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Privacy Policy
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Privacy Policy

Your privacy is important to us at Hapy. We respect your privacy regarding any information we may collect from you across our website.
HAPY Limited – PRIVACY POLICY

Effective Date: 11th August 2025 HAPY Limited (“we”, “our”, “us”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when providing our services, including through our websites, mobile applications, APIs, and offline interactions.

1. Application of this Privacy Policy

This Privacy Policy applies to all systems, operations, and processes of HAPY Limited that involve the collection, use, storage, and disclosure of personal data. It covers our websites, affiliated applications, platforms, APIs, verification portals, social media channels, and any offline services or interactions. It applies to personal data collected from users, clients, and third parties whose data is submitted for verification. For our users, this privacy policy is part of our TERMS OF USE.

This Privacy Policy applies to your use of (regardless of means of access) our Services. You may access or use our Services through a desktop, laptop, mobile phone, tablet, or other consumer electronic device (each, a "Device"). This Privacy Policy also applies to your offline interactions with HAPY .

When you submit an inquiry to us via any means, register for a HAPY account, register to attend a HAPY event, interact with us on social media, partake in competitions and promotional activities and volunteer information to us; we may collect personal information from you, which may include your name, email address, mobile phone number, banking information, image and other information that identifies you (collectively, "Personal Information"). By accessing or using our Services, you agree to this Privacy Policy.

2. Guiding Principles

We are committed to maintaining the principles in the Nigerian Data Protection Act (NDPA) 2023, the NDPA-GAID 2025, and other applicable data protection laws. We process personal data in line with the principles of lawfulness, fairness, transparency, accuracy, purpose limitation, data minimisation, storage limitation, integrity, confidentiality, and accountability. We may process your Personal Information under any of the bases provided below as recognised by data protection laws: Consent By using our Services, you consent to the terms of this Privacy Policy, as to allow us to utilise your data to serve you more accurately.

By accessing our Services and voluntarily providing us with the requested Personal Information, you consent to the collection and use of the information in accordance with this Privacy Policy. Your consent can be withdrawn at any time by sending a request to that effect to this e-mail: support@hapy.africa If you do not consent to the collection, use or disclosure of your Personal Information as outlined in this Privacy Policy, please do not provide any Personal Information to HAPY.

3. Information We Collect

In general, you can visit hapy.africa without telling us who you are or revealing any information about yourself. As a User, we will also ask you to create login information for your HAPY account, such as a username and password. When you provide your mobile phone number, we may ask for your consent to receive text messages relating to our Services on that number. In general, we collect Personal Information you give us by filling out forms or by corresponding with us by phone, email, social media posts & messages, or otherwise. By providing your Personal Information and any other kind of information or data to us, you expressly agree to our collection, use, storage, and disclosure of such information as described in this Privacy Policy. We may receive, use, store and transfer different kinds of Personal Information about you.

Depending on the service, we may collect the following categories of personal data:

  • Identity Data: Name, date of birth, address, ID/passport number, photograph.
  • Sensitive Data: Biometric data, criminal record information, health information.
  • Financial Data: Bank account details, tax information, investment history, payment method details, and transaction records.
  • Investment Data: Portfolio details, dividend entitlements, and transaction performance.
  • Document Data: Passports, National Identification Number, company incorporation and other documents submitted for verification.
  • Contact Data: Email address, phone number, mailing address.
  • Technical Data: IP address, device identifiers, browser type, operating system and analytics data.
  • Usage Data: How you use our website, apps, and services, platform navigation, investment preferences, account activity logs, feedback and survey responses.
4. How We Collect Data

We may use Analytics for research and commercial purposes to improve our Services. We may use Personal Information to fulfil and support our contractual obligations to you, to send important notices such as communications about our Services and changes to our terms, conditions, and policies, for our legitimate interests related to internal purposes such as auditing, data analysis, network and IT security, or to offer our products and services and products and services of third parties that we think you might find of interest and for other purposes contained in this Privacy Policy. Only HAPY and our third-party service providers involved in distributing the offers or providing the products or services will have access to your Personal Information. Our third-party service providers will only be permitted to use Personal Information for the clearly intended purpose. We may use your email address to respond to your inquiries and to provide information about our Services. You may elect not to receive promotional emails from us either by "unsubscribing" to an email you receive from us or by contacting us as indicated below. As a User, if you unsubscribe from receiving emails from us, we may still send you non-promotional emails, such as emails about your HAPY account or our ongoing business relations, unless you withdraw your consent to receive electronic communications as provided in our Terms of Use.

Personal data may be collected directly from:

  • Information you provide when creating or managing your HAPY account
  • Investment transactions and funding activities on the platform
  • Communications with us via email, chat, or calls
  • Automated tracking technologies such as cookies and analytics tools
  • Third-party KYC/AML verification providers
  • Partner institutions or brokers
5. Purpose and Lawful Basis for Processing

We may process your Personal Information to fulfil our contractual obligations such as providing our Services to you or to take necessary actions at your request before providing our Services to you. This enables us to provide you with the Services you request. When you enter into a contract with us, such as subscribing to our Services, or engaging in a business agreement, we need to use your Personal Information to carry out our commitments. This includes processing information such as your name, contact details, payment information, means of identification, personal documents and any other data necessary to deliver the agreed-upon Services or products. Without this data, we would be unable to complete transactions or manage our contractual relationship effectively. We process personal data for the purposes of document verification, fraud prevention, compliance with legal obligations, service improvement, and secure storage. Legal bases include consent, contractual necessity, legal obligation, legitimate interest, and, in rare cases, protection of vital interests or public interest tasks.

6. Data Sharing

How We Share Information You agree that we can share your Personal Information, and other information that you share with us:

  • if you request or authorise it;
  • if the information is provided to help complete a transaction for you;
  • with any of our affiliated companies and service providers;
  • with financial service providers, including the financial institutions identified in your cardholder bank agreement that provide banking services in connection with your HAPY account;
  • with another User, when you sign up for our Services via a referral link. The User that referred you may receive information indicating that you have enrolled with us;
  • with Licensed third-party verification providers.
  • with Cloud hosting providers who store data on our behalf.
  • with non-financial companies, such as email service providers that perform marketing services on our behalf, and fraud prevention service providers that use the information to provide services to us;
  • with a non-affiliated third-party to access and transmit your personal and financial information from a relevant institution. You grant the third-party the right, power, and authority to access and transmit this information according to terms of their privacy policy;
  • with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or alternatively, acquire all or parts of their businesses;
  • in response to a request for information, if we are required by, or we believe disclosure is in accordance with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas or legal process;
  • for our everyday business purposes;
  • for publication of our events and competitions on digital and print media;
  • protect our rights, property, or safety or the rights, property, or safety of our Users or others; or
  • with relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud.

All third parties are contractually bound to protect personal data in accordance with applicable laws. We do not share your Personal Information with: (1) other companies for joint marketing purposes without your consent; or (2) any other third parties so they can market to you. If you provide us with bank account or debit card information, or any other payment information, through our Services, we may share that information with third-party payment processors and other third-party service providers, solely to the extent necessary to provide you with the relevant Services. When you are no longer our User, we may continue to share your information as described in this Privacy Policy as permitted by applicable laws.

  1. Cross-Border Data Transfers We may transfer personal data outside Nigeria when:
  • Using cloud storage or verification partners located abroad.
  • Accessing foreign databases for verification purposes. Safeguards include encryption in transit and at rest, pseudonymisation, access controls, and contractual commitments to NDPA-equivalent standards. We use licensed secure providers for such transfers and ensure that receiving parties are bound by adequate data protection agreements.
8. Data Security

We have suitable security measures in place to prevent your Personal Information from being accidentally lost or used or accessed in an unauthorised way by a third party. When your bank account information is transmitted via our Services, it will be protected by encryption technology, such as Secure Sockets Layer (SSL). In addition, we limit access to your Personal Information to those employees, employers, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We have, and require our third-party service providers that receive Personal Information from us to have, a comprehensive written information security program that contains administrative, technical, and physical safeguards for our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, or alteration.

No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your email address, username and password for your HAPY account and do not share them with others.

If we receive instructions using your HAPY account login information or other HAPY account security information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your HAPY account or any other breach of security. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate HAPY accounts, and to remove or edit content.

Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.

Protecting Children's Privacy Our Services are not directed, or intended to be attractive, to children under the age of eighteen (18). We do not knowingly collect Personal Information from children under the age of eighteen (18). If you are under the age of eighteen (18), do not use our Services or submit any information to us.

Links to Third-Party Websites When you use our Services, you may be directed to other websites that are beyond our control. We may also allow third-party websites or applications to link to our Services. We are not responsible for the privacy practices of any third parties or the content of linked websites, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties and websites. This Privacy Policy only applies to our Services.

9. Data Retention

We deploy strict physical, electronic, and administrative security measures to protect your information from access by unauthorised persons, against unlawful processing and foreseeable hazards and breaches when online. We generally retain your Personal Information for as long as is necessary for the purposes we collected it and also to give you better service. To this end, we are committed to maintaining the confidentiality of the Personal Information. To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, and the applicable legal requirements.

By accessing this Website and any of its pages you are agreeing to the terms set out above. You may also request to have all your Personal Information deleted entirely. Please note that if you request the erasure of your Personal Information, we may retain and use your Personal Information to the extent necessary to comply with our legal obligations, including but not limited to tax, legal reporting and auditing obligations.

If you would like to know more about the retention periods we apply to your Personal Information, please contact us at support@HAPY .com.

10. Account Deactivation

Account deactivation for HAPY users is governed by our Deactivation Policy, which forms part of our Terms of Use and is incorporated by reference into this Privacy Policy. The Deactivation Policy outlines:

  • How you can request deactivation of your HAPY account.
  • Conditions that must be met before deactivation is processed, including settlement of pending investments and withdrawal or reinvestment of funds/dividends.
  • Circumstances under which HAPY may deactivate your account.
  • Timelines and procedures for transferring funds to your linked bank account.

Upon deactivation, HAPY will retain personal data only as long as necessary to comply with legal, regulatory, or contractual obligations, after which it will be securely deleted or anonymised in accordance with our Data Retention policy.

For the complete Deactivation Policy, please refer to the HAPY Terms of Use or deactivation policy.

11. User Rights

Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.

Links to Third-Party Websites When you use our Services, you may be directed to other websites that are beyond our control. We may also allow third-party websites or applications to link to our Services. We are not responsible for the privacy practices of any third parties or the content of linked websites, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties and websites. This Privacy Policy only applies to our Services.

Users have the right to request deletion, and object to processing requests can be made via support@HAPY .me and will be processed in accordance with applicable law.

Right to lodge a complaint with the Commission If you believe that the processing of your Personal Information violates data protection law, you also have the right to complain to the data protection supervisory authority, the Nigeria Data Protection Commission (“Commission”) website via the link: https://services.ndpc.gov.ng/breach/.

Right to withdraw consent Where we are relying on consent to process your Personal Information, you may withdraw your consent to the processing of Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you. We may advise you if this is the case at the time you withdraw your consent.

12. Changes to this Policy

Changes to our Privacy Policy Subject to applicable law, we may revise this Privacy Policy at any time and in our sole discretion. When we revise this Privacy Policy, we will post the revised version via our Services and will update the date at the top of this Privacy Policy. The revised Privacy Policy will be effective upon posting via our Services, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing or using our Services. If you do not agree to the terms of this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access and use of our Services. Except as otherwise expressly stated by us, your access and use of our Services is subject to the version of this Privacy Policy in effect at the time of access or use.

13. Contact Us

HAPY Limited.

62 Shipeolu Street, Shomolu, Lagos, Nigeria.

Email: support@hapy.africa or legal@hapy.africa