Privacy Policy
Last updated: March 2026
Welcome to the privacy policy page of AkawoPay Technologies Limited. This page outlines how we collect, use, protect, and disclose information gathered from users of our website and services.
By agreeing to our "Terms of Use" Agreement, clicking "Accept", continuing to visit our website, or visiting our premises, you accept and consent to the processing of your personal data in line with the practices prescribed in this Privacy Policy.
1.0 Introduction
Welcome to the Privacy Policy of AkawoPay Technologies Limited ("AkawoPay," "we," "us," or "our"). AkawoPay is a company incorporated under the laws of the Federal Republic of Nigeria, with its registered office at Plot 1037, Premier Academy Street, FHA, Lugbe, FCT. AkawoPay operates a Buy Now, Pay Later ("BNPL") platform focused on everyday essentials, enabling controlled online payments through secure APIs and data-driven affordability checks while promoting responsible borrowing and financial inclusion (the "Service").
This Privacy Policy is issued pursuant to Section 27 of the Nigeria Data Protection Act, 2023 ("NDP Act") and the General Application and Implementation Directive, 2025 ("GAID") issued by the Nigeria Data Protection Commission ("NDPC"). It explains how we collect, use, store, share, and protect your personal data when you access or use our Service, including our website, mobile application, and any associated platforms.
By creating an account, accessing, or using the Service, you acknowledge that you have read and understood this Privacy Policy. Where we rely on your consent as the lawful basis for processing your personal data, we will obtain such consent in a manner that is affirmative, informed, specific, and not based on a pre-selected confirmation.
This Privacy Policy should be read together with our Terms of Use, Cookie Notice, and any other privacy or fair processing notices that we may provide on specific occasions when we are collecting or processing personal data about you.
2.0 Who We Are
AkawoPay Technologies Limited is a financial technology company that provides Buy Now, Pay Later services to individuals in Nigeria. Our platform uses secure APIs and data-driven affordability checks to enable consumers to make controlled online payments for everyday essentials while promoting responsible borrowing and financial inclusion.
AkawoPay is registered with the Nigeria Data Protection Commission as a data controller of major importance.
3.0 Types of Personal Data We Collect
When you use our Service, interact with our website or mobile application, or communicate with us, we may collect different types of personal data about you. We have grouped these as follows:
| Types of personal data | Description |
|---|---|
| Personal identifiers | Full name, date of birth, gender, photograph, National Identification Number (NIN), Bank Verification Number (BVN), and other government-issued identification details required for identity verification and Know Your Customer ("KYC") processes. |
| Contact information | Residential address, email address, and telephone number for communications and account management. |
| Financial information | Bank account details, payment card information, bank statements, income information, existing debt obligations, credit history, and other financial data necessary for affordability assessments and transaction processing. |
| Transaction information | Records of your purchases, repayment history, payment schedules, outstanding balances, and other transaction data generated through use of the Service. |
| Technical information | IP address, device identifiers, browser type and version, operating system, mobile network information, and location data (approximate, derived from IP address) when you interact with our platforms. |
| Usage information | Information about how you use our website and mobile application, including pages visited, features accessed, session duration, and interaction patterns. |
| Communications data | Records of your correspondence with our customer support team, feedback, complaints, and any other communications with AkawoPay. |
| Marketing and communications preferences | Your preferences for receiving marketing communications and updates about our services and promotions. |
4.0 How We Obtain Personal Data
AkawoPay collects personal data in the following ways:
Directly from you, when you:
- Create an account or register on the Service;
- Complete our KYC and identity verification processes;
- Submit a BNPL application or undergo an affordability assessment;
- Make a purchase or repayment through the Service;
- Contact our customer support team;
- Subscribe to our newsletters or marketing communications (with your consent);
- Participate in surveys, promotions, or feedback exercises; or
- Visit our website or use our mobile application.
From third-party sources, including:
- Credit reference bureaus and financial information providers, for the purpose of conducting affordability and creditworthiness assessments;
- Identity verification service providers, for the purpose of confirming your identity and preventing fraud;
- Partner merchants and e-commerce platforms, in connection with your BNPL transactions;
- Payment processors and financial institutions, in connection with the processing of your transactions; and
- Publicly available sources, such as government registers and public records, where lawful and necessary for our operations.
Collected automatically, when you interact with our platforms:
- Device data and technical information collected through our servers, APIs, and similar technologies;
- Usage data collected through cookies and similar tracking technologies; and
- Approximate location data derived from your IP address.
5.0 Lawful Basis for Processing
5.1
Any personal information provided to AkawoPay will be used with your consent, or when we have another lawful basis. These bases include:
- Cases where the processing of personal data is required for the fulfilment of a contractual obligation.
- Cases where the processing of personal data is required for compliance with legal and/or regulatory requirements.
- Cases where the processing is required to protect your vital interests or those of any other natural person.
- Cases where the processing is required for an activity to be carried out in significant public interest.
- Cases where the processing is required for the legitimate interests of AkawoPay or a third party, insofar as this does not conflict with the requirements for the protection of your personal data.
Where we obtain your consent for the processing of your data, this consent may be obtained from you through the use of a check box, opt in, tick box, clicking "Accept" or "Agree" or by you visiting and engaging our site, signing up or using our products and services or taking such other actions to show that you have agreed to the processing of your personal information by us.
5.2
The collection and use of personal data by AkawoPay are guided by key principles to ensure that your information is handled responsibly. We take measures to ensure that your personal data is:
- Processed fairly, lawfully, and in a transparent manner.
- Obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with such purposes.
- Adequate, relevant, and limited to what is necessary to fulfil the purpose of processing.
- Accurate and, where necessary, kept up to date. Steps should be taken to rectify or erase data that is inaccurate.
- Not kept for longer than necessary for the purpose of processing.
- Processed in accordance with the data subject's rights.
- Kept safe from unauthorised processing, and accidental loss, damage, or destruction using adequate technical and organisational measures.
6.0 Purposes and Specific Lawful Bases for Processing
In accordance with Section 25(1) and Section 27(1)(b) of the NDP Act and Article 16(2) of the GAID, we set out below each specific purpose for which we process your personal data, together with the corresponding lawful basis relied upon:
| Purpose | Categories of data processed | Lawful basis |
|---|---|---|
| Account creation and management: To create and maintain your AkawoPay account, verify your identity through KYC processes, and manage your account settings and security features. | Personal identifiers, contact information, technical information | Performance of a contract to which you are a party. |
| Affordability assessment and credit decision: To conduct data-driven affordability checks, assess your creditworthiness, and determine your eligibility for BNPL services, including the generation of affordability scores. | Personal identifiers, financial information, transaction information | Performance of a contract — these checks are a necessary prerequisite to entering into a BNPL agreement with you; and compliance with a legal obligation where required by applicable financial regulations. |
| Transaction processing and order fulfilment: To process your BNPL transactions, facilitate payments to merchants, manage your repayment schedule, and deliver the Service. | Personal identifiers, contact information, financial information, transaction information | Performance of a contract to which you are a party. |
| Repayment management and collections: To track your repayment obligations, send payment reminders, and manage overdue accounts. | Personal identifiers, contact information, financial information, transaction information | Performance of a contract to which you are a party and legitimate interest in recovering amounts owed under the BNPL agreement. |
| Fraud prevention and security: To detect, prevent, and investigate fraud, unauthorised access, and other criminal or prohibited activities, and to protect the security of our platform, our users, and our business. | Personal identifiers, contact information, financial information, transaction information, technical information, usage information | Legitimate interest in protecting our platform, our users, and our business from fraud and security threats. |
| Customer support: To respond to your inquiries, resolve complaints, and provide technical support. | Personal identifiers, contact information, communications data | Performance of a contract to which you are a party. |
| Service improvement and analytics: To analyse platform performance, improve our features, conduct internal research, and develop new products and services. | Technical information, usage information, transaction information (in aggregated or anonymized form where possible) | Legitimate interest in improving our Service and developing our business. |
| Direct marketing: To send you promotional communications, offers, and information about our products and services. | Personal identifiers, contact information, marketing and communications preferences | Consent — we will only send you direct marketing communications with your prior affirmative consent. |
| Legal compliance and regulatory reporting: To comply with applicable laws, regulations, and requests from competent authorities, including anti-money laundering (AML) requirements, tax obligations, and regulatory reporting. | All categories as required by the specific legal obligation | Compliance with a legal obligation. |
| Establishment, exercise, or defence of legal claims: To establish, exercise, or defend legal claims, and to protect our rights, property, and safety. | All categories as relevant to the specific claim | Legitimate interest in the establishment, exercise, or defence of legal claims. |
7.0 Automated Decision-Making and Profiling
AkawoPay uses data-driven affordability checks as a core part of its BNPL service. These checks involve the automated processing of your financial information, transaction history, and other relevant data to generate an affordability assessment that informs our decision on whether to approve your BNPL application and, if so, on what terms (e.g., credit limit, repayment schedule).
We inform you that:
- Existence of automated decision-making: Our affordability assessment process involves automated processing of your personal data, including profiling, which may produce effects concerning you (e.g., approval or rejection of your BNPL application, determination of credit limits, and repayment terms).
- Significance and envisaged consequences: The outcome of the affordability assessment directly affects whether you are able to access our BNPL service and on what terms. A negative affordability assessment may result in the rejection of your application or the offer of reduced credit terms. This is designed to promote responsible borrowing and protect you from over-indebtedness.
- Your rights: You have the right to:
- Obtain human intervention on the part of AkawoPay in respect of any automated decision;
- Express your point of view regarding the decision; and
- Contest the decision.
8.0 How Long We Store Your Information
We retain your data for as long as is necessary for the purposes for which it was collected. The storage duration of your data is determined by legal, regulatory, administrative, or operational requirements. Data that is no longer needed for the purposes for which it was collected is securely destroyed.
9.0 Data Security
We take appropriate technical and organisational measures to prevent loss, unauthorised access, misuse, modification or disclosure of information under our control. This may include the use of encryption, access controls and other forms of security to ensure that your data is protected. We require all parties including our staff and third parties processing data on our behalf to comply with relevant policies and guidelines to ensure that information is protected in use, when stored and during transmission.
In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of data subjects, AkawoPay will notify the NDPC within 72 hours in accordance with applicable requirements. Where a breach is likely to result in a high risk to your rights and freedoms, we will immediately notify you in plain and clear language, including advice about measures you could take to mitigate the possible adverse effects.
10.0 Third-Party Disclosure
We may share your personal data in furtherance of any of our purposes above, and to the extent permitted by law or by you, with our affiliates, vendors, regulatory bodies and other third parties.
Where we share or transfer your personal data, we will do this in accordance with applicable data protection laws and will take appropriate safeguards to ensure its protection. We do not sell, trade, or otherwise transfer your personal data to third parties for their independent marketing purposes without your explicit consent. Where we share or transfer your personal data, we do so in accordance with applicable data protection laws and ensure that appropriate safeguards are in place through Data Processing Agreements that comply with applicable laws.
11.0 Cookies
Cookies are unique bits of computer data that many major websites will transfer to your electronic devices (e.g., computer, laptop, tablet, smartphones) the first time that you visit. Cookies are stored on your hard drive and may be later accessed by the website to track prior usage. A cookie may also be used to deliver customisable and personalised services and information by tracking which pages a user has already visited. We may also use cookies to track session information, such as pages visited or duration of visit, which will help us continue to improve our format and content. Our website may use cookies to enhance your browsing experience. Please refer to our cookie policy for more details.
12.0 Third-Party Links
Our website, applications, and services may contain links to third-party websites, products, and services. Additionally, we may use or offer products or services from third parties. Information collected by these third parties, such as location data or contact details, is governed by their privacy practices.
AkawoPay is not responsible for the privacy practices or the content of third-party sites and services. We encourage you to review the privacy policies of any third-party websites or services you interact with to understand how they handle your personal information.
13.0 Your Rights
You have certain rights regarding your personal data as prescribed under Nigerian data protection laws, including:
- Right to access: You have the right to request an extract or a copy of any personal information we hold about you. You can contact us via email at hello@akawopay.com.
- Right to rectify: We strive to ensure your personal information is accurate, complete, and up to date. You have the right to request that we correct any personal information you believe is inaccurate or incomplete.
- Right to withdraw consent: Where you have given consent for us to use your personal data, you can withdraw that consent at any time. Once consent is withdrawn, we will stop processing your personal data for the purpose(s) for which the consent was given.
- Right to restrict or object: You can restrict or object to the processing of your personal data in certain cases. We may continue to process your data if there are valid legal, regulatory or operational reasons for doing so.
- Right in relation to automated processing: You have the right to request for human intervention where your personal data is being processed through automated means.
- Right to data portability: If we process your personal information based on your consent or to fulfil a contract, and this processing is automated, you have the right to receive your data in a machine-readable format. You can also request that we transfer this data directly to another controller, where technically feasible.
- Right to erasure: You have the right to request that we delete your personal information in the following circumstances:
- You believe the data is no longer necessary for the purpose it was collected.
- We are using the data based on your consent, and you have decided to withdraw that consent.
- You have validly objected to our use of your data.
- Our use of your personal information is against the law or other legal obligations.
We may continue to retain such data if there are valid legal, regulatory, or operational reasons for doing so.
14.0 Exercising Your Rights
We take measures to ensure your personal data is handled with the utmost care and respect. Your privacy matters to us, and we are committed to upholding your rights regarding your personal information.
To exercise any of your rights above, or if you believe there has been a breach of this Privacy Policy or if you have any concerns regarding the processing of your personal data, we encourage you to contact us via email at hello@akawopay.com.
AkawoPay will take measures to ensure that your rights and interests are protected. We will respond to your request without undue delay and, in any event, within 30 days of receipt. Where additional time is required due to the complexity of the request, we will inform you of the extension and the reasons for the delay.
We will not charge a fee for processing your request unless the request is manifestly unfounded or excessive.
You also have the right to lodge a complaint with the data protection supervisory authority in Nigeria, the Nigerian Data Protection Commission (NDPC), at info@ndpc.gov.ng.
15.0 Children's Privacy
Our Service is not intended for persons under the age of 18 ("children" as defined under the NDP Act and the Child's Rights Act, 2003). AkawoPay does not knowingly collect personal data from children.
We have implemented age verification mechanisms as part of our account registration process, taking into consideration available technology. These include:
- A mandatory date of birth field during registration, which is validated against identification documents submitted during KYC;
- Verification of identity through BVN and NIN; and
- Automated rejection of applications where the applicant's verified age indicates they are below 18.
If we become aware that we have inadvertently collected personal data from a child without verifiable parental or guardian consent, we will take immediate steps to delete such data from our records. If you believe that a child has provided personal data to AkawoPay, please contact our Data Protection Officer immediately.
16.0 Contact Information and Further Advice
If you have any questions or concerns about our Privacy Policy or our data privacy practices or your personal data, please feel free to contact us via email at: hello@akawopay.com
17.0 Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our processing activities, applicable law, or regulatory guidance. Where changes are material, we will notify you by prominent notice on our platform and, where appropriate, by email or in-app notification.
Where material changes affect the basis on which your consent was originally given, we will seek your renewed consent before continuing to process your personal data under the updated terms.
We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.
This Privacy Policy was last updated in March 2026.