Privacy Policy

1. Who We Are

Nairagram LLC is a licensed Money Transmitter and digital remittance company dedicated to offering payment solutions to the African community across the globe. We are regulated by the relevant financial authorities in the states and countries where we operate, and we are legally required to collect, verify, and record certain information about our customers.

Nairagram LLC is the data controller responsible for your personal information. If you have any questions about how we handle your data, please contact us using the details at the end of this policy.

2. Information We Collect

We collect the following categories of personal information:

2.1 Basic Personal Information

• Full name
• Date of birth
• Residential address
• Phone number
• Email address

2.2 Identity Verification (KYC) Data

As a regulated financial institution, we are required by law to verify your identity. This may include:

• Government-issued photo ID (passport, driver's license, national ID card, or residence permit)
• Proof of address (utility bill, bank statement dated within the last 3 months)
• Source of funds documentation (payslip, bank statement, tax rebate receipt, or loan agreement)

2.3 Transaction Data

• Transaction amounts, dates, and reference numbers
• Recipient names, account details, and contact information
• Payment instrument details (debit/credit card or bank account information)
• Transaction history accessible through your account portal

2.4 Technical and Usage Data

• IP address and browser type
• Device information and operating system
• Pages visited and time spent on our website
• Referring URLs and search terms

2.5 Communication Data

We record all incoming and outgoing calls handled by Nairagram LLC for training and quality assurance purposes. You will be notified of this recording via a pre-recorded message before your call is connected.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

• Service delivery — to process your money transfers, mobile top-ups, and gift card transactions
• Identity verification — to verify your identity and comply with Know Your Customer (KYC) requirements
• Regulatory compliance — to meet our obligations under anti-money laundering (AML) and counter-terrorism financing (CTF) laws
• Fraud prevention — to detect, investigate, and prevent fraudulent transactions and other illegal activity
• Customer support — to respond to your enquiries, complaints, and requests
• Account management — to create and maintain your account, and send you transaction confirmations and service notices
• Service improvement — to analyse usage patterns and improve our website and services
• Legal obligations — to comply with applicable laws, regulations, and court orders

4. Legal Basis for Processing

We process your personal information on the following legal grounds:

• Contract performance — processing is necessary to provide you with our services
• Legal obligation — we are required by law to collect and process certain data for AML, KYC, and financial regulatory compliance
• Legitimate interests — to prevent fraud, maintain the security of our systems, and improve our services
• Consent — where you have given us explicit consent, such as for marketing communications

5. KYC and AML Compliance

US law requires all financial institutions to assist in the fight against money laundering activities and the financing of terrorism by obtaining, verifying, and recording identifying information about all customers. Any personal data collected for the purpose of preventing money laundering or terrorist financing will be used solely for that purpose.

We may be required to report certain transactions or suspicious activity to relevant government authorities. In such cases, we may be legally prohibited from informing you that a report has been made.

6. Sharing Your Information

We do not sell your personal information. We may share your information with:

• Service Providers — local banks, money exchange houses, and other third-party partners in destination countries who help us deliver your transactions
• Payment processors — to facilitate debit/credit card and bank account transactions
• Identity verification providers — third-party KYC and fraud screening services
• Regulatory and law enforcement authorities — where required by law, court order, or to protect the rights, property, or safety of Nairagram, our customers, or others
• Affiliates and successors — in the event of a merger, acquisition, or sale of all or part of our business, your information may be transferred to the relevant party

All third parties with whom we share your data are required to handle it in accordance with applicable data protection laws and our data sharing agreements.

7. Data Retention

We retain your personal information for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements.

As a licensed money transmitter, we are required to retain transaction records and associated identity documentation for a minimum period as mandated by applicable financial regulations. After this period, we will securely delete or anonymise your data unless we are required by law to retain it for longer.

8. Your Rights

You have the following rights in relation to your personal information:

To exercise any of these rights, please contact us using the details in Section 12. We will respond to your request within 30 days. Please note that some rights may be limited where we have a legal obligation to retain or process your data.

9. Security

We take the security of your personal information very seriously. We use state-of-the-art security measures — including physical, electronic, and procedural safeguards — to protect your information from unauthorised access, use, or disclosure. These measures include computer safeguards, secured files, and restricted access limited to employees, agents, and representatives who need to know.

Despite our efforts, no method of transmission over the internet or electronic storage is completely secure. If you believe your Nairagram account credentials have been lost, stolen, or compromised, please notify us immediately.

10. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyse website traffic, and personalise content. Cookies are small text files stored on your device when you visit our website.

We use the following types of cookies:

• Essential cookies — required for the website to function and cannot be switched off
• Analytics cookies — help us understand how visitors interact with our website
• Preference cookies — allow the website to remember choices you have made

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our website.

11. Third-Party Links

Our website may contain links to third-party websites. These sites are not operated or controlled by Nairagram and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

12. Children's Privacy

Our services are not directed at or intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a minor, please contact us immediately and we will take steps to delete it.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we make material changes, we will update the "Last updated" date at the top of this page. We encourage you to review this policy periodically. Your continued use of our services after any changes constitutes your acceptance of the updated policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way we handle your personal information, please contact us: