central Bank of Nigeria (CBN) and the Nigerian Financial Intelligence Unit (NFIU).

4. LEGAL BASIS FOR PROCESSING

Under the NDPA, we process your data based on:

  • Contractual Necessity: To provide the services you signed up for.
  • Legal Obligation: To comply with financial crime laws.
  • Consent: When you explicitly agree to marketing or biometric processing.
  • Legitimate Interest: To improve our app’s security and performance.

5. DATA SHARING AND DISCLOSURE

We do not sell your personal data. We only share information with:

  • Regulatory Authorities: The CBN, NFIU, EFCC, or law enforcement when legally required.
  • Service Providers: Third-party partners who facilitate BVN/NIN verification and virtual card issuance.
  • Banking Partners: Financial institutions that process your fiat withdrawals and deposits.
  • Internal Group: Affiliates within Dr. Bills Online Trading Academy Limited for administrative purposes.

6. DATA RETENTION

In accordance with Nigerian AML laws, we retain your personal and transaction data for a minimum of five (5) years after your account is closed or after the last transaction, whichever comes later. After this period, data is securely deleted or anonymized.

7. YOUR DATA PROTECTION RIGHTS

As a "Data Subject" in Nigeria, you have the right to:

  • Access: Request a copy of the personal data we hold about you.
  • Correction: Request that we update inaccurate or incomplete information.
  • Erasure: Request deletion of your data (subject to legal retention requirements).
  • Portability: Request the transfer of your data to another service provider.
  • Objection: Object to the processing of your data for direct marketing.

8. DATA SECURITY

We implement robust technical and organizational measures, including:

  • Encryption: End-to-end encryption for sensitive data and SSL protocols for all communications.
  • Access Controls: Restricted access to personal data to only authorized personnel.
  • Two-Factor Authentication (2FA): Mandatory for high-value transactions and account changes.

9. INTERNATIONAL DATA TRANSFERS

Some of our partners (e.g., virtual card issuers) may be located outside Nigeria. By using Dr. Bills Exchange, you consent to the transfer of your data to jurisdictions that ensure an adequate level of protection consistent with the NDPA.

10. CONTACT US

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact our Data Protection Officer (DPO) at:

  • Email: support@drbillsexchange.com
  • Address: Level 5, Standard Chartered Bank Building, 142 Ahmadu Bello Way, Victoria Island, Lagos, Nigeria.