Privacy Policy

1. Introduction

At Infinite 69Trading Services Limited ("Infinitswap"), we operate as a global technology platform with a focus on African financial infrastructure. We are committed to protecting your privacy and processing your personal data in strict accordance with the following regulatory frameworks:

• Nigeria: Nigeria Data Protection Act (NDPA) 2023
• South Africa: Protection of Personal Information Act (POPIA) 2013
• Ghana: Data Protection Act, 2012 (Act 843)
• Tanzania: Personal Data Protection Act, 2022

2. Information We Collect

To provide a secure and efficient technology interface, we collect the following categories of information:

• Identity Data: Full name, date of birth, gender, and government-issued identification (BVN, NIN, Passport, or National ID) required for regional KYC verification.
• Contact Data: Email address, physical billing address, and verified telephone number.
• Financial Instruction Data: Bank account details, digital wallet addresses, and transaction amounts.Note: We do not store full card primary account numbers (PAN) or CVV codes.
• Technical Data: IP address, device telemetry, browser metadata, and usage patterns collected via secure cookies.

4. Data Sharing and Cross-Border Transfers

As a technology layer, we do not settle funds. Consequently, your data must be shared with:

• Licensed Financial Partners: Regulated Payment Service Providers (PSPs) and banks (e.g., partners regulated by CBN, SARB, BoG, or BoT).
• Regulatory Authorities: Law enforcement or government bodies across Nigeria, Ghana, Tanzania, and South Africa when required by law.

Cross-Border Transfers: We ensure that any data moved across national borders is protected by Standard Contractual Clauses (SCCs) and robust encryption, ensuring a level of protection equivalent to the data's country of origin.

6. Data Security

We implement industry-leading technical measures, including:

• Encryption: TLS 1.3 for data in transit and AES-256 for data at rest.
• Access Control: Strict multi-factor authentication (MFA) for all internal infrastructure access.
• Audits: Regular third-party penetration testing and vulnerability assessments.

7. Regional Data Subject Rights

Depending on your jurisdiction, you hold specific rights over your data (e.g., NDPA Section 34, POPIA Section 23):

• Access & Correction: The right to see and correct your data.
• Objection: The right to object to processing for direct marketing.
• Erasure: The right to request data deletion, subject to mandatory financial retention laws.
• Portability: The right to receive your data in a structured, machine-readable format.