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.

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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, including but not limited to name, identification number, location data, online identifier, or factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
• "Processing" means any operation performed on personal data, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure, or destruction.
• "Platform" means our software applications, digital platforms, websites, mobile applications, and all technology products operated by BitaSei.
• "Technology Assets" means software, platforms, intellectual property, data, and proprietary materials owned or licensed by the Company.
• "User" or "You" means any individual who accesses or uses our Platform.

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2. Information We Collect

2.1 Personal Information You Provide

When you create an account, subscribe to our services, or interact with our Platform, we may collect:

a) Identity Information:

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

b) Contact Information:

• Email address
• Phone number
• Residential address
• Emergency contact details (where applicable)

c) Account Information:

• Username and password (encrypted)
• Account preferences and settings
• Profile biography and display information

d) Financial Information:

• Payment card details (processed securely through our payment processors—we do not store full card numbers)
• Bank account information (for refunds, where applicable)
• 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 during simulated trades
• Trading patterns and behavioral analytics

2.2 Information Collected Automatically

When you access our Platform, we automatically collect:

a) Device Information:

• Device type, model, and manufacturer
• Operating system and version
• Browser type and version
• Unique device identifiers

b) Usage Information:

• Pages visited and features accessed
• Time spent on each section of the Platform
• Clickstream data and navigation patterns
• Search queries within the Platform

c) Location Information:

• IP address
• Approximate geographic location (city/country level)
• Time zone settings

d) Log Data:

• Access times and dates
• Error logs and crash reports
• Referring URLs and exit pages

2.3 Information from Third Parties

We may receive information about you from:

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

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3. Legal Basis for Processing

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

Legal Basis	Purpose
Consent	Marketing communications, AI-powered personalized insights, optional features
Contractual Necessity	Account creation, service delivery, subscription management, payment processing
Legal Obligation	KYC/AML compliance, tax reporting, regulatory requirements, responding to lawful requests
Legitimate Interest	Platform security, fraud prevention, service improvement, analytics

You may withdraw your consent at any time by contacting us at privacy@bitasei.com. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.

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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)
• Notifying you of Platform updates, new features, or policy changes

4.4 Security and Compliance

• Verifying your identity (KYC processes)
• Detecting, preventing, and investigating fraud or unauthorized access
• Monitoring for suspicious activity and enforcing our Terms of Service
• Complying with applicable laws, regulations, and legal processes

4.5 Platform Improvement

• Analyzing usage patterns to improve user experience
• Conducting research and development for new features
• Performing internal audits and quality assurance
• Generating aggregated, anonymized analytics

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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

We engage trusted third-party service providers who process data on our behalf:

Provider Type	Purpose	Data Shared
Payment Processors (Paystack, Stripe)	Payment processing	Transaction details, billing information
Email Service (Resend)	Transactional and marketing emails	Email address, name
Cloud Infrastructure (Railway, Vercel, MongoDB Atlas)	Hosting and data storage	All Platform data (encrypted)
Identity Verification (Smile Identity)	KYC compliance	Identity documents, photographs
Analytics	Platform improvement	Anonymized usage data

All service providers are contractually bound to protect your data and use it only for specified purposes.

5.2 Legal Requirements

We may disclose your information if required to:

• Comply with applicable laws, regulations, or legal processes
• Respond to lawful requests from government authorities
• Enforce our Terms of Service or protect our legal rights
• Investigate potential violations or fraudulent activity
• Protect the safety, rights, or property of BitaSei, our users, or the public

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer and any changes to this Privacy Policy.

5.4 With Your Consent

We may share your information with third parties when you have given explicit consent to do so.

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6. Data Security

In accordance with our commitment to protecting Technology Assets and user data, we implement comprehensive security measures:

6.1 Technical Safeguards

• Encryption in Transit: All data transmitted between your device and our servers is encrypted using TLS 1.3
• Encryption at Rest: Sensitive data stored in our databases is encrypted using AES-256
• Password Security: User passwords are hashed using bcrypt with appropriate salt rounds
• Authentication: JWT-based authentication with secure refresh token rotation
• Access Controls: Role-based access control (RBAC) limiting data access to authorized personnel

6.2 Organizational Safeguards

• Regular security training for all employees and contractors
• Background checks for personnel with access to sensitive data
• Confidentiality agreements and data protection clauses in employment contracts
• Incident response procedures and breach notification protocols

6.3 Infrastructure Security

• Secure cloud infrastructure with regular security patches
• Firewall protection and intrusion detection systems
• Regular security audits and vulnerability assessments
• Automated monitoring and alerting for suspicious activity

While we implement industry-standard security measures, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security of your data.

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7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Policy:

Data Type	Retention Period
Account Information	Duration of account + 6 years after deletion
Transaction Records	6 years (in compliance with Nigerian tax laws)
Course Progress & Certificates	Duration of account + 10 years
Trading Simulation Data	Duration of account (deleted upon account deletion)
Communication Records	3 years
Log Data	12 months
Marketing Preferences	Until consent is withdrawn

Upon account deletion, we will delete or anonymize your personal data within 30 days, except where retention is required by law or for legitimate business purposes (e.g., resolving disputes, enforcing agreements).

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8. Your Rights

Under the NDPR and NDPA, you have the following rights regarding your personal data:

8.1 Right of Access

You may request a copy of the personal data we hold about you.

8.2 Right to Rectification

You may request correction of inaccurate or incomplete personal data.

8.3 Right to Erasure

You may request deletion of your personal data, subject to legal retention requirements.

8.4 Right to Restriction

You may request that we restrict processing of your personal data in certain circumstances.

8.5 Right to Data Portability

You may request your personal data in a structured, commonly used, machine-readable format.

8.6 Right to Object

You may object to processing of your personal data for direct marketing or based on legitimate interests.

8.7 Right to Withdraw Consent

Where processing is based on consent, you may withdraw consent at any time.

8.8 Right to Lodge a Complaint

You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data protection rights have been violated.

To exercise any of these rights, contact us at:

• Email: privacy@bitasei.com
• Response Time: We will respond to your request within 30 days

We may request verification of your identity before processing your request.

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9. Cookies and Tracking Technologies

9.1 Essential Cookies

We use essential cookies to:

• Maintain your authentication session
• Remember your preferences and settings
• Ensure Platform security and functionality

These cookies are strictly necessary and cannot be disabled.

9.2 Analytics Cookies

With your consent, we may use analytics tools to:

• Understand how users interact with our Platform
• Identify areas for improvement
• Measure the effectiveness of features

9.3 Managing Cookies

You can manage cookie preferences through your browser settings. Note that disabling essential cookies may affect Platform functionality.

We do not use third-party advertising cookies or sell data to advertisers.

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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 we become aware that we have collected personal data from a child without parental consent, we will take immediate steps to delete such information. If you believe we have inadvertently collected data from a child, please contact us immediately at privacy@bitasei.com.

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11. International Data Transfers

Your personal data may be transferred to and processed in countries outside Nigeria where our service providers operate. When transferring data internationally, we ensure:

• Adequate safeguards are in place (e.g., Standard Contractual Clauses)
• The receiving country provides adequate data protection or the transfer is otherwise lawful
• Your data receives equivalent protection as required under Nigerian law

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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 the privacy policies of any third-party sites you visit.

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13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons.

Notification of Changes:

• Material changes will be communicated via email to registered users
• A notice will be posted on our Platform
• The "Last Updated" date at the top of this Policy will be revised

Your continued use of the Platform after changes take effect constitutes acceptance of the updated Policy. If you do not agree with the changes, you should discontinue use of our Services.

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14. Contact Information

If you have questions, concerns, or complaints regarding this Privacy Policy or our data practices, please contact us:

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)
https://ndpc.gov.ng

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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.