Privacy Policy

Project Seven ("we", "our", or "us") operates the Virtual Account Platform (the "Platform") under the licence and regulatory oversight of Garum Mallam Microfinance Bank ("Garum Mallam MFB"), a duly licensed microfinance bank regulated by the Central Bank of Nigeria (CBN). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you register for and use our services. Please read this policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Platform.

1. Information We Collect

1.1 Business Registration Information

When you create an account, we collect information about your business including:

• Business name, registration number, and registration date
• Business address, phone number, and email address
• Business type, industry, and tax identification number (TIN)
• Director and authorised signatory details (name, date of birth, nationality, ID documents)
• Bank Verification Number (BVN) of directors and signatories

1.2 KYC Documents

As part of our Know Your Customer (KYC) process required by Nigerian financial regulations, we collect and verify government-issued identification documents, certificates of incorporation, and other supporting business documents.

1.3 Transaction Data

We collect records of all transactions processed through your virtual accounts, including amounts, timestamps, counterparty details, session IDs, and transaction references.

1.4 Usage and Technical Data

We automatically collect information about how you interact with the Platform, including IP addresses, browser type, device information, pages visited, and API usage logs.

2. How We Use Your Information

We use the information we collect to:

• Create and manage your business account and virtual accounts
• Verify your identity and conduct KYC/AML checks as required by law
• Process transactions and send transaction notifications
• Provide customer support and respond to enquiries
• Send operational communications (e.g. account approvals, KYC status updates)
• Detect, investigate, and prevent fraudulent transactions and other illegal activities
• Comply with applicable laws, regulations, and regulatory directives (CBN, NDIC, EFCC, etc.)
• Improve our Platform, products, and services
• Generate anonymised, aggregate analytics and reports

3. Sharing of Information

We may share your information with:

• Banking Partners: We share necessary business and director information with Garum Mallam MFB and our financial technology partners (including NCube and related processors) to open and maintain virtual accounts on your behalf.
• Regulatory Authorities: We disclose information to the Central Bank of Nigeria (CBN), the Nigeria Financial Intelligence Unit (NFIU), and other regulatory or law enforcement authorities when required by law.
• Service Providers: We engage third-party vendors who assist us in operating the Platform (e.g., email delivery, cloud hosting). These vendors are contractually bound to protect your data.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of the transaction.

We do not sell your personal information to third parties.

4. Data Retention

We retain your personal data and transaction records for a minimum of seven (7) years after the termination of your account, in compliance with Nigerian financial regulations and anti-money laundering requirements. After this period, we will securely delete or anonymise your data unless we are required by law to retain it longer.

5. Data Security

We implement industry-standard technical and organisational security measures to protect your data against unauthorised access, alteration, disclosure, or destruction. These include encryption in transit (TLS), access controls, and regular security assessments. However, no method of transmission over the internet or electronic storage is completely secure. We encourage you to keep your API keys and account credentials confidential.

6. Your Rights

Subject to applicable law, you have the right to:

• Access the personal data we hold about your business
• Request correction of inaccurate or incomplete data
• Request erasure of your data (subject to our legal retention obligations)
• Object to or restrict the processing of your data
• Receive a copy of your data in a portable format

To exercise any of these rights, please contact us at info@tech-seven.com.

7. Cookies and Tracking

We use session cookies and local storage tokens solely for authentication and session management purposes. We do not use advertising or tracking cookies. You may disable cookies in your browser settings, but this may affect the functionality of the Platform.

8. Children's Privacy

The Platform is intended for use by registered businesses and is not directed at individuals under 18 years of age. We do not knowingly collect personal information from minors.

9. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or by posting a notice on the Platform. Continued use of the Platform after changes become effective constitutes your acceptance of the revised policy.

10. Contact Us

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