Privacy Policy

1. Introduction & Scope

This Privacy Policy describes how HOLDWAY TECHNOLOGIES LTD ("Company", "we", "our") collects, uses, stores, and protects personal information when you use our WhatsApp checkout interface, web applications, or merchant services. We are committed to protecting your privacy in full compliance with the Nigeria Data Protection Regulation (NDPR) and international data safety standards.

2. Information We Collect

To process escrow checkouts and dispatch goods, we collect:

• Contact Information: Phone number (WhatsApp), name, and email address.
• Delivery Information: Physical street address, Local Government Area (LGA), and State.
• Financial Data: Bank account numbers, transaction references, and payment verification webhooks (processed securely via licensed financial partners). We do not store raw credit card PINs or bank passwords.
• Conversation Logs: Order-related chat transcripts between buyers and our automated checkout assistant for order verification and dispute resolution.

3. How We Use Your Information

We use collected data strictly for operational purposes:

• Generating dedicated virtual bank accounts for escrow checkout.
• Validating delivery addresses and calculating courier rates via logistics partners.
• Notifying merchants and buyers of payment, dispatch, and delivery milestones.
• Resolving order disputes and verifying escrow release conditions.

4. Third-Party Data Sharing

We share data only with essential infrastructure service providers necessary to complete your order:

• Financial Partners (Nomba / Nombank MFB): Virtual account generation and bank transfer verification.
• Logistics Providers (Shipbubble & Couriers): Address validation and delivery dispatch.
• AI & Messaging Infrastructure (Groq & Twilio / Meta): Natural language order processing and WhatsApp message delivery.

We do not sell, rent, or trade your personal data to third parties for marketing purposes.

5. Data Security & Storage

All personal data is encrypted in transit (TLS 1.3) and at rest using enterprise-grade database encryption (Supabase / PostgreSQL). Access to transaction logs is restricted to authorized personnel under strict security protocols.

6. Your Rights Under NDPR

You have the right to request access to your personal data, request correction of inaccurate records, or request deletion of non-active user profiles by contacting our data compliance officer.