TruePeer Privacy Policy

1. Information We Collect

• Identity and contact details: full name, date of birth, gender, email address, phone number, residential address and country.
• Verification records: Bank Verification Number (BVN), National Identification Number (NIN), international passport or driver's licence images and the details read from them, proof-of-address documents, the selfie or short facial scan from your liveness check, and the result of each check (see Section 2).
• Location readings for proof of address: if you allow it, your device's location while the app is open, for a limited time after you submit a proof of address (see Section 2.4).
• Financial and transaction data: balances, every transaction you make or receive, the bank accounts and virtual account numbers linked to you, saved beneficiaries, crypto wallet addresses you send to or receive from, swap quotes, bill payment details (such as a meter or phone number), Circle memberships and contributions, payment requests and splits, referral codes and rewards, and your account statements.
• Device and session data: a device identifier, device name and type, operating system, app version, IP address, sign-in history, active sessions and push notification tokens.
• Security data: hashed passwords and transaction PINs, one-time codes we send you, two-factor settings, and whether you use fingerprint or face unlock on your device (the biometric itself never leaves your device).
• Support and communications: support conversations, including messages and any files or images you choose to share, and records of the notifications and emails we send you.
• Usage and diagnostics: app and web app analytics events (such as screens used and features tried), crash reports, and in-app activity signals used to decide whether a notification is needed.
• Information from others: verification results from identity providers, payment details from partner banks and payment providers, sanctions and fraud lists, and information other users give us about you (for example when they invite you to a Circle or request money from you).

If you pay a TruePeer user without an account, we collect the name and contact details you enter, your IP address and the payment details, to deliver and record the payment.

2. How We Use Your Information

We use personal information to:

• Open and run your account, and provide every service you use.
• Verify your identity and address, set your verification tier and apply its limits (KYC).
• Detect and prevent fraud, money laundering, terrorist financing and sanctions breaches, including linking accounts that share a device, phone number or identity details, holding or reviewing large or unusual transactions, and screening crypto addresses against public sanctions and scam lists.
• Send you one-time codes, transaction alerts, security alerts and other service notices.
• Provide customer support and resolve disputes and complaints.
• Produce account statements and reports you ask for.
• Run the referral programme and pay rewards.
• Understand how the product is used, fix crashes and improve it.
• Comply with the law, respond to lawful requests from regulators and law enforcement, and keep the records we are required to keep.

Under the Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation (NDPR), we rely on the performance of our contract with you, our legal obligations, our legitimate interest in running a secure platform, and, for biometric checks and location readings, your consent.

2.1 TrueDepth Camera Data

TruePeer may use Apple's TrueDepth camera technology only for identity verification and user authentication where supported on compatible devices. This functionality is used solely to confirm the identity of the user during Know Your Customer (KYC) verification and to enhance account security.

Any depth information or facial mapping data generated through the TrueDepth camera is processed only for the requested verification session. TruePeer does not store, retain, sell, or share TrueDepth data with third parties for advertising, profiling, or marketing purposes.

TrueDepth data is used exclusively to perform the requested authentication or identity verification and is discarded immediately after processing unless otherwise required by applicable law.

2.2 Identity Verification and Biometric Data

To complete KYC verification, TruePeer works with licensed identity-verification providers (currently Smile Identity for BVN, NIN and proof-of-address checks, and Didit for passport and driver's licence checks). During verification you may be asked to provide your BVN or NIN, capture a live selfie or short facial scan (a "liveness check"), or photograph an identity document. This information is shared with the verification provider solely to confirm your identity against official records and to detect impersonation or fraud.

Biometric verification is always performed with your knowledge — you will see and complete the capture step yourself, and consent is requested before the check begins. Verification providers process this data under their own security and privacy obligations and do not use it for advertising or marketing.

The verification outcome (approved or rejected, and the tier it unlocks), the details read from your document, and a copy of the document and selfie images are stored on your TruePeer profile in private storage that only authorised compliance staff can open, with every full-size view logged. Verification records are retained as required by AML/KYC regulations.

2.3 Your Profile Photo

When a verification that included a selfie is approved, that selfie becomes your profile photo. It is shown to the people you interact with on TruePeer — for example when someone searches for your username to send you money, on payment requests, in Circles you belong to, and on your public pay page. You can replace it with another photo at any time in Settings. The profile photo is a plain picture; it is not used for facial recognition.

2.4 Location for Proof of Address

To confirm the address on a proof-of-address document without asking you for more paperwork, the app can compare that address with where your device is. If you allow location access, the app takes a reading when you submit the document, when you tap "Confirm my address now", and occasionally when you reopen the app during the following 24 hours. Readings are only taken while the app is open on your screen — never in the background — and stop after that window.

Each reading (coordinates, accuracy and time) is stored with your verification record so that our compliance team can see why an address was or was not confirmed. The document address is converted to coordinates using a geocoding service (Google Maps or OpenStreetMap). You can decline location access; your address will then be reviewed manually from the document alone.

2.5 Devices and Sessions

Your account is signed in on one device at a time. We record an identifier for each device, its name and type, and the IP address and time of each sign-in, so that we can ask for an email code when a new device appears, sign the previous device out, show you your active session, and detect accounts that share a device. Push notification tokens are tied to the device that is signed in and deleted when it is signed out.

3. What Other People Can See

• Other TruePeer users who search for you, send you money, request money from you or save with you in a Circle see your name, username and profile photo. Circle members also see your contribution record (rounds completed and contributions missed).
• Anyone with the link to your dollar pay page sees your name, username and profile photo. Anyone with a split link sees your name and the amounts.
• Your referral link carries your referral code, not your personal details.
• Recipients of a bank payout see the name on your TruePeer virtual account, as banks require.

4. Who We Share Information With

We do not sell personal data. We share it only with the parties below, for the purposes in this policy, and they may process it only on our instructions or as the law requires:

• Partner banks and payment providers that issue your virtual account numbers, receive your deposits, process card payments and bank payouts (such as Globus Bank, Payrep, Paystack and Monnify). They receive your name, identity details and the transaction details needed to move the money.
• Crypto infrastructure, liquidity and price providers that create wallet addresses, broadcast and monitor blockchain transactions, provide market rates and settle swaps. They receive wallet addresses and transaction details, not your identity.
• Identity-verification and screening providers (Smile Identity, Didit) for KYC, liveness and AML checks, and public sanctions and scam-address lists.
• Billers and billing aggregators for airtime, data, power and subscription payments: the identifier you pay for and the amount.
• Geocoding services (Google Maps, OpenStreetMap) receive the address on your proof-of-address document, not your identity.
• Cloud, analytics and messaging providers for hosting, file storage, app analytics and crash reporting (Google Firebase), push notifications (OneSignal), email and SMS delivery.
• Our internal alerting tools, which receive limited operational details (such as a transaction reference and account identifier) so that our team can act on holds, failures and incidents quickly.
• Regulators, law enforcement and courts — including the Central Bank of Nigeria, the Nigerian Financial Intelligence Unit and other competent authorities — where the law requires it or on a lawful request. This can include printed or exported copies of your account record and statements. Every such print or export is logged with the staff member, the reason and a reference.
• Professional advisers and successors, under confidentiality, for audit, legal advice, or if the business is sold or restructured.

Some providers operate outside Nigeria. Where personal data leaves Nigeria we rely on providers with adequate protections and contractual safeguards as the NDPA requires.

5. Security Practices

To protect your information and assets, TruePeer uses encryption in transit and at rest, hashed passwords and PINs, multi-layer wallet and account security, role-based access for staff with every sensitive view and action logged, and continuous monitoring to detect suspicious activity. We recommend enabling Two-Factor Authentication (2FA) and never sharing your login credentials. TruePeer staff — including our customer support team — will never ask you for your password, transaction PIN, one-time codes or wallet private keys, in chat or anywhere else.

6. Customer Support Conversations

When you contact us through the in-app support chat, the conversation — your messages, our replies, and any images or documents you attach — is stored on our systems. Authorised support staff can view your conversation together with basic account context (such as your profile, verification tier, and recent transactions) so they can resolve your issue without asking you to repeat yourself. Access is restricted by role-based permissions and logged.

Files shared in support chat are limited in size and type (images and PDF documents), and are stored with our cloud storage provider. Please do not share passwords, PINs, card numbers, or other credentials in chat — we will never ask for them.

Support conversations may be reviewed for quality, training, dispute resolution, and compliance purposes.

7. Notifications and Communications

We send notifications to keep you informed about your account: transaction alerts, security alerts (such as a sign-in on a new device), one-time codes, verification updates, holds and their outcome, Circle and payment-request activity, referral rewards, and replies from our support team. Depending on your device and settings these may arrive as mobile push notifications, browser notifications, in-app messages, SMS, or email. We may also show announcements inside the app.

To avoid disturbing you unnecessarily, we use limited in-app activity signals (for example, whether the support chat screen is currently open) to decide when a notification is actually needed, and we limit repeated alerts for the same conversation.

You can control push and browser notifications in your device or browser settings at any time. Note that we may still deliver essential security and service notices required to protect your account. Marketing communications, where sent, always include an opt-out.

8. Data Retention

We retain personal data only as long as necessary for legal, compliance, or operational purposes. Once retention periods expire, data will be securely deleted or anonymised. In particular:

• KYC and transaction records, including verification images, account statements, holds and their outcome, and compliance reports: retained for at least five (5) years after your account is closed, or longer where applicable AML/CFT and CBN regulations require.
• Location readings for proof of address: kept with the verification record they belong to, and not used for anything else.
• Sign-in, session and device records: retained while you have an account and for a period afterwards to investigate security incidents.
• Records of prints and exports of your account made for regulators or on lawful request: retained as a permanent audit trail.
• Support chat records: the text of support conversations is retained for up to five (5) years, as evidence for dispute resolution, complaint handling, and regulatory record-keeping.
• Support attachments: files and images shared in support chat are automatically deleted from storage approximately twelve (12) months after the conversation is resolved.
• In-app history: the app displays your recent support history (approximately the last six months of resolved conversations); older records remain retained per the periods above but are not shown in the app.
• Analytics and crash data: kept in aggregated or pseudonymous form.

9. Your Rights

Under the NDPA you have the right to:

• Access the personal data we hold about you, and receive a copy of your transaction history and statements from the app.
• Ask us to correct inaccurate data; most profile details can be changed in Settings.
• Ask us to delete your data, from the app or at truepeer.app/data-deletion.
• Withdraw consent where processing is based on consent, for example by turning off location access on your device.
• Object to, or ask us to restrict, processing in certain circumstances.
• Lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you are dissatisfied with our response.

Deletion requests are honoured except where we are legally required to retain specific records (for example, KYC and transaction records under AML regulations). We answer requests within the time the NDPA allows and never charge for a first request.

10. Children

TruePeer is for people aged 18 and over. We do not knowingly collect personal data from anyone younger, and we close accounts we find to belong to a minor.

11. Compliance and Legal Obligations

TruePeer adheres to all applicable Nigerian laws, including:

• The Nigeria Data Protection Act 2023 and the Nigeria Data Protection Regulation
• Central Bank of Nigeria (CBN) guidelines applicable to our services and partners, including those for Virtual Asset Service Providers
• The Money Laundering (Prevention and Prohibition) Act and related AML/CFT regulations, including suspicious- and currency-transaction reporting

12. Changes to This Policy

We update this policy when our services or the law change. We will tell you about material changes in the app or by email before they take effect, and the "Last updated" date above always shows the current version.

13. Dispute Resolution

Any privacy-related dispute will first be resolved amicably with our support team. If unresolved, it will be settled in accordance with Nigerian law.

14. Contact Information