How we collect, use, and protect your personal information.
Welcome to HorlartPay. HorlartPay is a digital currency exchange platform that facilitates the conversion of foreign currencies (primarily USD) to Nigerian Naira (NGN) through e-wallet transfers.
This Privacy Policy explains how we collect, use, store, protect, and share your personal information when you use our Platform. We are committed to protecting your privacy and complying with the Nigeria Data Protection Act 2023 (NDPA), the Nigeria Data Protection Regulation 2019 (NDPR), and other applicable data protection laws.
By accessing or using HorlartPay, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with any part of this Privacy Policy, please do not use our Platform.
When you create an account and use our services, we collect the following personal information:
Full name, email address, encrypted password (if provided).
Profile photograph or avatar (optional), preferences, settings, 2FA credentials (if enabled).
E-wallet details, account usernames/emails, transaction amounts, selected offers, payment instructions, and Proof of Payment uploads.
Nigerian bank account details to receive fund, transaction history, and exchange rates applied.
Messages exchanged through in-app admin chat, customer support correspondence, feedback, and survey responses.
We automatically collect technical information when you use the Platform, including:
We also use cookies and similar technologies (session, authentication, security, and analytics cookies). See Section 9 for details.
We may receive information from:
We do not intentionally collect sensitive categories of personal data (genetic, biometric, health, religious, political, sexual orientation, or trade union membership). If such data is inadvertently disclosed, we will handle it with high protection and only use it to address your specific inquiry.
We process your personal data for the following lawful purposes:
Creating and managing accounts, processing currency exchange transactions, facilitating Admin communication, verifying transfers, maintaining records, and providing customer support.
Complying with AML regulations, preventing fraud, responding to lawful government requests, maintaining transaction records, and filing regulatory reports.
Operating and improving the Platform, detecting fraud and security threats, troubleshooting, R&D, enforcing Terms, and protecting legal rights.
With your explicit consent (withdrawable), we may send marketing communications or share your data for purposes not outlined in this Policy. We will obtain consent where required by law.
Under the NDPA and NDPR, we rely on the following legal bases:
We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.
Technical safeguards include SSL/TLS encryption, encrypted storage of sensitive data, secure authentication, optional 2FA, and regular security updates. Organizational safeguards include access controls, employee training, confidentiality agreements, audits, incident response procedures, and secure disposal of data. Administrative access is limited, logged, and monitored.
You play a role in protecting your account: choose strong passwords, enable 2FA, keep credentials confidential, log out from shared devices, monitor account activity, and report concerns promptly.
If a breach affects your personal data, we will notify the Nigeria Data Protection Commission (NDPC) within 72 hours as required by law and notify affected users without undue delay if there is a high risk to rights and freedoms. We will describe the breach, likely consequences, and measures taken to address it.
We retain personal data only as long as necessary to fulfill the purposes in this Policy and to comply with legal obligations.
After retention periods expire, we will delete personal data from active systems, anonymize data retained for statistics, and securely destroy backups and physical records. You may request earlier deletion via the right to erasure (see Section 8).
Under the NDPA and NDPR, you have the following rights regarding your personal data:
Request confirmation of processing and obtain a copy of your personal data. To exercise: contact support@horlartpay.com. Response time: within 30 days.
Correct inaccurate or complete incomplete data. To exercise: update account settings or contact support@horlartpay.com. Response time: within 14 days.
Request deletion when data is no longer necessary, consent withdrawn, processing unlawful, or deletion required by law. Limitations apply (e.g., 7-year retention for financial records). To exercise: contact support@horlartpay.com.
Request restriction when accuracy is contested, processing unlawful but deletion not desired, or processing needed for legal claims. To exercise: contact support@horlartpay.com.
Receive data in a machine-readable format and transmit to another provider for data you provided based on consent or contract. To exercise: contact support@horlartpay.com.
Object to processing based on legitimate interests or direct marketing and withdraw consent where applicable. To exercise: contact support@horlartpay.com or use account settings.
If you believe your rights are violated, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC) or contact us first at support@horlartpay.com to try to resolve the issue.
Our Platform may contain links to third-party websites, services, or resources (for example, e-wallet providers).
We are not responsible for third-party privacy practices. Review third-party privacy policies before sharing personal information. Linking does not imply endorsement.
We may update this Privacy Policy to reflect changes in processing practices, legal requirements, Platform features, or feedback.
For material changes, we will update the "Last Updated" date, notify you via email or Platform notice, and seek consent where required.
Continued use after changes constitutes acceptance. If you disagree, stop using the Platform and contact us to close your account.
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
We aim to respond to all inquiries within 48-72 hours (business days).
This Privacy Policy is governed by and construed in accordance with the laws of the Federal Republic of Nigeria. Any disputes arising from this Privacy Policy shall be subject to the exclusive jurisdiction of Nigerian courts.
By using HorlartPay, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.