GoTap Privacy Policy

1. Introduction

TapprX Limited ("GoTap", "We", "Us", or "Our") is committed to protecting the privacy and security of your personal data. This Privacy Policy outlines how we collect, use, store, share, and protect your information when you use our mobile application, website and payment services (collectively, the "Services").

GoTap supports personal and business payments by QR, phone-to-phone Tap on supported Android devices, Near Payments and transfers to Nigerian bank accounts. GoTap AI prepares payment details for you to review and confirm. By accessing or using our Services, you consent to the data practices described in this policy.

2. Consent

By downloading the GoTap App, signing up as a User or Merchant, or using our payment services, you explicitly consent to the collection, processing, and storage of your personal data as defined in this Policy. You have the right to withdraw your consent at any time, subject to legal and contractual restrictions (see Section 9).

3. Information We Collect

To provide a secure, compliant, and seamless payment experience, we collect the following categories of data:

3.1. Identity & Verification Data (KYC)

1. Personal Information: Full Name, Date of Birth, Gender, Email Address, Phone Number.
2. Government Identifiers: Bank Verification Number (BVN), National Identification Number (NIN), Tax Identification Number (TIN).
3. Identity Checks and Device Authentication: Facial images submitted for identity or liveness checks. Optional fingerprint or face authentication is performed on your device; GoTap uses the authentication result rather than receiving your fingerprint or Face ID biometric template.
4. Merchant Documents: Certificate of Incorporation (CAC), Memorandum of Association, and Director details.

3.2. Transaction & Financial Data

1. Wallet Data: Wallet balance, funding sources, and withdrawal history.
2. Transaction Logs: Details of payments made and received, including timestamps, amounts, counterparty details, and payment methods (NFC/QR/Transfer).
3. Bank Account Details: NUBAN numbers linked for funding or settlement.

3.3. Device & Location Data

1. Location: Location information provided by your device for features such as Near Payments, or when requested during a payment. Follow the permissions shown in the app and use the Near Payments availability control to choose when you are discoverable to nearby GoTap users.
2. Device Fingerprint: IP address, device model, operating system version, IMEI, and unique device identifiers.

3.4. Usage & Interaction Data

1. GoTap AI: Text, voice and image inputs provided to our AI interface (e.g., "Send 5k to David"). These inputs are interpreted to prepare payment details for your review. A payment requires your confirmation before it is sent.
2. App Analytics: Clickstreams, feature usage, and error logs.

4. How We Use Your Information

We use your data for specific, lawful purposes:

• Service Delivery: To process payments via NFC, QR, and Transfers; to manage your Wallet; and to provide the Merchant Dashboard.
• Regulatory Compliance: To verify your identity (KYC) against NIBSS and NIMC databases as required by the CBN.
• Fraud Prevention: To monitor transaction velocity, detect location mismatches, and prevent money laundering (AML) and terrorist financing (CFT).
• Business Customer Records: To create or update a customer's payment history when a business sale completes.
• Bank Transfers: To process your requests to send money to Nigerian bank accounts and provide a transaction record.
• Communication: To send transaction receipts, security alerts (OTPs), and critical service updates.

5. Data Sharing & Disclosure

We do not sell your personal data. We only share data with the following entities under strict data processing agreements:

• Financial Institutions & Settlement Partners: We share the transaction information needed by banks and payment providers to process the transfers you request. For questions about the providers supporting your account, contact hello@usegotap.com.
• Regulatory Authorities: We are legally obligated to share data with the Central Bank of Nigeria (CBN), Nigeria Inter-Bank Settlement System (NIBSS), and the Nigerian Financial Intelligence Unit (NFIU) for reporting and fraud monitoring.
• Service Providers: Third-party vendors who provide critical infrastructure (e.g., Cloud Hosting, Identity Verification, SMS Gateways). These partners are bound by confidentiality obligations.
• Legal Requests: We may disclose data if required by a court order or legal process.

6. Data Retention

In compliance with the Money Laundering (Prohibition) Act and CBN guidelines, we are required to retain transaction and KYC records for a minimum of five (5) years after the termination of the business relationship.

After the retention period expires, data will be securely deleted or anonymised for statistical analysis.

7. Data Security

GoTap provides account and payment controls to help protect your access:

• PINs: Use your login PIN to access the app and your transaction PIN to authorise payments. Keep both private.
• Biometrics: You can enable supported fingerprint or face authentication in Privacy & Security. Follow the authentication prompts shown on your device.
• Payment Review: Check the recipient, amount, any fee and total debit before confirming a payment.
• Support: Contact hello@usegotap.com if you lose access or see an unrecognised transaction. Never include a PIN or verification code in a support message.

8. International Data Transfers

GoTap operates primarily in Nigeria. However, some of our cloud infrastructure or service providers may be located outside Nigeria. In such cases, we ensure that the transfer complies with the Nigeria Data Protection Act (NDPA) 2023, utilising standard contractual clauses to ensure your data remains protected.

9. Your Rights

Under the Nigeria Data Protection Act, you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion of your data (subject to our legal retention obligations outlined in Section 6).
• Restrict Processing: Request that we limit how we use your data.
• Portability: Request your data in a structured, machine-readable format.
• Withdraw Consent: You may withdraw consent for marketing or non-essential processing at any time. Note: Withdrawing consent for mandatory items (like BVN or Location) may result in the inability to use GoTap.

To exercise these rights, contact our Data Protection Officer at: hello@usegotap.com.

10. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance user experience and analyse traffic. You can manage your cookie preferences through your device or browser settings.

11. Updates to This Policy

We may update this Privacy Policy to reflect changes in our technology, legal obligations, or business operations. We will notify you of any material changes via the App or Email. Continued use of GoTap after such updates constitutes acceptance of the new policy.

12. Contact Us

If you have questions regarding this Privacy Policy or our data practices, please contact us: