We collect the minimum we need to run your account — your phone number, your name, and your transactions.
We never store your PIN or your card details. We do not sell your data, and we do not use it for advertising.
1.Who is responsible for your data
[LEGAL ENTITY NAME], of [REGISTERED ADDRESS], is the controller
of the personal data described here. For any privacy question, contact [PRIVACY EMAIL].
2.What we collect
Information you give us
Your name, as you give it to the bot.
Your phone number — this identifies your account.
Your country and whether you are local (Nigeria/Ghana) or in the diaspora.
Your PIN — stored only as an encrypted hash. We never store or see the PIN itself.
Messages you send to our support team.
Information created when you use Abiora
Your balance and transaction records: amounts, currencies, dates, references and who you sent to or received from.
Savings goals you create.
Referral relationships and rewards.
The link between your phone number and your Telegram account, plus the chat identifier we need in order to reply to you.
Website assistant
When you use the chat assistant on our website, we process the question you type and your IP address, only to
answer you and to limit abuse of the service.
3.What we do not collect
We do not store card numbers or bank login details — those go directly to our payment providers.
We cannot see your other WhatsApp or Telegram conversations. We only receive the messages you send to Abiora.
We do not sell your personal data, and we do not use it for advertising or profiling.
4.Why we use your data, and our legal basis
Why
Legal basis
To open and run your account and carry out your transactions
Performance of our contract with you
To keep accounts secure and prevent fraud and abuse
Our legitimate interests, and legal obligation
To meet financial-crime, record-keeping and reporting duties
Legal obligation
To answer your support messages
Performance of our contract, and legitimate interests
To fix problems and improve the service
Our legitimate interests
5.Who we share it with
Payment and airtime providers, so that deposits, withdrawals and purchases can be carried out.
WhatsApp (Meta) and Telegram, because your messages travel through their platforms. Their own
privacy policies apply to that.
Infrastructure providers that host the service and store our encrypted backups.
An AI provider, where the website assistant is set to phrase answers more naturally. It receives
only your typed question — never your account details, balance or transactions.
Regulators, courts and law enforcement, where we are legally required to share information.
Professional advisers such as auditors and lawyers, where necessary.
6.Where your data is processed
Your data may be processed outside your country, including in the European Union and the United States. Where that
happens, we rely on appropriate safeguards such as standard contractual clauses.
7.How long we keep it
Account and transaction records: while your account is open, and afterwards for as long as financial
record-keeping and anti-money-laundering law requires [typically 5–7 years — confirm].
Support conversations: kept while needed to resolve your issue and for a reasonable period afterwards.
Website assistant questions and IP data: kept only briefly, for rate limiting and troubleshooting.
8.Your rights
Depending on where you live, you may have the right to:
ask for a copy of the data we hold about you;
have inaccurate data corrected;
ask us to delete data, where we are not required to keep it;
object to, or ask us to restrict, certain processing;
receive your data in a portable format;
withdraw consent, where we relied on consent.
To use any of these, contact [PRIVACY EMAIL]. You also have the right to complain to your
data protection authority — for example the CNIL in France, the Nigeria Data Protection Commission, or the Data
Protection Commission in Ghana.
9.How we protect your data
Every transaction is confirmed with your 6-digit PIN.
PINs are stored as encrypted hashes, never in readable form.
A PIN locks temporarily after repeated wrong attempts.
Data is transmitted over encrypted connections, and backups are encrypted and stored offsite.
Access to systems is limited to people who need it.
No service can promise perfect security, but we work to protect your data and will tell you and the relevant
authority if a breach affects you, as the law requires.
10.Children
Abiora is not for anyone under 18. We do not knowingly collect data from children, and we will delete such data
if we discover it.
11.Cookies and tracking
Our chat assistant does not set cookies and does not track you across websites.
[If your website uses analytics or other cookies, describe them here — confirm with your lawyer.]
12.Changes to this policy
We may update this policy as the service develops. We will change the date at the top, and tell you through the
service where a change materially affects you.
13.Contact us
Type support in the Abiora chat, or email [PRIVACY EMAIL].