Privacy Policy

Effective Date: July 2026 Last Updated: July 2026

Drafting note: This is a general-purpose draft privacy policy built around the services Instapay9ja offers (bill payments, airtime/data, CAC registration, NIN/BVN verification, virtual dollar cards, and the Marketplace & Escrow system) and your NDPC certification details. It has not been reviewed by a lawyer or a licensed Data Protection Officer. Before publishing, have it reviewed for compliance with the Nigeria Data Protection Act, 2023 (NDPA) and the NDPC’s General Application and Implementation Directive (GAID), and fill in the bracketed placeholders.

Our NDPC Certification

Esq1 Tech Hub Ltd, the company operating the Instapay9ja app, is officially certified by the Nigeria Data Protection Commission (NDPC) as a registered Data Controller/Processor of Major Importance.

Registration ID: NDPC/DCP/13546

This certification reflects our ongoing commitment to protecting your personal data and maintaining world-class compliance standards under the Nigeria Data Protection Act, 2023. We are required to, and do, adhere to the NDPA’s principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, confidentiality, and accountability in everything we do with your data.

1. Introduction

1.1 This Privacy Policy explains how Esq1 Tech Hub Ltd (“Instapay9ja,” “we,” “us,” or “our”) collects, uses, discloses, and protects the personal data of users (“you,” “User”) of the Instapay9ja mobile application and website (together, the “App”).

1.2 This Policy applies to all Instapay9ja services, including bill payments, airtime and data purchase, recharge card printing, CAC registration, NIN/BVN verification services, virtual dollar cards, and the Instapay9ja Marketplace & Escrow system.

1.3 By creating an account or otherwise using the App, you consent to the collection and use of your information as described in this Policy, in accordance with the Nigeria Data Protection Act, 2023.

1.4 If you do not agree with this Policy, please do not use the App.

2. Data Controller Information

Data Controller: Esq1 Tech Hub Ltd (operating as Instapay9ja) NDPC Registration ID: NDPC/DCP/13546

3. Information We Collect

We collect the following categories of personal data, depending on which services you use:

3.1 Identity and Verification Information

Full name, date of birth, gender, phone number, email address
National Identification Number (NIN), Bank Verification Number (BVN), and other government-issued identifiers you submit for verification services
Documents submitted for Corporate Affairs Commission (CAC) business registration
Photograph or selfie used for identity verification (know-your-customer/KYC checks), where applicable

3.2 Financial Information

Wallet balance and transaction history
Bank account or card details linked for funding your wallet or virtual dollar card
Billing details for airtime, data, electricity, and other bill payments
Escrow transaction records, including Marketplace order amounts, status, and payout details

3.3 Marketplace and Escrow-Specific Information

Product listings, order details, and delivery information you provide as a Buyer or Seller
In-app Order Chat messages between Buyers and Sellers, which are logged for dispute-resolution and evidentiary purposes as described in our Marketplace Terms & Conditions
Dispute records and supporting information submitted to Instapay9ja Administrators

3.4 Technical and Usage Information

Device information (device type, operating system, unique device identifiers)
IP address, approximate location, and network information
App usage data, log files, crash reports, and analytics data
Cookies and similar tracking technologies (see Section 8)

3.5 Information from Third Parties

Information from identity verification partners (for NIN/BVN checks)
Information from payment processors, banks, and card networks
Information from courier/logistics partners for Marketplace deliveries
Information from referral partners, where you are referred to Instapay9ja or you refer others

4. How We Use Your Information

We process your personal data for the following purposes, consistent with the lawful bases available to us under the NDPA:

To provide our services — processing bill payments, airtime/data purchases, recharge card generation, CAC registration submissions, NIN/BVN verification requests, virtual dollar card issuance, and Marketplace/Escrow transactions.
To verify your identity — completing KYC checks required for financial services and regulatory compliance.
To operate the Marketplace & Escrow system — holding funds in escrow, releasing or refunding them according to our Marketplace Terms, facilitating Order Chat, and reviewing disputes.
To communicate with you — sending transaction confirmations, security alerts, service updates, and responses to support requests.
To maintain security and prevent fraud — monitoring for suspicious activity, verifying transactions, and protecting your wallet and account.
To comply with legal and regulatory obligations — including obligations under the NDPA, Central Bank of Nigeria (CBN) regulations, anti-money laundering (AML) requirements, and requests from law enforcement or regulatory bodies.
To improve our services — analyzing usage patterns and feedback to develop new features and improve reliability.
For marketing — with your consent, where required, sending you information about new features, promotions, or services. You may opt out at any time.

5. Legal Basis for Processing

Under the Nigeria Data Protection Act, 2023, we rely on one or more of the following legal bases to process your data:

Your consent, given at account creation or at the point of collection;
Performance of a contract with you, to provide the services you request;
Compliance with a legal obligation, such as KYC, AML, and tax reporting requirements;
Our legitimate interests, such as fraud prevention and service improvement, balanced against your rights and freedoms.

We do not sell your personal data. We may share your information with:

Payment processors and banking partners, to process wallet funding, withdrawals, and virtual dollar card transactions.
Identity verification providers, to complete NIN/BVN checks and other KYC requirements.
Corporate Affairs Commission (CAC) or its authorized agents, where you request business registration services.
Other Marketplace Users, limited to the information necessary to complete a transaction (for example, a Seller receiving a Buyer’s delivery address, or a Buyer seeing a Seller’s business name).
Courier and logistics partners, to facilitate delivery of Marketplace orders.
Regulators and law enforcement, including the NDPC, CBN, and other authorities, where required by law or valid legal process.
Service providers and contractors, such as cloud hosting, customer support, and analytics providers, bound by confidentiality and data protection obligations.
Professional advisors, such as auditors or legal counsel, where necessary.
A successor entity, in the event of a merger, acquisition, or sale of assets, subject to continued protection of your data under this Policy.

All third parties with whom we share data are required to implement appropriate technical and organizational safeguards consistent with the NDPA.

7. Data Retention

7.1 We retain your personal data for as long as necessary to provide our services, comply with legal and regulatory obligations (including CBN and AML record-keeping requirements), resolve disputes, and enforce our agreements.

7.2 Marketplace Order Chat logs and Audit Trail records are retained for the period necessary to support dispute resolution and legal compliance, as described in our Marketplace Terms & Conditions.

7.3 Where you close your account, we may retain certain data for a period thereafter as required by law or for legitimate business purposes, such as fraud prevention and regulatory record-keeping.

8. Cookies and Tracking Technologies

8.1 The Instapay9ja App and website may use cookies, SDKs, and similar technologies to keep you logged in, remember your preferences, and understand how the App is used.

8.2 You can manage cookie preferences through your device or browser settings. Disabling certain cookies may affect the functionality of the App.

9. Data Security

9.1 We implement technical and organizational measures designed to protect your personal data against unauthorized access, alteration, disclosure, or destruction, consistent with our obligations as an NDPC-certified Data Controller/Processor of Major Importance.

9.2 These measures include encryption of sensitive data, access controls, secure escrow fund handling, and regular security reviews.

9.3 No system is completely secure. While we work to protect your information, we cannot guarantee absolute security, and you also play a role in protecting your account (for example, keeping your password, PIN, and device secure).

10. Your Rights Under the Nigeria Data Protection Act, 2023

As a data subject, you have the right to:

Access the personal data we hold about you;
Request correction of inaccurate or incomplete data;
Request deletion of your data, subject to our legal and regulatory retention obligations;
Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing before withdrawal;
Object to or restrict certain processing, including direct marketing;
Request data portability, where technically feasible;
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 using the details in Section 2. We will respond within the timeframe required under the NDPA.

11. International Data Transfers

Where your data is processed or stored outside Nigeria (for example, by a cloud service provider), we take steps to ensure such transfers comply with the NDPA’s requirements for cross-border data transfer, including verifying that the recipient jurisdiction or organization provides an adequate level of data protection or that appropriate safeguards are in place.

12. Children’s Privacy

The App is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected data from a minor, we will take steps to delete it.

13. Marketplace & Escrow Data Handling

13.1 Data shared between Buyers and Sellers through the Marketplace (such as delivery addresses and Order Chat messages) is used strictly to facilitate the transaction and, where necessary, to resolve disputes.

13.2 As set out in our Marketplace Terms & Conditions, only in-app Order Chat and system Audit Trail records are relied upon as evidence in a dispute; we do not collect or consider external communications (e.g., WhatsApp, phone calls) for this purpose.

13.3 Escrow transaction data, including fund status (HELD, Released, Refunded) and payout details, is retained for financial record-keeping and regulatory compliance.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. Material changes will be communicated through the App or by other reasonable means before they take effect. Continued use of the App after changes take effect constitutes acceptance of the updated Policy.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact:

Esq1 Tech Hub Ltd (Instapay9ja) NDPC Registration ID: NDPC/DCP/13546

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

This document was drafted as a general privacy policy for the Instapay9ja app based on the services and certification details provided. It has been reviewed by a qualified Data Protection Officer and Intsapay9ja legal Team before publication.