This Privacy Policy explains how eClinton Enterprise, operating eClinton Pay (the "Platform"), collects, uses, discloses, and protects your personal data, in compliance with the Nigeria Data Protection Act, 2023 ("NDPA") and applicable regulations issued by the Nigeria Data Protection Commission ("NDPC"). By using the Platform, you consent to the practices described in this Policy.
We collect information that you provide directly to us, information generated automatically as you use the Platform, and information received from our licensed Third-Party Providers in the course of fulfilling a transaction. The categories of information we collect are detailed in the sections below.
This includes your full name, date of birth, gender, residential address, and any other identifying information you provide when creating or maintaining your account.
This includes your phone number and email address, which we use for account verification, transaction receipts, OTP delivery, and customer support communication.
Where required for KYC compliance, we may collect government-issued identification details or document images, and information used to confirm your identity before enabling higher transaction limits or additional Platform features.
We collect records of the Services you purchase (airtime, data, electricity, cable TV, education PINs, and other utility bill payments), including amounts, timestamps, recipient details (such as phone or meter numbers), and transaction status. This data is necessary to process your transactions and to maintain records required by financial regulation.
We automatically collect certain technical information when you access the Platform, including IP address, browser type, device identifiers, operating system, and general location inferred from your IP address, for security, fraud-prevention, and service-optimisation purposes.
The Platform uses cookies and similar technologies to keep you logged in, remember your preferences (such as dark or light mode), and understand how the Platform is used. You can control cookies through your browser settings, though disabling them may affect certain Platform features.
We may use analytics tools to understand aggregate usage patterns, such as which Services are most used or where users experience errors, so that we can improve the Platform. Analytics data is used in aggregate and is not used to make automated decisions that produce legal effects concerning you.
We implement administrative, technical, and physical safeguards designed to protect your personal data against unauthorised access, alteration, disclosure, or destruction, including access controls, transaction PINs, and two-factor authentication options available on your account.
Sensitive data transmitted to and from the Platform is protected using industry-standard SSL/TLS encryption. Sensitive account data, such as your transaction PIN, is stored in encrypted or hashed form and is not accessible in plain text, even to our own staff.
We monitor account activity and transaction patterns to detect and prevent fraudulent or unauthorised use of the Platform. This may involve automated risk-scoring of transactions and, where necessary, temporarily holding a transaction pending manual review.
We process identity verification and transaction data as necessary to comply with anti-money laundering ("AML") and Know-Your-Customer obligations applicable to digital payment platforms operating in Nigeria, and may share such data with regulators or law enforcement where legally required.
To fund your wallet or complete a transaction, your payment information may be processed by licensed third-party payment processors and billers (such as card processors, bank transfer providers, and telecommunications or utility billers). These providers process your data under their own privacy and security policies, and we encourage you to review them.
We may disclose personal data to the Nigeria Data Protection Commission, the Central Bank of Nigeria, law enforcement agencies, or other competent authorities where required by law, regulation, or a valid legal process.
We retain personal and transaction data for as long as your account remains active, and for a reasonable period afterward as required to comply with legal, tax, accounting, or regulatory record-keeping obligations, or to resolve disputes. Once data is no longer required, it is securely deleted or anonymised.
Subject to applicable law, you have the right to request access to the personal data we hold about you, request correction of inaccurate data, request deletion of your data (subject to our legal retention obligations), object to certain processing, and withdraw consent where processing is based on consent. To exercise any of these rights, contact us at contact@pay.eclinton.com.
We may send you service-related communications (such as transaction receipts and security alerts) as a normal part of providing the Platform. Where we send promotional communications, you may opt out at any time using the unsubscribe option provided or by contacting us directly.
The Platform is not directed at, and is not intended for use by, individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected data from a minor, we will take steps to delete it.
Where any of our service providers process data outside Nigeria, we take reasonable steps to ensure such transfers are subject to an adequate level of data protection consistent with NDPA requirements, including the use of contractual safeguards where applicable.
We may update this Privacy Policy periodically to reflect changes in our practices, technology, or legal requirements. We will post the updated Policy on the Platform with a revised "Last updated" date, and, where changes are material, notify you directly.
For questions, requests, or complaints regarding this Privacy Policy or how we handle your personal data, please contact:
eClinton Enterprise
Flat 2, No. 3F Close, Uratta by Express Road, Port Harcourt–Enugu Expressway, Osisioma LGA, Abia State, Nigeria.
Phone / WhatsApp: +234 806 997 0450
Support Email: contact@pay.eclinton.com
Alternative Email: rufusclintonmail@gmail.com