Privacy Policy

Introduction

BitaSei Technologies Limited (“BitaSei,” “Company,” “we,” “our,” or “us”) is a company incorporated under the Companies and Allied Matters Act 2020 of the Federal Republic of Nigeria, with its registered office at 8B, Obadare Street, Amuwo Odofin, Lagos State, Nigeria.

BitaSei is engaged in the development and operation of software applications and digital platforms for financial education, investment learning, and technology-enabled training solutions. This Privacy Policy explains how we collect, use, disclose, store, and safeguard your personal information when you access or use our website (www.bitasei.com), web application (app.bitasei.com), mobile applications, and all related services (collectively, the “Platform” or “Services”).

This Privacy Policy is issued in compliance with:

• The Nigeria Data Protection Regulation (NDPR) 2019
• The Nigeria Data Protection Act (NDPA) 2023
• The Companies and Allied Matters Act (CAMA) 2020
• Other applicable Nigerian laws and international best practices

By accessing or using our Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with this Policy, please do not use our Services.

1. Definitions

For the purposes of this Privacy Policy:

• “Data Controller” means BitaSei Technologies Limited, which determines the purposes and means of processing personal data.
• “Data Subject” means any individual whose personal data is collected, held, or processed by the Company.
• “Personal Data” means any information relating to an identified or identifiable natural person.
• “Processing” means any operation performed on personal data, including collection, recording, organization, structuring, storage, adaptation, retrieval, use, disclosure, or destruction.
• “Platform” means our software applications, digital platforms, websites, mobile applications, and all technology products operated by BitaSei.
• “User” or “You” means any individual who accesses or uses our Platform.

2. Information We Collect

2.1 Personal Information You Provide

a) Identity Information:

• Full legal name
• Date of birth
• Gender
• Nationality
• Government-issued identification (for KYC verification)
• Photograph or avatar

b) Contact Information:

• Email address
• Phone number
• Residential address

c) Account Information:

• Username and password (encrypted)
• Account preferences and settings

d) Financial Information:

• Payment card details (processed securely through our payment processors — we do not store full card numbers)
• Transaction history and subscription records
• Billing address

e) Educational and Assessment Data:

• Course enrollment and progress data
• Assessment scores and certifications earned
• Learning preferences and module completion status

f) Trading Simulation Data:

• Paper trading entries, positions, and performance metrics
• Trade journal entries (entry/exit prices, timestamps, notes)
• Self-reported emotional states and confidence levels
• Trading patterns and behavioral analytics

2.2 Information Collected Automatically

• Device type, model, browser type and version
• Pages visited, features accessed, time spent
• IP address and approximate geographic location
• Access times, error logs, and crash reports

2.3 Information from Third Parties

• Payment processors (Paystack, Stripe) regarding transaction status
• Identity verification providers (for KYC compliance)
• Social media platforms (if you choose to link accounts)

3. Legal Basis for Processing

We process your personal data based on the following legal grounds under the NDPR and NDPA:

You may withdraw your consent at any time by contacting us at privacy@bitasei.com.

4. How We Use Your Information

4.1 Service Delivery

• Creating and managing your account
• Providing access to courses, modules, and educational content
• Processing subscriptions and payments
• Delivering certificates upon course completion
• Enabling paper trading simulations and portfolio tracking

4.2 AI-Powered Features

• Generating personalized trading insights through Sei AI
• Analyzing trading patterns and behavioral tendencies
• Providing pattern recognition and market analysis
• Delivering customized learning recommendations

4.3 Communication

• Sending transactional emails (account verification, password resets, subscription confirmations)
• Providing customer support and responding to inquiries
• Sending marketing communications (with your consent)

4.4 Security and Compliance

• Verifying your identity (KYC processes)
• Detecting, preventing, and investigating fraud or unauthorized access
• Complying with applicable laws, regulations, and legal processes

5. Data Sharing and Disclosure

BitaSei does not sell, rent, or trade your personal data. We may share your information only in the following circumstances:

5.1 Service Providers

5.2 Legal Requirements

We may disclose your information if required to comply with applicable laws, respond to lawful government requests, enforce our Terms of Service, or protect the safety of BitaSei, our users, or the public.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity with prior notice to you.

6. Data Security

6.1 Technical Safeguards

• Encryption in Transit: All data is encrypted using TLS 1.3
• Encryption at Rest: Sensitive data is encrypted using AES-256
• Password Security: Passwords are hashed using bcrypt
• Authentication: JWT-based with secure refresh token rotation
• Access Controls: Role-based access control (RBAC)

While we implement industry-standard security measures, no method of electronic transmission or storage is completely secure.

7. Data Retention

8. Your Rights

Under the NDPR and NDPA, you have the following rights:

• Right of Access — Request a copy of personal data we hold about you.
• Right to Rectification — Request correction of inaccurate or incomplete data.
• Right to Erasure — Request deletion of your personal data, subject to legal retention requirements.
• Right to Restriction — Request restriction of processing in certain circumstances.
• Right to Data Portability — Request your data in a structured, machine-readable format.
• Right to Object — Object to processing for direct marketing or based on legitimate interests.
• Right to Withdraw Consent — Withdraw consent at any time without affecting prior processing.
• Right to Lodge a Complaint — Lodge a complaint with the Nigeria Data Protection Commission (NDPC).

To exercise any of these rights, contact us at privacy@bitasei.com. We will respond within 30 days.

9. Cookies and Tracking Technologies

9.1 Essential Cookies

We use essential cookies to maintain your authentication session, remember your preferences, and ensure Platform security. These cookies are strictly necessary and cannot be disabled.

9.2 Analytics Cookies

With your consent, we may use analytics tools to understand Platform usage and identify areas for improvement.

9.3 Managing Cookies

You can manage cookie preferences through your browser settings. We do not use third-party advertising cookies or sell data to advertisers.

10. Children's Privacy

Our Platform is not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately at privacy@bitasei.com.

11. International Data Transfers

Your personal data may be transferred to and processed in countries outside Nigeria where our service providers operate. We ensure adequate safeguards are in place, including Standard Contractual Clauses where required.

12. Third-Party Links

Our Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email to registered users, and a notice will be posted on our Platform. Your continued use of the Platform after changes take effect constitutes acceptance of the updated Policy.

14. Contact Information

BitaSei Technologies Limited

• Data Protection Officer: privacy@bitasei.com
• General Inquiries: support@bitasei.com
• Website: www.bitasei.com

Registered Office: 8B, Obadare Street, Amuwo Odofin, Lagos State, Nigeria

Regulatory Authority: Nigeria Data Protection Commission (NDPC) — ndpc.gov.ng

15. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria. Any disputes arising from this Policy shall be subject to the exclusive jurisdiction of the courts of Nigeria.