Privacy Policy

Effective date: 1 October 2025

Short summary: BlueSea Mobile (“we”, “us”, “our”) collects and processes personal data to provide wallet, airtime buyback, group payments, and related services. This policy explains what we collect, why, how long we keep it, and your rights.

1. Who we are

BlueSea Mobile is a fintech services provider offering digital wallet, airtime & data buyback, group payments, loyalty marketplace and related services. For privacy enquiries contact: blueseamobile5@gmail.com.

2. Scope and application

This policy applies to all BlueSea Mobile websites, mobile apps, services, and communications. It covers personal data collected from customers, visitors, applicants, and partners. We process personal information in accordance with applicable law including the Nigeria Data Protection Act (NDPA) 2023. :contentReference[oaicite:1]{index=1}

3. Definitions

• Personal Data — any information relating to an identified or identifiable person (name, phone, email, ID).
• Processing — collection, storage, use, modification, deletion or disclosure of personal data.
• Controller — BlueSea Mobile, which determines processing purposes and means.

4. Categories of data we collect

We may collect the following categories of personal data:

• Identity & account data: full name, date of birth (if provided), username, profile picture, phone number used to create account.
• Contact data: email, postal address, WhatsApp number.
• Payment & transaction data: bank account or card details (tokenized via payment processor), transaction history, wallet balance, buyback records.
• Device & usage data: IP address, device IDs, OS, browser, logs, crash reports, feature usage and analytics.
• KYC / verification data: ID documents, selfie verification images, and any documents required by law or our processors (used only for verification and compliance).
• Support & communications: messages we exchange, support tickets and call recordings if you call support (where we notify you).

5. How we collect personal data

We collect data directly when you sign up, verify your account, use services, top up or withdraw, communicate with support, or interact with the website/app. We also collect data from third parties (payment processors, KYC providers, analytics and telcos) where you have used those services. We use cookies and local storage for site functionality and analytics — see our Cookie Policy. (If you use third-party login or social connectors we receive the profile data you allow.)

6. Purposes & lawful basis for processing

We process data for the following purposes. For each purpose we indicate the typical lawful basis (NDPA/modern privacy practice):

• Provide & improve services — to operate your account, process transactions, and deliver features. Legal basis: contractual necessity / legitimate interest.
• Payments & compliance — payment processing, fraud prevention, KYC and AML checks. Legal basis: legal obligation / vital interest / contractual necessity.
• Security & fraud prevention — monitoring for suspicious activity. Legal basis: legitimate interest & legal compliance.
• Customer support — manage queries and disputes. Legal basis: contractual necessity & legitimate interest.
• Marketing (optional) — only where you consent, we may send offers or personalised communications. You can opt out anytime. Legal basis: consent.
• Analytics & research — to understand and improve the service. Legal basis: legitimate interest (or consent where required by local law).

7. Sharing & third-party processors

We do not sell your personal data. We share data only with:

• Payment processors, banks and telco partners to execute transactions and top-ups.
• KYC/identity verification providers to comply with law and reduce fraud.
• Analytics and hosting providers (Amazon Web Services, analytics vendors) to run and improve our service.
• Law enforcement or regulators when required by law or court order.

When we share data with third-party processors we require contracts that compel them to protect your data and not use it for unrelated purposes.

8. Cross-border transfers

Some processors or services may store or process data outside Nigeria. Where data is transferred abroad we ensure adequate safeguards such as standard contractual clauses or equivalent protections as required by law. If you would like specifics about a transfer, contact blueseamobile5@gmail.com.

9. Data retention

We retain personal data only as long as necessary to provide the service, meet legal obligations, resolve disputes and enforce agreements. Example retention periods (illustrative — update for your needs):

• Transaction and accounting records: 7 years (regulatory/accounting purposes).
• Basic account information: while account is active + 3 years after closure for fraud prevention.
• Support records: 2–5 years depending on issue severity.
• Deleted data: where possible we permanently delete data; however, backups and logs may persist for a limited time.

10. Security

We use industry-standard safeguards including encryption in transit (TLS), strong access controls, role-based permissions, and vendor security requirements. While we take steps to protect data, no online system is 100% secure — if you suspect a breach contact us immediately at blueseamobile5@gmail.com. The NDPA also requires breach response and notification procedures — we will follow applicable requirements. :contentReference[oaicite:2]{index=2}

11. Your rights

Depending on local law and your circumstances, you may have rights to:

• Access a copy of personal data we hold about you.
• Request correction of inaccurate data.
• Request deletion / restriction of processing (subject to legal retention requirements).
• Object to processing for direct marketing or legitimate interest grounds.
• Request data portability where technically feasible.

To exercise rights contact: blueseamobile5@gmail.com. We may need identity verification to fulfil requests. If you're unsatisfied you may lodge a complaint with the Nigeria Data Protection Commission (NDPC). :contentReference[oaicite:3]{index=3}

12. Cookies & tracking

We use cookies and similar technologies for strictly necessary functions, analytics and (with your consent) advertising and personalization. For full details see our Cookie Policy page (link in the footer). Where required by law we obtain consent before non-essential cookies are set. If you wish to opt out of analytics or advertising cookies, use your browser settings or our cookie preferences tool.

For GDPR-style consent patterns and cookie patterns, see common practice guides and consent banner templates. :contentReference[oaicite:4]{index=4}

13. Children

Our services are not directed to children under 13 (or a higher age depending on local law). We do not knowingly collect personal data from children without parental consent. If you believe we have collected a child's data, contact us and we will take steps to remove it.

14. Changes to this policy

We will post the effective date at the top. Material changes will be announced on our site and where required will seek consent if needed under applicable law.

15. Contact & DPO

Data protection officer / privacy contact: blueseamobile5@gmail.com. For regulatory matters you can contact the Nigeria Data Protection Commission. :contentReference[oaicite:5]{index=5}

Disclaimer: This policy is a general template and does not constitute legal advice. For regulatory compliance and legal binding text — especially for payments, crypto, and cross-border processing — consult a local lawyer. We can tailor this further for specific vendors once you provide vendor names (payment processor, KYC provider, analytics vendor).