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OYAFI PRIVACY POLICY



Effective Date: September 10, 2026
Last Updated: September 10, 2026

Oyafi (“Oyafi”, “we”, “us”, or “our”) respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how Oyafi collects, uses, stores, protects, and otherwise processes personal information when you visit or use oyafi.online, create an Oyafi account, use our digital services, contact customer support, or otherwise interact with the Oyafi Platform.

Oyafi is operated by Lord Atkin Corporations.

This Privacy Policy is intended to explain our privacy practices in a clear and understandable manner and is designed with applicable Nigerian data-protection requirements, including the Nigeria Data Protection Act 2023, in mind. The Nigeria Data Protection Commission identifies principles including lawful, fair and transparent processing, purpose limitation, data minimisation, appropriate retention, accuracy, and security of personal data.




1. WHO WE ARE



Platform: Oyafi
Operator: Lord Atkin Corporations
Website: oyafi.online
Support Email: [[email protected]](mailto:[email protected])

For privacy-related questions, requests, complaints, or concerns, you may contact us at:

[[email protected]](mailto:[email protected])




2. INFORMATION WE COLLECT



We collect only information that is reasonably necessary to operate, secure, and improve Oyafi and to provide the Services you request.

Depending on how you use Oyafi, this may include the following.

2.1 Account Information



When you create an Oyafi Account, we may collect:

* Full name;
* Email address;
* Phone number;
* Username;
* Password credentials in protected form;
* Transaction PIN in protected form;
* Account status;
* Account creation and verification information.

Oyafi uses email verification to verify ownership of the email address associated with an Account.

Oyafi does not require identity verification through government-issued identification documents as part of ordinary account registration.




3. TRANSACTION INFORMATION



When you use Oyafi Services, we may collect and retain information relating to your Transactions.

This may include:

* Transaction ID;
* Transaction type;
* Service purchased;
* Amount;
* Price;
* Transaction status;
* Date and time;
* Recipient information supplied for the Transaction;
* Provider reference;
* Payment reference;
* Refund or reversal information;
* Transaction processing information;
* Transaction history;
* Wallet activity; and
* other information reasonably necessary to process and investigate a Transaction.

For example, when you purchase airtime or data, Oyafi may need to record the telephone number or service identifier to which the Service was requested.




4. WALLET INFORMATION



If you use the Oyafi Wallet, we may collect and maintain information concerning:

* Wallet balance;
* Wallet transactions;
* Wallet funding;
* payment references;
* adjustments;
* refunds;
* transaction history; and
* related security information.

Your Wallet activity may be retained as necessary to provide the service, maintain accurate financial records, investigate disputes, prevent fraud, and comply with applicable legal obligations.




5. PAYMENT INFORMATION



Oyafi may use third-party payment processors to process Wallet funding and other supported payments.

For Wallet funding, Oyafi may use Paystack.

Oyafi does not intend to store complete payment-card information such as your full card number or CVV on Oyafi's own systems.

Instead, Oyafi may receive and retain information necessary to identify and reconcile a payment, such as:

* payment reference;
* transaction reference;
* payment status;
* amount;
* date and time;
* payment method information provided by the payment processor; and
* receipt or confirmation information.

Payment processing may therefore involve the relevant payment provider processing information under its own applicable privacy practices.




6. SERVICE PROVIDERS



Oyafi relies on certain third-party service providers and infrastructure to operate the Platform.

These may include providers used for:

* payment processing;
* digital service delivery;
* communications;
* customer support;
* hosting;
* security;
* email delivery; and
* other technical functions necessary to operate Oyafi.

For example, Oyafi may use Subarena or other relevant service infrastructure to process and deliver supported VTU and digital services.

Where a third party is necessary to complete a Service you have requested, we may provide that third party with the minimum information reasonably necessary to complete the Service.

Oyafi does not sell your personal information.

We do not intentionally disclose your personal information to third parties for their independent advertising or marketing purposes.




7. EMAIL COMMUNICATIONS



Oyafi currently uses PHPMailer to send emails directly from the Platform's server-side application.

Emails may include:

* account verification messages;
* password-reset messages;
* transaction notifications;
* receipts;
* security alerts;
* support communications;
* promotional communications where applicable; and
* other necessary Platform communications.

Oyafi may change its email delivery infrastructure in the future. If a third-party email delivery provider is introduced, this Privacy Policy may be updated accordingly.




8. WHATSAPP SUPPORT



Oyafi may provide customer support through WhatsApp.

If you choose to contact Oyafi through WhatsApp, your interaction will also be subject to WhatsApp's own terms and privacy practices.

Oyafi may receive and process information you voluntarily provide through the support conversation for the purpose of assisting you, investigating complaints, resolving Transactions, and providing customer support.

You should avoid sending unnecessary sensitive information through support channels.




9. INFORMATION FROM YOUR DEVICE



When you use Oyafi, our systems may automatically process certain technical information necessary for the Platform to function securely.

This may include:

* IP address;
* browser information;
* device type;
* operating system;
* session information;
* login information;
* security-related information;
* approximate technical information associated with a connection; and
* timestamps associated with Platform activity.

We use this information primarily for:

* maintaining secure sessions;
* preventing unauthorized access;
* protecting Accounts;
* detecting suspicious activity;
* troubleshooting technical problems;
* maintaining Platform security; and
* understanding basic Platform performance.

We do not use device information to create unnecessary personal profiles.




10. COOKIES



Oyafi uses cookies and similar technologies that are necessary for the operation and security of the Platform.

Our primary cookies include:

Essential Cookies



These cookies are required for important Platform functions such as:

* maintaining login sessions;
* authentication;
* security;
* maintaining user state; and
* enabling requested Platform features.

Without these cookies, certain parts of Oyafi may not function properly.

Session Cookies



Session cookies help Oyafi maintain your active session while you navigate the Platform.

They may be used to determine that requests are associated with the correct authenticated session.

Oyafi does not currently use cookies for third-party advertising purposes.




11. HOW WE USE YOUR INFORMATION



We may process personal information for purposes including:

Providing Services



To:

* create and maintain your Account;
* process purchases;
* process Wallet transactions;
* deliver airtime, data, and other Services;
* process refunds and reversals;
* provide receipts; and
* provide customer support.

Account Security



To:

* authenticate Users;
* protect Accounts;
* detect suspicious activity;
* prevent fraud;
* investigate unauthorized Transactions;
* maintain secure sessions; and
* protect the Platform.

Communication



To send:

* verification emails;
* password-reset messages;
* Transaction notifications;
* receipts;
* security notifications;
* support communications; and
* other necessary service communications.

Platform Improvement



To understand how Oyafi functions and improve:

* Platform reliability;
* user experience;
* Service performance;
* customer support;
* security systems; and
* Oyafi Padi.




12. OYAFI PADI AND ARTIFICIAL INTELLIGENCE



Oyafi may provide an AI-powered support assistant known as Oyafi Padi.

When you interact with Oyafi Padi, your messages may be processed to:

* answer questions;
* provide information about Oyafi;
* assist with Services;
* troubleshoot problems;
* help identify Transaction issues;
* improve support quality; and
* improve Oyafi's AI systems.

Oyafi may use appropriately processed or reviewed support conversations to improve Oyafi Padi and its ability to provide useful responses.

Where conversations are reviewed by humans for support, quality, safety, or improvement purposes, access should be limited to persons who reasonably need that access.

Oyafi Padi does not replace human support and should not be treated as a professional financial, legal, medical, or other regulated adviser.

For Transactions requiring human investigation, Oyafi may transfer the matter to human support.




13. AI TRAINING AND IMPROVEMENT



Oyafi may use information from interactions with Oyafi Padi to improve the AI assistant.

Where practical, Oyafi may use techniques intended to reduce unnecessary identification of individual Users when information is used for improvement purposes.

We will not intentionally use your private support conversations for unrelated advertising purposes.




14. LEGAL BASES FOR PROCESSING



Depending on the circumstances, Oyafi may process personal information on lawful grounds including:

Performance of a Contract



Where processing is necessary to provide a Service you requested.

For example, processing your phone number may be necessary to deliver a data or airtime purchase.

Legitimate Interests



Where processing is reasonably necessary for purposes such as:

* Platform security;
* fraud prevention;
* system maintenance;
* service improvement;
* customer support; or
* protecting Oyafi and its Users.

We will consider your privacy interests when relying on legitimate interests.

Legal Obligations



Where processing is necessary to comply with applicable laws, lawful requests, regulatory requirements, accounting requirements, or other legal obligations.

Consent



Where applicable, Oyafi may request your consent before processing information for a purpose that requires consent.

Where processing is based on consent, you may withdraw that consent, subject to legal or operational limitations.

The Nigeria Data Protection Act requires consent to be informed and affirmative where consent is the lawful basis, and withdrawal of consent does not affect processing that was lawful before withdrawal.




15. DATA MINIMISATION



Oyafi follows a data-minimisation approach.

We aim to collect and process information that is reasonably necessary for the purposes described in this Privacy Policy.

Oyafi does not intentionally collect unnecessary personal information simply because it may be technically possible to do so.




16. WHO CAN ACCESS YOUR INFORMATION



Access to personal information within Oyafi should be limited according to operational necessity.

Depending on the circumstances, information may be accessed by:

* authorized Oyafi personnel;
* authorized customer support personnel;
* technical administrators;
* security personnel;
* payment processors;
* Service Providers;
* technology providers; and
* other parties where disclosure is legally required or necessary to provide a requested Service.

Access should be limited to the information reasonably necessary for the relevant purpose.




17. DATA SHARING



Oyafi does not sell personal information.

We do not intentionally share personal information with third parties for their own unrelated advertising purposes.

However, some information may need to be transmitted to a service provider when you request a Service.

For example:

* payment information may be processed by Paystack;
* information necessary to fulfil a VTU or digital service may be processed by the relevant Provider;
* support information may be processed through WhatsApp if you choose WhatsApp support.

Only information reasonably necessary for the relevant purpose should be disclosed.




18. LEGAL AND REGULATORY DISCLOSURES



Oyafi may disclose personal information where reasonably necessary to:

* comply with applicable law;
* respond to a lawful request;
* comply with a court order;
* prevent or investigate fraud;
* protect Users;
* protect the Platform;
* investigate security incidents; or
* protect the rights, property, or safety of Oyafi or another person.

Where legally permitted, Oyafi will seek to limit such disclosure to information reasonably necessary for the relevant purpose.




19. DATA RETENTION



Oyafi does not retain personal information indefinitely without purpose.

Different categories of information may be retained for different periods depending on why the information was collected.

Account Information



Account information may generally be retained while your Account remains active and for an appropriate period afterward where necessary for security, dispute resolution, legal obligations, or legitimate business purposes.

Transaction Records



Transaction and Wallet records may be retained for longer periods because they may be necessary for:

* accounting;
* transaction verification;
* fraud prevention;
* dispute resolution;
* financial records;
* regulatory requirements; and
* legal obligations.

Security Records



Login, session, security, and fraud-prevention records may be retained for a limited period appropriate to the security purpose.

Support Conversations



Support conversations may be retained for an appropriate period to:

* resolve disputes;
* maintain support history;
* improve customer service;
* investigate abuse; and
* improve Oyafi Padi where applicable.

AI Improvement Data



Information used for improving Oyafi Padi may be retained according to the applicable AI improvement and data-management practices.

When information is no longer reasonably required for a legitimate purpose, Oyafi may delete it, anonymize it, or otherwise securely dispose of it, subject to applicable legal and operational requirements.

The NDP Act requires personal data not to be retained longer than necessary for the lawful purpose for which it was collected or processed.




20. DATA SECURITY



Oyafi takes reasonable technical and organizational measures to protect personal information against unauthorized access, loss, misuse, alteration, disclosure, or destruction.

Security measures may include:

* password hashing;
* protected authentication systems;
* access controls;
* transaction security;
* session management;
* monitoring for suspicious activity;
* secure communications;
* database security;
* restricted administrative access; and
* security logging.

However, no internet-based system can be guaranteed to be completely secure.

You are also responsible for protecting your Account credentials, password, Transaction PIN, email account, and devices.




21. DATA BREACHES



If Oyafi becomes aware of a personal-data breach, we will assess and respond to the incident in accordance with applicable law.

Where notification is legally required, Oyafi will make the required notifications within the applicable timeframe and take reasonable steps to mitigate the effects of the breach.

Users may also be contacted where appropriate.




22. YOUR PRIVACY RIGHTS



Subject to applicable law and legitimate limitations, you may have rights concerning your personal information, including the right to:

* request access to your personal information;
* request correction of inaccurate information;
* request deletion or erasure;
* request restriction of certain processing;
* object to certain processing;
* withdraw consent where processing is based on consent;
* request data portability where applicable;
* challenge certain automated decision-making; and
* lodge a complaint with the Nigeria Data Protection Commission.

The NDPC provides mechanisms for data-subject requests involving access, rectification, erasure, restriction, portability, withdrawal of consent, objection, and automated decision-making.




23. HOW TO EXERCISE YOUR RIGHTS



You may submit a privacy request by contacting:

[[email protected]](mailto:[email protected])

Your request should identify:

* your name;
* the email address associated with your Oyafi Account;
* the nature of your request; and
* any information reasonably necessary for us to identify the relevant Account.

For security reasons, we may need to verify your identity before fulfilling certain requests.

This is intended to prevent someone else from gaining access to or modifying your personal information.

We will handle valid requests within the timeframe required by applicable law.




24. ACCOUNT DELETION



You may request closure or deletion of your Oyafi Account.

Account deletion may not result in immediate deletion of every record.

Certain information may need to be retained for:

* legal compliance;
* accounting;
* transaction records;
* fraud prevention;
* security;
* dispute resolution; or
* other lawful purposes.

Where information is no longer required, Oyafi may delete or anonymize it in accordance with its retention practices.




25. CHILDREN AND YOUNGER USERS



Oyafi is intended to provide access to digital services used by people who use mobile phones and require services such as airtime and mobile data.

Oyafi does not intentionally require users to provide unnecessary age-related personal information.

Where applicable law requires parental or guardian involvement, age-related consent, or additional safeguards for younger users, Oyafi will apply those requirements.

Parents or legal guardians who believe that a child has provided personal information to Oyafi in circumstances where such processing is not appropriate may contact:

[[email protected]](mailto:[email protected])

Oyafi may take reasonable steps to investigate and address the request.




26. INTERNATIONAL DATA PROCESSING



Some of the technology or service providers used by Oyafi may process information outside Nigeria.

Where personal information is transferred or processed outside Nigeria, Oyafi will take reasonable steps to ensure that the transfer and processing are conducted in accordance with applicable data-protection requirements.




27. THIRD-PARTY WEBSITES AND SERVICES



Oyafi may link to or integrate with third-party platforms.

Examples may include payment providers, telecommunications services, WhatsApp, or other service providers.

When you leave Oyafi or interact directly with a third-party platform, that third party's own privacy policy and terms may apply.

Oyafi is not responsible for the independent privacy practices of third parties.




28. CHANGES TO THIS PRIVACY POLICY



Oyafi may update this Privacy Policy when necessary.

Changes may occur because of:

* new Platform features;
* changes to Services;
* new service providers;
* changes in data-processing practices;
* security improvements;
* changes in applicable law; or
* other operational requirements.

When we make significant changes, we may provide notice through the Platform or other appropriate communication channels.

The “Last Updated” date at the beginning of this Privacy Policy will indicate when it was most recently revised.




29. QUESTIONS AND PRIVACY COMPLAINTS



If you have questions, concerns, or complaints about how Oyafi handles your personal information, please contact us first.

Email: [[email protected]](mailto:[email protected])

We will make reasonable efforts to investigate and resolve legitimate privacy concerns.

You may also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) where applicable. The NDPC is Nigeria's data-protection authority established under the Nigeria Data Protection Act 2023.




30. CONTACT INFORMATION



Oyafi
Operated by Lord Atkin Corporations

Website: oyafi.online
Email: [[email protected]](mailto:[email protected])

For privacy requests, account-data requests, or privacy complaints:

[[email protected]](mailto:[email protected])




31. ACCEPTANCE



By creating an Oyafi Account or using the Platform, you acknowledge that you have had the opportunity to read this Privacy Policy and understand how Oyafi processes personal information.

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