Terms and Conditions of Use

These Terms are subject to, and incorporate by reference, all applicable Nigerian laws and regulations, including without limitation:

• The Companies and Allied Matters Act 2020 (CAMA);
• The Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation 2019 (NDPR);
• The Cybercrime (Prohibition, Prevention, etc.) Act 2015 (as amended 2024);
• The Electronic Transactions Act (where applicable by State adoption and federal practice);
• The Federal Competition and Consumer Protection Act 2018 (FCCPA);
• The Central Bank of Nigeria (CBN) guidelines and circulars applicable to digital financial services, including the CBN Regulatory Framework for Open Banking in Nigeria 2021, the CBN Guidelines on Operations of Electronic Payment Channels, and all relevant CBN circulars;
• The Payment Service Banks (PSBs) Guidelines and the CBN Framework for the Regulation and Supervision of Mobile Money Services (as applicable);
• The Investment and Securities Act 2007 (ISA) and any successor legislation;
• The Consumer Protection Framework issued by the CBN and the Federal Competition and Consumer Protection Commission (FCCPC).

We reserve the right, in our sole discretion, to amend these Terms at any time. Material changes will be notified to you by email or by a prominent notice on the Platform at least fourteen (14) days before the amendment takes effect, except where a shorter notice period is necessitated by law or regulatory directive. Your continued use of the Services following the effective date of any revision constitutes your acceptance of the amended Terms.

Table of Contents

1. Our Services
2. Intellectual Property Rights
3. Account Registration and User Representations
4. Know Your Customer (KYC) and Anti-Money Laundering (AML)
5. Prohibited Activities
6. User-Generated Contributions and Submissions
7. Contribution Licence
8. Fees, Charges, and Payment Terms
9. Services Management
10. Term and Termination
11. Modifications and Service Interruptions
12. Data Protection and Privacy
13. Electronic Communications and Signatures
14. Governing Law
15. Dispute Resolution
16. Corrections
17. Disclaimer of Warranties
18. Limitations of Liability
19. Indemnification
20. Miscellaneous
21. Contact Us

1. Our Services

The Company provides a Software-as-a-Service (SaaS) platform offering processing, business management tools, financial analytics, digital lending, and related services to registered users within and outside the Federal Republic of Nigeria ("Services").

The Services are intended for use by individuals of legal age and incorporated entities lawfully operating in jurisdictions where the use of such services is permitted. The information and functionality provided through the Services are not directed at any person or entity in any jurisdiction where such access or use would contravene applicable law or regulation or subject the Company to any licensing or registration obligation in that jurisdiction. Persons who access the Services from outside Nigeria do so on their own initiative and are solely responsible for compliance with all applicable local laws.

The Company operates as a technology service provider. Where the Services facilitate financial transactions, payment processing, or similar regulated activities, the Company does so either under its own applicable licences or in partnership with duly licensed financial institutions, Mobile Money Operators (MMOs), Payment Service Providers (PSPs), or switching companies regulated by the Central Bank of Nigeria (CBN). Nothing in these Terms shall be construed as constituting the Company as a bank, deposit-taking institution, or financial adviser unless specifically stated and licensed accordingly.

2. Intellectual Property Rights

2.1 Our Intellectual Property

The Company is the owner or licensee of all intellectual property rights in the Services, including all source code, databases, algorithms, application programming interfaces (APIs), software, platform designs, audio, video, text, photographs, graphics, and data compilations (collectively, the "Content"), as well as the trademarks, service marks, trade names, and logos contained therein (the "Marks").

The Content and Marks are protected under the Copyright Act 2022 (Nigeria), the Trade Marks Act (Cap T13, LFN 2004), the Patents and Designs Act (Cap P2, LFN 2004), and equivalent intellectual property laws in other applicable jurisdictions. All rights not expressly granted to you herein are reserved by the Company.

2.2 Licence to Use the Services

Subject to your compliance with these Terms, the Company grants you a limited, non-exclusive, non-transferable, non-sublicensable, revocable licence to access and use the Services solely for your internal business operations or personal lawful use. This licence does not permit you to:

• copy, reproduce, adapt, modify, translate, create derivative works from, or publicly display any part of the Content;
• sublicence, sell, resell, transfer, assign, or otherwise commercially exploit the Services or Content;
• reverse-engineer, decompile, disassemble, or attempt to extract the source code of any software forming part of the Services, except as expressly permitted by applicable law;
• scrape, data-mine, or systematically extract data from the Services without prior written consent.

Any use of the Content or Marks not expressly authorised herein requires the Company's prior written consent. Requests should be directed to the management of Andata Innovative Solutions And Ventures Limited.

2.3 Your Submissions

By submitting any question, comment, suggestion, idea, or feedback regarding the Services ("Submissions"), you agree to assign to the Company all intellectual property rights in such Submission, to the fullest extent permitted by law. You acknowledge that the Company shall own such Submissions and may use them for any lawful purpose without obligation of compensation or acknowledgement to you.

You represent and warrant that your Submissions: (a) are original or that you hold all necessary rights to make such assignment; (b) do not infringe any third-party intellectual property rights; (c) do not constitute confidential information belonging to a third party; and (d) comply with all applicable Nigerian laws. You indemnify the Company against all losses arising from a breach of these warranties.

3. Account Registration and User Representations

To access certain features of the Services, you must register an account. By registering, you represent and warrant that:

• you are at least eighteen (18) years of age or have attained the legal age of majority in your jurisdiction of residence;
• if registering on behalf of a legal entity, you are duly authorised to bind that entity to these Terms;
• all information you provide during registration is true, accurate, current, and complete;
• you will maintain the accuracy of your information and promptly update it when necessary;
• you will keep your login credentials confidential and not share them with any third party;
• you will notify us immediately upon becoming aware of any unauthorised access to your account;
• your use of the Services will not violate any applicable law or regulation, including all CBN guidelines and FCCPC consumer protection rules;
• you are not subject to any sanctions list maintained by Nigeria's Office of the National Security Adviser (ONSA), the Nigerian Financial Intelligence Unit (NFIU), the United Nations Security Council, or any other competent authority.

The Company reserves the right to suspend or terminate your account and refuse any current or future access to the Services if any of the foregoing representations are found to be untrue, inaccurate, or incomplete.

4. Know Your Customer (KYC) and Anti-Money Laundering (AML)

In compliance with the Money Laundering (Prevention and Prohibition) Act 2022 (MLPPA), the Terrorism (Prevention and Prohibition) Act 2022, the NFIU guidelines, and all applicable CBN AML/CFT regulatory frameworks, the Company is required to verify the identity of its users before providing certain Services.

By using the Services, you agree to:

• provide valid government-issued identification documents (including but not limited to National Identity Number (NIN), Bank Verification Number (BVN), International Passport, or Driver's Licence) as may be required;
• submit to enhanced due diligence procedures where required by applicable law or regulatory directive, including where you are a Politically Exposed Person (PEP) or related to one;
• provide accurate information concerning the source of your funds and the nature of your business, as required;
• consent to the Company sharing your KYC information with licensed partner banks, CBN-regulated institutions, and competent law enforcement or regulatory authorities where required by law.

The Company reserves the right to suspend, restrict, or terminate access to the Services pending satisfactory completion of KYC verification. The Company shall not be liable for any losses arising from account suspension pending KYC compliance.

5. Prohibited Activities

You may access and use the Services only for lawful purposes and in accordance with these Terms. The following activities are strictly prohibited:

5.1 Financial Crime

• using the Services for money laundering, terrorism financing, or proliferation financing contrary to the MLPPA 2022 or the Terrorism (Prevention and Prohibition) Act 2022;
• facilitating Ponzi schemes, pyramid structures, or unlicensed investment solicitations;
• conducting unauthorised foreign exchange dealings contrary to the Foreign Exchange (Monitoring and Miscellaneous Provisions) Act;
• processing transactions for or on behalf of sanctioned persons or entities.

5.2 Cybercrime and System Integrity

• engaging in any act prohibited under the Cybercrime (Prohibition, Prevention, etc.) Act 2015 (as amended), including unauthorised access to computer systems, identity theft, phishing, and fraudulent electronic messages;
• uploading or transmitting malware, viruses, Trojan horses, ransomware, spyware, or any other malicious code;
• circumventing, disabling, or interfering with security features of the Services;
• attempting to gain unauthorised access to any part of the Services, user accounts, servers, or connected networks;
• conducting denial-of-service attacks or otherwise disrupting the availability of the Services.

5.3 Misrepresentation and Fraud

• providing false, misleading, or deceptive information in any registration or transaction, contrary to the FCCPA 2018;
• impersonating another person, user, or entity, or misrepresenting your affiliation with any person or entity;
• using the Services to commit fraud, obtain financial advantage by deception, or engage in any act constituting an offence under Nigerian criminal law.

5.4 Intellectual Property and Data

• reproducing, distributing, or commercially exploiting Content or Marks without authorisation;
• scraping, harvesting, or systematically collecting data from the Services without prior written consent;
• reverse-engineering or decompiling any software forming part of the Services, except as expressly permitted by law.

5.5 Regulatory Non-Compliance

• using the Services for any purpose that would require a licence or regulatory approval that you do not hold;
• facilitating transactions in violation of CBN directives on virtual assets, digital currencies, or other regulated instruments, as issued from time to time;
• using the Services to offer financial products or services to the public without applicable regulatory authorisation.

5.6 General Misuse

• using the Services to harass, threaten, defame, or harm any person;
• using the Services in connection with any illegal gambling, obscene, or adult-content platforms;
• using the Services to send unsolicited bulk communications (spam) in violation of the Nigerian Communications Commission (NCC) regulations;
• any use of the Services that creates an undue burden on our infrastructure or that competes with the Company's business without prior written agreement.

The Company reserves the right to investigate suspected violations and report them to relevant authorities including the EFCC, NFIU, CBN, FCCPC, or law enforcement agencies, as appropriate.

6. User-Generated Contributions and Submissions

Where the Services permit you to create, upload, post, transmit, or otherwise make available content, data, or materials ("Contributions"), you agree that your Contributions shall:

• be accurate, lawful, and not misleading;
• not infringe the intellectual property rights, privacy rights, or any other rights of any third party;
• not contain material that is defamatory, obscene, hateful, discriminatory, or in violation of any applicable Nigerian law including the Criminal Code Act and the Penal Code (Northern States) Federal Provisions Act;
• not constitute unsolicited advertising or promotional material;
• not contain personal data of third parties without their prior, freely given, and informed consent as required under the NDPA 2023.

You retain ownership of your Contributions. By making a Contribution available on the Services, you grant the Company a worldwide, royalty-free, non-exclusive licence to host, store, process, and display such Contributions solely to the extent necessary to provide and improve the Services. The Company does not endorse any Contribution and is not liable for the content of any Contribution made by you or any other user.

7. Contribution Licence

You and the Company agree that the Company may access, store, process, and use any information and personal data that you provide in accordance with our Privacy Notice and your expressed choices (including your account settings).

By submitting feedback, suggestions, or other input regarding the Services, you agree that the Company may use and share such feedback for any lawful purpose without obligation of compensation to you.

The Company does not claim ownership over your Contributions. You retain full ownership of all intellectual property rights in your Contributions. We are not liable for any statements or representations contained in your Contributions. You are solely responsible for your Contributions and expressly agree to exonerate the Company from and refrain from bringing any legal action against the Company in respect of your Contributions.

8. Fees, Charges, and Payment Terms

Access to certain features of the Services is subject to subscription fees, transaction charges, or other fees as set out in the pricing schedule published on the Platform from time to time ("Fees"). All Fees are stated in Nigerian Naira (₦) unless otherwise specified.

By subscribing to a paid tier or initiating a chargeable transaction, you authorise the Company (or its licensed payment processor) to debit the applicable Fees from your designated payment method. You are responsible for ensuring that sufficient funds are available.

The Company reserves the right to revise its Fees at any time upon at least thirty (30) days' prior written notice. Continued use of the Services after the effective date of a Fee revision constitutes acceptance of the revised Fees.

All Fees are non-refundable except: (a) where required by the Consumer Protection Framework issued by the CBN or FCCPC; (b) where the Services were unavailable for a material portion of a billing period due to the Company's fault; or (c) as otherwise expressly stated in a separate agreement with you.

All applicable taxes (including VAT at the applicable rate under the Value Added Tax Act, Cap V1, LFN 2004, as amended) are included in or added to the stated Fees as indicated on the Platform.

9. Services Management

The Company reserves the right, but not the obligation, to:

• monitor the Services for violations of these Terms or applicable law;
• take appropriate legal or regulatory action against any user who, in the Company's reasonable determination, violates these Terms, including reporting such user to the EFCC, NFIU, CBN, FCCPC, the Nigerian Police Force, or other competent authorities;
• refuse, restrict, or limit access to the Services or any feature thereof, including disabling Contributions or account functionality, without notice and without liability;
• remove or disable any Content or Contributions that are excessive in size, technically burdensome, or otherwise in violation of these Terms; and
• manage the Services in a manner designed to protect the rights, safety, and property of the Company, its partners, and its users.

10. Term and Termination

These Terms shall remain in full force and effect for so long as you access or use the Services.

WITHOUT LIMITING ANY OTHER PROVISION OF THESE TERMS, THE COMPANY RESERVES THE RIGHT, IN ITS SOLE DISCRETION AND WITHOUT NOTICE OR LIABILITY, TO DENY, SUSPEND, OR TERMINATE YOUR ACCESS TO AND USE OF THE SERVICES, INCLUDING BLOCKING SPECIFIC IP ADDRESSES, FOR ANY REASON, INCLUDING BREACH OF ANY REPRESENTATION, WARRANTY, OR OBLIGATION CONTAINED IN THESE TERMS, ANY APPLICABLE LAW OR REGULATION, OR CBN OR FCCPC DIRECTIVES.

Upon termination:

• your right to access and use the Services ceases immediately;
• you must cease all use of the Services and, where applicable, delete all downloaded Content;
• the Company may, subject to applicable data retention obligations under the NDPA 2023 and applicable CBN and NFIU record-keeping requirements, delete or anonymise your account data;
• you remain liable for all fees and obligations accrued prior to the date of termination.

You may terminate your account at any time by following the account closure procedure on the Platform. Closure is subject to the resolution of any outstanding transactions, fees, or regulatory holds.

11. Modifications and Service Interruptions

The Company reserves the right to modify, update, suspend, or discontinue the Services or any feature thereof at any time and for any reason. Where practicable, the Company will provide reasonable advance notice of material changes. The Company shall not be liable for any loss, damage, or inconvenience arising from the modification, suspension, or discontinuation of the Services.

The Company does not guarantee that the Services will be available at all times. Maintenance, system upgrades, regulatory compliance activities, or circumstances beyond our control may result in downtime or service degradation. We will endeavour to communicate planned maintenance via the Platform or by email.

12. Data Protection and Privacy

The Company processes personal data in accordance with the Nigeria Data Protection Act 2023 (NDPA), the Nigeria Data Protection Regulation 2019 (NDPR), and the provisions of our Privacy Notice (available on this website), which is incorporated into these Terms by reference.

By using the Services, you acknowledge that the Company may collect, process, store, and share your personal data for the purposes set out in the Privacy Notice, including for the purpose of complying with KYC, AML, and other regulatory obligations. Where the Company acts as a data controller, it will do so on the bases of consent, contractual necessity, legal obligation, or legitimate interest, as applicable.

The Company has designated a Data Protection Officer (DPO) who may be contacted at dpo@andatainnovative.com. You have the right to access, correct, delete, restrict, or object to the processing of your personal data, subject to applicable legal and regulatory exceptions, by writing to the DPO.

The Company shall maintain appropriate technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. In the event of a data breach affecting your personal data, the Company will notify you and the Nigeria Data Protection Commission (NDPC) in accordance with its obligations under the NDPA 2023.

13. Electronic Communications and Signatures

Accessing the Services, submitting online forms, and communicating with us by email or through the Platform all constitute electronic communications. You consent to receive communications from us electronically. You agree that all agreements, notices, disclosures, and other communications provided to you electronically satisfy any legal requirement that such communications be in writing, to the extent permitted under applicable Nigerian law.

You agree to the use of electronic signatures, contracts, authorisations, and records in connection with your use of the Services. Electronic signatures and records created or stored in connection with the Services shall have the same legal effect as hand-written signatures and paper records, to the extent recognised under Nigerian law, including the Evidence Act 2011 (as amended) and applicable CBN guidelines on electronic banking.

14. Governing Law

These Terms shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria. The Parties irrevocably submit to the non-exclusive jurisdiction of the Federal High Court of Nigeria and the High Court of the Federal Capital Territory, Abuja, in respect of any dispute arising out of or in connection with these Terms, without prejudice to the Company's right to seek injunctive or other equitable relief in any competent court.

15. Dispute Resolution

15.1 Informal Resolution

Before initiating any formal legal or arbitral proceedings, the Parties shall first attempt in good faith to resolve any dispute, controversy, or claim arising out of or relating to these Terms or the Services ("Dispute") through direct negotiation. Either Party may initiate informal resolution by providing written notice to the other Party, identifying the Dispute in reasonable detail. The Parties shall have thirty (30) days from the date of such notice (or such longer period as they may agree in writing) to attempt resolution.

15.2 Complaints to Regulatory Bodies

Nothing in this clause limits your right to escalate a complaint to the Consumer Protection Department of the CBN, the FCCPC, the NDPC, or any other competent Nigerian regulatory authority. The Company undertakes to cooperate fully with any such regulatory inquiry or investigation.

15.3 Arbitration

If a Dispute is not resolved through informal negotiation within the thirty (30) day period, it shall be referred to and finally resolved by arbitration under the Arbitration and Mediation Act 2023 (Nigeria) and the rules of the Lagos Court of Arbitration or the Arbitration and Conciliation Centre (Abuja), as the Parties may agree. The arbitration shall be conducted by a sole arbitrator mutually agreed upon by the Parties or, failing agreement within fourteen (14) days of referral, appointed in accordance with the applicable arbitration rules. The seat of arbitration shall be Abuja, Nigeria. The language of the proceedings shall be English. The arbitral award shall be final and binding.

15.4 Exceptions

The following Disputes shall not be subject to arbitration and may be brought before a court of competent jurisdiction: (a) claims for injunctive or other urgent equitable relief; (b) disputes relating to the validity or enforcement of the Company's intellectual property rights; and (c) claims arising from allegations of fraud, cybercrime, or other criminal conduct.

15.5 No Class Action

Each Party agrees that any Dispute shall be resolved on an individual basis only. No Dispute shall be consolidated with any other proceeding, and neither Party shall seek to have a Dispute heard as a class or representative action.

16. Corrections

The Platform may contain information with typographical errors, inaccuracies, or omissions, including in relation to descriptions, pricing, availability, or other details. The Company reserves the right to correct any such errors, inaccuracies, or omissions and to update information on the Platform at any time without prior notice.

17. Disclaimer of Warranties

THE SERVICES ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE NIGERIAN LAW, THE COMPANY EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.

THE COMPANY MAKES NO WARRANTY THAT: (A) THE SERVICES WILL MEET YOUR REQUIREMENTS; (B) THE SERVICES WILL BE UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE; (C) THE RESULTS OBTAINED FROM THE USE OF THE SERVICES WILL BE ACCURATE OR RELIABLE; OR (D) ANY ERRORS IN THE SERVICES WILL BE CORRECTED.

NOTHING IN THESE TERMS EXCLUDES OR LIMITS ANY WARRANTY OR LIABILITY THAT CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE NIGERIAN LAW, INCLUDING CONSUMER RIGHTS UNDER THE FEDERAL COMPETITION AND CONSUMER PROTECTION ACT 2018 AND CBN CONSUMER PROTECTION FRAMEWORK.

18. Limitations of Liability

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE NIGERIAN LAW, THE COMPANY, ITS DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, PARTNERS, AND AFFILIATES SHALL NOT BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, INCLUDING LOSS OF PROFIT, LOSS OF REVENUE, LOSS OF DATA, LOSS OF BUSINESS, OR BUSINESS INTERRUPTION, ARISING OUT OF OR IN CONNECTION WITH YOUR USE OF OR INABILITY TO USE THE SERVICES, EVEN IF THE COMPANY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

NOTWITHSTANDING THE FOREGOING, THE COMPANY'S TOTAL AGGREGATE LIABILITY TO YOU FOR ANY CLAIMS ARISING OUT OF OR IN CONNECTION WITH THESE TERMS OR THE SERVICES SHALL NOT EXCEED THE TOTAL FEES PAID BY YOU TO THE COMPANY IN THE THREE (3) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR FIFTY THOUSAND NAIRA (₦50,000), WHICHEVER IS GREATER.

The limitations of liability set out above shall not apply to liability for: (a) death or personal injury caused by the Company's negligence; (b) fraud or fraudulent misrepresentation by the Company; or (c) any other liability that cannot be limited or excluded under applicable Nigerian law.

19. Indemnification

You agree to defend, indemnify, and hold harmless the Company, its subsidiaries, affiliates, and their respective directors, officers, employees, agents, licensors, and service providers, from and against any and all claims, liabilities, damages, losses, costs, and expenses (including reasonable legal fees) arising out of or relating to:

• your use or misuse of the Services;
• your breach of these Terms or any applicable law or regulation;
• your breach of any representation or warranty made herein;
• your infringement of any third-party intellectual property, privacy, or other rights;
• any Contribution you submit that causes harm to a third party;
• any regulatory penalty or sanction imposed on the Company as a direct result of your non-compliance with applicable law.

The Company reserves the right, at your expense, to assume sole control of the defence of any matter subject to indemnification hereunder. You agree to cooperate fully with the Company in the defence of any such claim. The Company shall use reasonable efforts to notify you of any claim, action, or proceeding subject to this indemnification upon becoming aware of it.

20. Miscellaneous

Entire Agreement: These Terms, together with the Privacy Notice, any applicable Service Level Agreement, and any other policies or operating rules posted on the Platform, constitute the entire agreement between you and the Company with respect to the Services and supersede all prior agreements, representations, and understandings.

Waiver: The Company's failure to exercise or enforce any right or provision of these Terms shall not operate as a waiver of such right or provision. No waiver shall be effective unless made in writing and signed by an authorised representative of the Company.

Severability: If any provision of these Terms is found to be unlawful, void, or unenforceable under applicable Nigerian law, that provision shall be severed from these Terms to the minimum extent necessary, and the remaining provisions shall continue in full force and effect.

Assignment: The Company may assign any of its rights and obligations under these Terms to an affiliate, successor entity, or acquirer without your consent. You may not assign or transfer your rights or obligations under these Terms without the Company's prior written consent.

Force Majeure: The Company shall not be liable for any delay or failure in performance resulting from causes beyond its reasonable control, including acts of God, government action, regulatory directives, telecommunications failures, power outages, civil unrest, or acts of third parties.

No Agency: Nothing in these Terms creates a joint venture, partnership, employment, or agency relationship between you and the Company.

Regulatory Compliance: The Company is committed to conducting its business in full compliance with all applicable Nigerian laws and regulations. These Terms shall be interpreted and applied consistently with such compliance obligations, and any provision found to be inconsistent with a mandatory regulatory requirement shall be modified to the minimum extent necessary to ensure compliance.

21. Contact Us

To report a complaint regarding the Services, exercise your data rights, or obtain further information about these Terms, please contact us at:

Andata Innovative Solutions And Ventures Limited
10B Sakono Street, Wuse II, Abuja, FCT, Nigeria
Email: info@andatainnovative.com
Data Protection Officer: dpo@andatainnovative.com

We aim to acknowledge all written complaints within five (5) working days and to resolve them within thirty (30) working days. Where a complaint cannot be resolved within that period, we will inform you of the reason for the delay and the expected resolution date.

© 2026 Andata Innovative Solutions And Ventures Limited. All rights reserved.

Privacy Policy

This Privacy Notice for Andata Innovative Solutions And Ventures Limited ("we", "us", or "our") describes how and why we collect, store, use, and share your personal information when you use our services ("Services"), including when you:

• Download and use our mobile application (Mango) or any other application of ours that links to this Privacy Notice;
• Use our software platform, APIs, SDKs, or technology integration services;
• Purchase, resell, or distribute digital vending products and services including airtime, data bundles, utility payments, electricity tokens, examination pins, subscriptions, or related value-added services; or
• Engage with us in other related ways, including any marketing or events.

Questions or concerns? If you have any questions after reading this Privacy Notice, please contact us using the details in Section 14. If you do not agree with our policies and practices, please do not use our Services.

Applicable Law

Andata Innovative Solutions And Ventures Limited is incorporated in Nigeria and primarily subject to the Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation (NDPR). Where our services are accessed by users in the European Economic Area (EEA), the United Kingdom (UK), or other jurisdictions, the additional legal bases and rights described in the relevant sections below also apply.

Summary of Key Points

What personal information do we process? We collect personal information you voluntarily provide (such as names, contact details, and payment data) as well as information collected automatically when you use our Services.

Do we process sensitive personal information? We may process certain sensitive information (such as financial data or biometric data) where necessary, with your consent, or as otherwise permitted by applicable law.

Do we collect information from third parties? We may obtain information from public databases, marketing partners, social media platforms, and other outside sources to supplement and update our records.

How do we process your information? We process your information to provide and improve our Services, communicate with you, prevent fraud, and comply with applicable law. We only process information when we have a valid legal basis.

With whom do we share your information? We may share information with service providers, affiliates, business partners, and other third parties in specific circumstances described in Section 4.

How do we keep your information safe? We apply appropriate technical and organisational security measures. However, no electronic transmission or storage system is 100% secure.

What are your rights? Depending on your location, you may have rights to access, correct, delete, or restrict the processing of your personal information.

Table of Contents

1. What Information Do We Collect?
2. How Do We Process Your Information?
3. What Legal Bases Do We Rely On to Process Your Personal Information?
4. When and With Whom Do We Share Your Personal Information?
5. Do We Use Cookies and Other Tracking Technologies?
6. Do We Offer Artificial Intelligence-Based Products?
7. How Do We Handle Your Social Logins?
8. How Long Do We Keep Your Information?
9. How Do We Keep Your Information Safe?
10. What Are Your Privacy Rights?
11. Controls for Do-Not-Track Features
12. Do United States Residents Have Specific Privacy Rights?
13. Do We Make Updates to This Notice?
14. How Can You Contact Us About This Notice?
15. How Can You Review, Update, or Delete Your Data?

1. What Information Do We Collect?

Personal Information You Disclose to Us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide when you register on the Services, express an interest in our products or Services, participate in activities on the Services, or otherwise contact us. The personal information we collect may include:

• Names
• Phone numbers
• Email addresses
• Mailing addresses
• Job titles
• Usernames and passwords
• Contact preferences
• Billing addresses
• Debit/credit card numbers (see Payment Data below)

Sensitive Information

Where necessary, and with your consent or as otherwise permitted by applicable law, we may process the following categories of sensitive personal information:

• Financial data and credit-worthiness data
• Biometric data (where applicable)
• Student data
• Information revealing trade union membership

Payment Data

We may collect data necessary to process your payments, such as your payment instrument number and associated security code. Payment transactions are processed by our third-party payment processor(s). You should review their privacy notice(s) for information on how they handle your payment data.

Social Media Login Data

We may give you the option to register using your existing social media account (e.g. Facebook or X). If you choose to do so, we will collect certain profile information from that provider as described in Section 7.

Application Data

If you use our mobile application(s), we may collect the following information if you grant us the relevant access or permission:

Geolocation Information: We may request permission to track location-based information from your device to provide location-based services. You can withdraw this permission at any time in your device settings.

Mobile Device Access: We may request access to features such as your camera, contacts, microphone, SMS messages, and storage. You can manage these permissions in your device settings.

Mobile Device Data: We automatically collect device information including device ID, model, manufacturer, operating system, browser type, IP address, and app usage data. This is used to maintain security, troubleshoot issues, and conduct internal analytics.

Information Collected Automatically

In Short: Some information — such as your IP address and browser characteristics — is collected automatically when you visit our Services.

We automatically collect certain technical information when you visit or use the Services. This includes:

Log and Usage Data: IP address, device information, browser type, pages viewed, date/time stamps, and other activity data recorded in server log files.

Device Data: Information about your computer, phone, or tablet including hardware model, operating system, and network information.

Location Data: General location derived from your IP address. More precise location is only collected if you grant permission. You may opt out via your device settings, though this may limit certain features.

Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

Information Collected from Other Sources

In Short: We may collect limited data from public databases, marketing partners, and social media platforms.

To provide relevant marketing and keep our records current, we may obtain information about you from public databases, joint marketing partners, affiliate programmes, data providers, and social media platforms. This may include mailing addresses, job titles, email addresses, phone numbers, IP addresses, and social media profiles used for targeted advertising and event promotion.

If you interact with us via a social media platform, we may receive your name, email address, and other profile information permitted by your privacy settings on that platform. Their use of your information is governed by their own privacy policies, not this Notice.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, prevent fraud, and comply with law.

We process your personal information for the following purposes:

• Account creation and authentication: To allow you to create and log in to your account and keep it operational.
• Service delivery: To provide the services you have requested.
• Customer support: To respond to your inquiries and resolve issues.
• Order fulfilment: To process and manage your orders, payments, returns, and exchanges.
• User-to-user communications: To enable communications between users where applicable.
• Feedback: To request feedback about your experience with our Services.
• Marketing communications: To send promotional communications in line with your preferences. You may opt out at any time (see Section 10).
• Targeted advertising: To display personalised content and advertisements based on your interests and location.
• Usage analytics: To understand how our Services are used so we can improve them.
• Campaign effectiveness: To measure the performance of our marketing and promotional campaigns.
• Safety and vital interests: To protect the vital interests of users or third parties where necessary.

3. What Legal Bases Do We Rely On to Process Your Personal Information?

In Short: We only process your information when we have a valid legal reason to do so.

Nigeria (NDPA / NDPR)

As a Nigerian company, our primary legal obligations are governed by the Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation (NDPR). We process personal information on the basis of:

• Consent: Where you have given clear, informed, and specific consent to the processing.
• Contract: Where processing is necessary to perform a contract with you or to take steps at your request before entering a contract.
• Legal obligation: Where processing is necessary to comply with a legal or regulatory obligation.
• Legitimate interest: Where processing is necessary for our legitimate business interests, provided your rights and interests are not overridden.
• Vital interests: Where processing is necessary to protect the vital interests of you or another person.

European Economic Area and United Kingdom (GDPR / UK GDPR)

If you are located in the EEA or UK, we additionally rely on the following legal bases:

• Consent (Art. 6(1)(a)): Where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Contract (Art. 6(1)(b)): Where processing is necessary to fulfil or prepare a contract with you.
• Legitimate Interests (Art. 6(1)(f)): For purposes such as: sending information about offers and discounts; developing and displaying personalised advertising; analysing service usage to improve engagement and retention; supporting marketing activities; and understanding how users interact with our products.
• Legal Obligations (Art. 6(1)(c)): Where required to comply with applicable law, cooperate with regulators, exercise legal rights, or present evidence in litigation.
• Vital Interests (Art. 6(1)(d)): Where necessary to protect the vital interests of you or a third party.

Withdrawing Consent

Where we rely on your consent as a legal basis, you may withdraw it at any time by contacting us using the details in Section 14. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

4. When and With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations with specific categories of third parties.

We may share your personal information with the following categories of third parties:

• Ad Networks
• Cloud Computing Services
• Data Analytics Services
• Payment Processors
• Performance Monitoring Tools
• User Account Registration and Authentication Services
• Testing Tools

We may also share your information in the following circumstances:

Business Transfers: In connection with any sale, financing, or acquisition of all or part of our business.

Google Maps Platform: Where we use Google Maps Platform APIs (e.g. Maps API, Places API), your location data may be processed by Google. We cache location data on your device; you may revoke consent by contacting us.

Affiliates: With our parent company, subsidiaries, or joint venture partners, who are required to honour this Privacy Notice.

Business Partners: To offer you certain products, services, or promotions.

Other Users: If you share personal information in public areas of the Services, that information may be visible to other users and publicly accessible.

Offer Wall: Our application may display a third-party offer wall. When you interact with it, a unique identifier (such as your user ID) will be shared with the offer wall provider to prevent fraud and credit your account.

5. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and similar tracking technologies to collect and store your information.

We may use cookies, web beacons, and pixels to gather information when you interact with our Services. These technologies help us maintain security, prevent crashes, save preferences, and support core site functions.

We also permit third-party service providers to use tracking technologies on our Services for analytics and advertising purposes, including managing and displaying ads tailored to your interests and sending abandoned shopping cart reminders (subject to your communication preferences).

Where these technologies are considered a "sale" or "sharing" under applicable US state privacy laws, you may opt out as described in Section 12. For detailed information on the specific technologies used and how to manage your cookie preferences, please refer to our Cookie Notice.

6. Do We Offer Artificial Intelligence-Based Products?

In Short: We offer products, features, or tools powered by artificial intelligence or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence (AI) and machine learning ("AI Products"). These tools are designed to enhance your experience and provide innovative solutions. Our AI Products are used for the following functions:

• AI applications
• AI deployment
• AI-assisted data processing and analytics

All personal information processed using our AI Products is handled in accordance with this Privacy Notice and our agreements with relevant third-party providers. Where AI processing involves significant or systematic processing of personal data, we conduct or maintain an appropriate Data Protection Impact Assessment (DPIA) in line with applicable law.

7. How Do We Handle Your Social Logins?

In Short: If you register or log in using a social media account, we may receive certain information from that provider.

Where you choose to register or log in using a third-party social media account (such as Facebook, Instagram, or X), we will receive profile information from that provider. This typically includes your name, email address, friends list, and profile picture, as well as any other information you have made public on that platform.

We use this information only as described in this Privacy Notice. We do not control, and are not responsible for, the social media provider's use of your information. We recommend reviewing their privacy notice to understand how they handle your data and how you can manage your privacy settings on their platforms.

8. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfil the purposes described in this Notice, unless a longer period is required or permitted by law.

We retain personal information only for as long as it is necessary for the purposes set out in this Privacy Notice, subject to any longer retention period required by law (e.g. for tax, accounting, or regulatory compliance). Our standard retention periods are:

• Account information (Category B): Retained for the duration of your account with us, plus any legally mandated period after closure.
• Internet/network activity (Category F): Retained for up to 1 year.
• Financial transaction records: Retained for the period required by applicable financial and tax laws.

When we no longer have a legitimate business need or legal basis to retain your information, we will delete or anonymise it. Where immediate deletion is not possible (e.g. data stored in backup archives), we will securely isolate the data from further processing until deletion is possible.

9. How Do We Keep Your Information Safe?

In Short: We implement appropriate technical and organisational security measures to protect your personal information.

We have implemented reasonable and appropriate technical and organisational security measures to protect the personal information we process. These include access controls, encryption, and regular security reviews.

Despite these safeguards, no electronic transmission over the internet or information storage system can be guaranteed to be 100% secure. We cannot guarantee that unauthorised third parties will never be able to circumvent our security measures. You should access our Services only within a secure environment, and you transmit personal information to us at your own risk.

10. What Are Your Privacy Rights?

In Short: Depending on your location, you have rights regarding your personal information including rights to access, correct, delete, and restrict processing.

Rights Under Nigerian Law (NDPA / NDPR)

If you are located in Nigeria, you have the right to:

• Request access to your personal information and obtain a copy;
• Request correction of inaccurate or incomplete personal information;
• Request deletion of your personal information where it is no longer necessary;
• Withdraw consent at any time (where processing is based on consent);
• Object to or restrict certain processing activities;
• Lodge a complaint with the Nigeria Data Protection Commission (NDPC).

Rights Under EEA / UK Law (GDPR / UK GDPR)

If you are located in the EEA or UK, you also have the right to:

• Access your personal information and obtain a copy (Art. 15 GDPR);
• Rectification of inaccurate data (Art. 16 GDPR);
• Erasure ("right to be forgotten") (Art. 17 GDPR);
• Restriction of processing (Art. 18 GDPR);
• Data portability (Art. 20 GDPR);
• Object to processing based on legitimate interests (Art. 21 GDPR);
• Not be subject to solely automated decision-making with significant effects (Art. 22 GDPR).

If you believe we are unlawfully processing your data, you may also lodge a complaint with your local data protection authority (EEA Member State authority or the UK ICO). Swiss residents may contact the Federal Data Protection and Information Commissioner (FDPIC).

Opting Out of Marketing

You may opt out of marketing and promotional communications at any time by clicking the unsubscribe link in any marketing email, or by contacting us using the details in Section 14. Please note that we may still send you non-marketing communications necessary for the administration of your account.

Account Information

You may review or update your account information by logging in to your account settings. To terminate your account, please contact us. Upon your request, we will deactivate or delete your account and associated data from our active databases, subject to retention of certain information as required for fraud prevention, legal compliance, or dispute resolution.

Cookies

Most browsers accept cookies by default. You can usually configure your browser to remove or reject cookies, though this may affect certain features of our Services.

Exercising Your Rights

To exercise any of the rights described above, please contact us using the details in Section 14 or submit a data subject access request. We will respond in accordance with applicable data protection law.

11. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature that signals your preference not to have your online browsing activities tracked. As no uniform technology standard for recognising DNT signals has been finalised, we do not currently respond to DNT signals.

California law requires us to disclose our response to DNT signals. At this time, we do not respond to such signals. If a recognised standard is adopted in future, we will update this Notice accordingly.

12. Do United States Residents Have Specific Privacy Rights?

In Short: Residents of certain US states have additional rights regarding their personal information.

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, applicable state privacy laws may grant you additional rights, including the right to:

• Know whether we are processing your personal data;
• Access your personal data;
• Correct inaccuracies in your personal data;
• Request deletion of your personal data;
• Obtain a copy of the personal data you have previously shared with us;
• Opt out of targeted advertising, the sale of personal data, or profiling that produces significant legal or similar effects;
• Non-discrimination for exercising any of the above rights.

Categories of Personal Information Collected (Past 12 Months)

How to Exercise Your Rights

To exercise your rights under applicable US state law, please contact us using the details in Section 14 or submit a data subject access request. You may also designate an authorised agent to make a request on your behalf, provided the agent submits proof of valid authorisation.

Request Verification

Upon receiving a request, we will verify your identity using the information provided. If we cannot verify your identity from existing records, we may ask for additional information for security and fraud-prevention purposes.

Appeals

If we decline to act on your request, you may appeal our decision by emailing us at the address in Section 14. We will respond in writing with our decision and reasoning. If your appeal is denied, you may submit a complaint to your state attorney general.

California 'Shine The Light' Law

California Civil Code Section 1798.83 permits California residents to request, once per year and free of charge, information about any personal information we disclosed to third parties for direct marketing purposes during the preceding calendar year. To make such a request, please contact us in writing using the details in Section 14.

13. Do We Make Updates to This Notice?

In Short: Yes, we will update this Notice as necessary to stay compliant with applicable law.

We may update this Privacy Notice from time to time. The updated version will be indicated by a revised "Last Revised" date at the top of this Notice. Where we make material changes, we will notify you either by posting a prominent notice or by sending you a direct notification. We encourage you to review this Notice periodically to stay informed about how we protect your information.

14. How Can You Contact Us About This Notice?

If you have questions or comments about this Notice, or wish to exercise any of your privacy rights, you may contact our Data Protection Officer (DPO):

Organisation: Andata Innovative Solutions And Ventures Limited
Role: Data Protection Officer (DPO)
Email: dpo@andatainnovative.com
Postal address: 10B Sakono Street, Wuse II, Abuja, FCT, Nigeria

15. How Can You Review, Update, or Delete Your Data?

Depending on the laws applicable in your country or state of residence, you may have the right to request access to, correction of, or deletion of the personal information we hold about you. You may also have the right to withdraw your consent to our processing of your personal information.

To submit a request, please complete and submit a data subject access request form, or contact us directly using the details in Section 14. These rights may be limited in certain circumstances by applicable law.