Pin-Up Privacy Policy

What Personal Data Is Collected

Pin-Up collects personal information that users provide directly, as well as data generated through the use of the platform. This includes, but is not limited to:

• Full name and date of birth
• Email address and phone number
• Residential address
• Government-issued identification documents
• Financial and payment information
• Device and browser data, IP address, and usage logs

Purpose of Collection

Personal data is collected for the following purposes:

• Verifying user identity in accordance with Know Your Customer (KYC) requirements
• Processing deposits, withdrawals, and other financial transactions
• Delivering the services offered on the platform
• Meeting legal and regulatory obligations under Nigerian law
• Detecting and preventing fraud, money laundering, and other unlawful activities

Protection Measures

Pin-Up applies technical and organisational measures to safeguard personal information against unauthorised access, loss, or misuse. These measures include:

• Data encryption during transmission and storage
• Restricted access controls for authorised personnel only
• Regular security assessments and system audits
• Secure server infrastructure

User Rights

All users have the right to:

• Access the personal data held about them
• Request corrections to inaccurate or outdated information
• Request deletion of their personal data, subject to legal retention obligations
• Withdraw consent for processing where consent is the legal basis

Compliance With Nigerian Law

Pin-Up processes personal data in compliance with applicable Nigerian data protection legislation, including the Nigeria Data Protection Act (NDPA) and guidelines issued by the Nigeria Data Protection Commission (NDPC). Users whose data is processed have the right to lodge a complaint with the relevant regulatory authority if they believe their rights have been violated.

Personal information collected by Pin-Up is used solely for lawful, clearly defined purposes. The table below outlines the primary uses of collected data:

All processing is carried out on a lawful basis, including user consent, contractual necessity, or legal obligation. Personal information is never sold to third parties for commercial gain. Users who wish to opt out of marketing communications may do so at any time by updating their account preferences or contacting the support team.

How to Access Your Data

Users may submit a written request to Pin-Up to obtain a copy of the personal information held about them. Requests are processed within a reasonable timeframe, in accordance with applicable data protection regulations.

Updating or Correcting Information

If a user believes that the personal data on file is inaccurate or incomplete, they may request a correction through the following steps:

1. Log in to the user account on the platform.
2. Navigate to account settings and update the relevant information directly.
3. For changes requiring document verification, contact the support team and submit the required documentation.

Requesting Deletion of Data

Users may request the deletion of their personal data by contacting Pin-Up in writing. Deletion requests are subject to legal retention requirements. Certain data may be retained for a defined period as required by Nigerian law and regulatory obligations, even after a deletion request is received.

Consent to Security and Payment Processing

By using the platform, users acknowledge and consent to the following:

• Personal and financial information may be subject to security verification checks carried out by Pin-Up or its authorised partners.
• Payment data may be processed by licensed third-party payment service providers to facilitate financial transactions.
• These checks and processing activities are necessary to operate the platform securely and lawfully.

The Pin-Up platform is intended exclusively for individuals who are 18 years of age or older. Access to the website, registration, and participation in any services offered are strictly prohibited for persons under this age.

Age Verification Limitations

Pin-Up takes reasonable steps to prevent underage access; however, the platform cannot independently verify the age of every user without the submission of valid identity documents. Users are required to provide accurate age information during registration, and identity verification may be requested at any stage of the account lifecycle.

Handling of Data Belonging to Minors

If a parent or legal guardian becomes aware that a minor has submitted personal information to Pin-Up, they should contact the platform immediately. Upon confirmation, Pin-Up will:

• Promptly delete all personal data associated with the minor’s account
• Permanently close the account in question
• Take any additional steps required under applicable Nigerian law to address the situation

Pin-Up does not knowingly collect or process personal data relating to individuals under the age of 18.

Pin-Up operates through a network of business partners, technology providers, and service organisations located in various countries. As a result, personal data collected from users in Nigeria may be transferred to, stored in, or processed in countries outside Nigeria.

Basis for International Transfers

By using the Pin-Up platform, users consent to the international transfer of their personal data as described in this policy. Such transfers are carried out only where necessary to deliver platform services, fulfil legal obligations, or support business operations.

Data Protection Standards for Partners

All third-party partners and service providers that receive personal data from Pin-Up are contractually required to:

• Maintain the confidentiality of all personal information received
• Apply data protection standards consistent with applicable international and Nigerian regulatory requirements
• Use the data solely for the purposes for which it was shared

Pin-Up does not transfer personal data to partners that do not meet these standards.

This Privacy Policy constitutes a binding document governing the relationship between Pin-Up and its users with respect to the collection, processing, and protection of personal data.

Scope and Effect

The provisions of this disclaimer may alter the scope or effects of the rules set out in this policy. Such alterations apply when a user formally accepts the policy through one of the following actions:

• Electronic acceptance during account registration
• Signature on a written agreement incorporating this policy
• Continued use of the platform following notification of any updates to this document

Limitations

Pin-Up accepts no liability for data processing activities that occur outside the scope of this policy, including processing carried out by independent third parties on their own platforms. Users are advised to review the privacy policies of all external services they interact with in connection with their use of the platform.

This policy does not limit any rights that users may have under Nigerian data protection law or other applicable legislation.

What Cookies Are

Cookies are small text files placed on a user’s device by a website during a browsing session. These files store limited amounts of information and are retrieved by the website on subsequent visits.

How Pin-Up Uses Cookies

The platform uses cookies for the following purposes:

• Statistical analysis: Collecting aggregated data on how users interact with the website to measure performance and identify areas for improvement.
• Behavioural analysis: Monitoring navigation patterns to better understand how different sections of the platform are used.
• Personalisation: Storing user preferences such as language settings, display options, and login status.
• Site improvement: Using insights derived from cookie data to enhance the overall functionality and content of the platform.

Cookie Retention Period

Cookies placed by Pin-Up are retained on the user’s device for a period of up to one year, after which they expire automatically. Users may delete cookies at any time through their browser settings.

Managing Cookie Preferences

Users may configure their browser to reject cookies or to alert them before a cookie is placed. Disabling cookies may affect the functionality of certain features on the platform. No personally identifiable information is stored within cookies without the user’s prior consent.

By accessing, registering on, or otherwise using the Pin-Up platform, users confirm that they have read, understood, and agreed to the terms set out in this Privacy Policy in full.

Current Version Prevails

This document represents the most current and authoritative version of the Privacy Policy. In the event of any conflict between this version and any previous version, the current document takes precedence.

Policy Updates

Pin-Up reserves the right to update or amend this Privacy Policy at any time. Users will be notified of significant changes through the platform or via the contact information registered to their account. Continued use of the platform following the publication of an updated policy constitutes acceptance of the revised terms.

Users who do not agree with the terms of this policy are advised to discontinue use of the platform and contact the support team to request account closure.

Pin-Up may share personal information with third parties in specific circumstances. All such sharing is carried out on a lawful basis and in accordance with this policy.

Circumstances for Data Sharing

Personal data may be disclosed to third parties in the following situations:

• Legal obligations: Where required by a court order, regulatory directive, or applicable Nigerian law.
• Dispute resolution: In connection with the investigation or resolution of a legal dispute involving a user’s account or transactions.
• Contractual arrangements: Where a third-party service provider requires access to personal data to fulfil a service on behalf of Pin-Up, such as payment processing, identity verification, or fraud prevention.

Identification of Third Parties

Where a list of relevant third parties is available on the platform, users are directed to that list for full details. In cases where a specific third party is not listed, Pin-Up will, to the extent permitted by law, inform users of the purpose and scope of the data sharing before it takes place.

Consent to Data Sharing

By submitting personal information on the platform and continuing to use Pin-Up services, users consent to the sharing of their data with third parties as described in this section. Users who wish to withdraw this consent should contact the support team, noting that doing so may affect access to certain platform features.

The Pin-Up platform may contain links to third-party websites for informational or operational purposes. These external websites are operated independently and maintain their own privacy policies.

Disclaimer of Responsibility

Pin-Up is not responsible for the data collection, storage, or processing practices of any third-party website accessible through links on the platform. The inclusion of a link does not constitute an endorsement of the third-party website or its data handling practices.

User Responsibility When Visiting External Sites

Users are advised to exercise caution when navigating away from the Pin-Up platform to external websites. Specifically, users should:

• Review the privacy policy of any third-party website before submitting personal information.
• Be aware that data submitted on external websites is governed by those websites’ own terms and policies, not by this document.
• Contact the relevant third-party website directly with any questions or concerns about how their personal data is handled.

Pin-Up accepts no liability for any loss or harm resulting from a user’s interaction with external websites linked from the platform.