Privacy Policy

1. INTRODUCTION

November 15, 2025

At UnionBillsPay, we are a forward-thinking fintech solution built for the new economy. We are registered with the Corporate Affairs Commission with the number RC…

Your privacy matters to us. We collect only the data necessary to provide secure and reliable services. This includes transaction details, identity verification data (KYC), and app usage metrics. We do not sell your information to third parties. You don’t have to share any information with us but to use our services we’ll need some information from you. All data is encrypted and handled in compliance with the provisions of the Nigeria Data Protection Act 2023 and other international data protection laws.

By using or accessing any of our services, you agree to the collection, use and disclosure of your personal data as described in this Privacy Policy. Your use of our services is also subject to our regular terms and conditions for account opening.

Should you disagree to abide by such terms or if you revoke your consent to the processing of your personal data, your account will be disabled and you will no longer be able to access or interact with us on any of our platforms.

2. WHAT INFORMATION DO WE COLLECT?

We collect and use any information you supply when you interact with any of our touch points. When you open an account with us, you share details like your names, Bank Verification Number (BVN), identification documents, address and pictures.

Other details we collect include date of birth, gender, your profile picture, phone number, residential address and email address. These are done in fulfillment of regulatory requirements.

We also collect a video of your face during a liveness check done to confirm that you’re the one opening or upgrading your account. We share this video with a third-party service provider to facilitate our liveness check.

You may choose not to upload a video of your face on the UnionBillsPay app, however, this will limit what you can do with your account as the identification and verification will be incomplete.

We will not share the video of your face that we collect during a liveness check with advertisers or anyone else other than the third-party service provider that facilitates the liveness check process.

If at any time you choose to withdraw your consent for us to use this video for your liveness check, we will delete it. However, please note that this would affect your ability to use your account as certain services are dependent on us processing your video for the liveness check.

Information you give us through the in-app chat so we can help you.

This is to help protect you against fraud by tracking the location of your phone if you’ve authorized it.

View your contact list for airtime purchases or access your SMS and related data.

The above is not exhaustive, as we may need to collect additional information and data as our services evolve or as a result of changes in regulatory requirements.

Additionally, we may collect special or sensitive data about you such as gender/sex, personal identifiable information, and sensitive financial information.

Information you give us when you contact us through other channels

If you contact us via other means than the in-app chat, we collect the following information so we can answer your questions or take action

The phone number you’re calling from and information you give us during the call.

The email address you use and the contents of your email (and any attachments) sent to us. Public details from your social media profile like Facebook, Instagram or X (formerly Twitter) if you reach out to us via these platforms, and the contents of your messages or posts to us.

  • The mobile network operator and the operating system that you use,
  • Your IP addresses and device ID
  • Your phone contacts so you can make airtime purchases.
Information we get from third parties

As part of our Know Your Customer (KYC) process, we run checks on the identity information you supply during signup. We will verify the authenticity and validity of the identity

3. HOW DO WE USE YOUR INFORMATION?

We retain Personal Data in an identifiable format only for as long as required for our business purposes, with specific reference to the service rendered to you and to fulfill our legal or regulatory obligations. Subject to applicable law, which might from time to time oblige us to retain your Personal Data for a certain period of time, we will retain your Personal Data for as long as necessary to fulfil the purposes we collect it for, including the purposes of satisfying any legal, accounting or reporting obligations.

4. HOW DO WE PROCESS PERSONAL DATA?

We collect your personal data to provide you an efficient and secure customer experience. We may process your Personal Data for the following reasons:

Provide services including to:

  • Initiate a payment, send or request money or pay a bill
  • Authenticate your access to an account
  • Communicate with you about your account
  • Manage risk, fraud and abuse of our services and prevent you from fraud. Our risk and fraud tools use personal data, device information and geolocation from our Platform that offers services to help detect and prevent fraud and abuse of the services.
  • Comply with our legal and regulatory obligations and to enforce the terms of our services, including to comply with all applicable laws and regulations.
  • Track data breach and remediate such identified breaches.
  • Resolve disputes and troubleshoot problems.

Additionally, you can withdraw your consent at any time and free of charge.

5. SHARING YOUR PERSONAL DATA

We may share your Personal Data or other information about you with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may for example, provide you with services, verify your identity, assist in processing transactions, send you advertisements for our products and services or provide customer support. Rest assured that we make double sure that these companies have compliant, legal measures in place to ensure the security and confidentiality of your Personal Data. We may share your Personal Data with other financial institutions that we have partnered with to process transactions and keep your financial information up to date.

Where permitted or required by law, we may share your Personal Information with law enforcement authorities, other government officials or third parties pursuant to a court order or other legal process or requirement applicable where we reasonably believe that the disclosure is necessary or appropriate to prevent an imminent physical harm or financial loss. We also will share your Personal Data and other information to investigate violations of or enforce a user agreement or other legal terms applicable to any service to support our audit, compliance and corporate governance functions.

Your personal data may be transferred to and stored in countries outside Nigeria. Where such transfers occur, we implement appropriate safeguards to protect your data, including Standard Contractual Clauses or other lawful transfer mechanisms.

6. WHAT ARE YOUR RIGHTS
  • You have the right to access and request the information that we have on you in our records and you may receive the information in a structured, commonly used machine-readable format and also ask us to transfer it to another data controller (this is the right to the portability of data).
  • You may also ask us to delete your information on our record, restrict the way in which we use your personal information, ask that we update the personal information we hold about you or correct such personal information which you think is incorrect or incomplete and we will grant this request as long as we’re legally allowed to.
  • You also have the right to object to us using your information for our marketing purposes or any additional services we may be offering you.
  • You may request that we restrict the processing of your data while a request or objection is being resolved or during legal proceedings.
  • You also have the right not to be subject to decisions based solely on automated processing and request for human intervention, express your views, and contest the decision, unless it is necessary for a contract, authorized by law or based on your explicit consent.
  • You may also withdraw any consent you’ve previously given us.
7. HOW DO WE PROTECT YOUR PERSONAL DATA?

We maintain technical, physical and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure and alteration. The security measures include firewalls, data encryption, physical access controls to our premises as well as information access authorization controls.

Your Personal Data is regarded as confidential and will not be divulged to any third party, except under legal and/or regulatory conditions. You have the right to request sight of and copies of any and all information we keep on you, if such requests are made in compliance with the Freedom of Information Act and other relevant enactments.

While we are dedicated to securing our systems and services and safeguarding the information entrusted to us, your role in fulfilling confidentiality duties includes, but is not limited to adopting and enforcing appropriate security measures such as securing and maintaining the privacy of your password(s) and account/profile registration information, verifying that the Personal Data we maintain of you is accurate and current.

We will inform you of any breaches which may likely result in high risks to your rights and freedom.

We have drafted policies and other documents that ensure the safety, integrity and confidentiality of your personal data. We also periodically train and equip our authorised staff on the contemporary measures for data security

8. COOKIE POLICY

We use cookies and similar technologies on our website and on other platforms to help collect information and operate the site.  We use cookies to:

  • Remember visitors to our websites or other platforms.
  • Make your user experience easier.
  • Customise our services, content and advertising.
  • help you ensure that your account security is not compromised, mitigate risk and prevent fraud.
  • Promote trust and safety on our website. Cookies are small text files placed by a website and stored by your browser on your device. Our cookies hold a unique random reference to you so that once you visit the site we can recognise who you are and provide certain content to you. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this may impact your experience using our website.
9. HOW DO YOU LODGE A COMPLAINT?

If you have reservations or complaints about your personal information, please contact our Data Protection Officer by:

  • Sending a message via the app
  • Emailing us at privacy@unionbillspay.com.ng
  • Calling us on: ‪+234 810 527 8683

Our Data Protection Officer shall within 30 days of our notice of the said violation address the issue and redress the violation as practicable as possible.

10. CHANGES TO OUR PRIVACY POLICY

This document will be reviewed on a yearly basis or more frequently if occasioned by changes or amendment to applicable data protection regulations. If we make any changes, we’ll add a note to this page, and if there are significant changes we’ll let you know by email.

11. CONTACT US

If you have questions or concerns about this Privacy Policy or the way in which we handle your Personal Data, kindly contact us via the details below: