Introduction
Midescrow Ventures Ltd ("Midescrow," "we," "our," or "us") values your privacy and is committed to protecting your personal information. This Privacy Policy outlines how we collect, use, store, disclose, and protect your personal data when you use our platform, mobile application, and related services.
By using our services, you consent to the practices described in this Privacy Policy.
Legal Compliance
We process your data in accordance with the following data protection laws:
- Nigeria Data Protection Regulation (NDPR), 2019
- Nigeria Data Protection Act (NDPA), 2023
Midescrow acts as a Data Controller of your personal data.
What Data We Collect
Basic Information:
- Full name
- Email address
- Phone number
Identity Verification Data:
- BVN (Bank Verification Number)
- Date of birth
- Government-issued ID (e.g., NIN, international passport, driver's license)
- Utility bill or other proof of address
Transactional & Usage Data:
- Wallet transactions and transfers
- Escrow transaction history
- Virtual card usage
- Device and access logs (IP address, device type, timestamps)
How We Use Your Data
We use your personal data for the following lawful purposes:
- To verify your identity and fulfill Know-Your-Customer (KYC) obligations
- To provide core services such as escrow transactions, wallet services, and virtual card issuance
- To process and track your bill payments, transfers, and account upgrades
- To detect and prevent fraud, abuse, or illegal activities
- To communicate with you (transactional notifications, support, updates)
- To comply with legal or regulatory obligations
- For service improvement, analytics, and user experience personalization (non-identifiable data)
Data Sharing and Disclosure
We may share your data with trusted third parties only as necessary to provide our services:
- Partner banks and licensed financial institutions for wallet and account services
- Identity verification partners for KYC and fraud prevention
- Payment processors and telcos for VAS services like airtime and data
- Law enforcement or regulators as required by law or court order
We do not sell or rent your personal data to any third party.
Data Retention
We retain your personal data:
- As long as your account is active
- For a minimum of 5 years after account closure, to comply with regulatory and legal obligations (e.g., anti-fraud, tax, or audit trails)
After this period, your data will be securely deleted or anonymized.
Your Rights
As a data subject under the NDPR and NDPA, you have the right to:
- Access: Request a copy of your personal data
- Correct: Request correction of inaccurate or incomplete information
- Delete: Request deletion of your data, where applicable
- Withdraw Consent: Withdraw consent for specific data uses (e.g., marketing)
- Object: Object to processing based on legitimate interest
- Complain: Lodge a complaint with the Nigeria Data Protection Commission (NDPC)
To exercise your rights, contact us at: support@midescrow.com.ng
Security Measures
We use industry-standard security controls to protect your data:
- End-to-end encryption
- Secure socket layer (SSL) protocols
- Access controls and role-based permissions
- Regular audits and threat monitoring
However, no online system is 100% secure. Users must also protect their passwords and avoid sharing sensitive credentials.
Cookies and Tracking
Our app or website may use cookies or device identifiers to:
- Maintain your session
- Analyze user behavior (anonymously)
- Improve service performance
You can disable cookies in your browser or app settings, but some features may not function properly.
International Data Transfers
Your data is stored on secure servers located within Nigeria. If we ever need to transfer data internationally, it will only be to countries with adequate data protection or under strict legal safeguards.
Updates to This Policy
We may revise this Privacy Policy from time to time. When we do, we will update the "Effective Date" above and notify you via email or in-app alerts. Continued use of our platform after changes implies acceptance.
Contact Us
If you have any questions, requests, or concerns about your data or this Privacy Policy, please contact:
Data Protection Officer
Email: support@midescrow.com.ng
Phone: +234905229859
Office Address
GM Mall KM 46, Lekki-Epe Express Way, Sangotedo, Lagos