Privacy

What we hold about you, and why.

Wagezapp asks for more than most apps, because the law that lets us move money requires it. This page sets out exactly what is collected, what it is used for, and what you can ask us to do with it.

Nigeria Data Protection Act 2023Controller: Fiinwage Ltd
This wording is in review.

The structure and everything stated here reflects how Wagezapp is actually built. The final wording has not yet been settled with Fiinwage's counsel, and the sections marked below are the ones still waiting on them. Nothing on this page should be relied on as the published policy until that review is done.

Who is responsible

Fiinwage Ltd operates Wagezapp and decides what personal data is collected and why. In the language of the Nigeria Data Protection Act 2023, Fiinwage is the data controller.

Where your employer has put Wagezapp in place for their staff, your employer is a separate controller for the employment information they give us, such as your salary and whether you still work there. They do not get access to the rest of your Wagezapp account.

What we collect

CategoryWhat that means
IdentityYour name, date of birth, Bank Verification Number, National Identity Number, a photograph of an accepted identity document, and a selfie taken at sign up.
ContactYour phone number and email address.
EmploymentYour employer, your role, your salary, your pay cycle and whether you are still employed. On the employer track this comes from your employer rather than from you.
MoneyYour bank account details, the advances you take, your repayments, your savings and the transactions on your Wagezapp account.
DeviceThe device you sign in from, its operating system, and the records of your sign in attempts.
LocationOnly where you have agreed to it, and only to check that your work pattern still matches the employer on your account. You can refuse, and you can withdraw that agreement later.

We ask for the identity data because a regulated financial service in Nigeria cannot open an account or move money without verifying who you are. We do not ask for anything we do not use.

What we use it for

  • To open and run your account, which includes verifying your identity and confirming you work where you say you work.
  • To work out what you have earned so far in the cycle, and therefore what you can draw.
  • To move money into your bank account, and to recover the advance on payday.
  • To decide what you can borrow, which includes your WageScore.
  • To find fraud and to stop someone else using your account.
  • To meet legal duties we owe as a financial service, including record keeping and reporting.
  • To tell you things you need to know, such as that an advance has gone out or that payday is near.

We do not sell your personal data, and we do not share it with advertisers.

Who else sees it

Your data is shared only where the service cannot work without it, and only the part that is needed:

  • An identity verification provider, to confirm your BVN, your NIN and your document against the official records.
  • A payment partner, to move money into your bank account.
  • Your employer, where they have Wagezapp in place, and only to the extent of confirming your employment and applying the deduction on payday. They do not see your savings, your transaction history or your WageScore.
  • A licensed lender, where your employer is not on Wagezapp and the advance is funded by a third party. In that case the lender is a separate controller and its own privacy terms apply alongside this one.
  • Regulators, law enforcement and the courts, where we are required to.
  • Service providers who host or secure the platform, under contract and under instruction.
Needs Fiinwage

Whether the named partners should be listed here by name, rather than by category, is a commercial decision for Fiinwage. Any transfer of personal data outside Nigeria also needs to be identified and the safeguard for it named.

How it is protected

  • Your BVN, NIN and other identifying data are encrypted where they are stored, not only in transit.
  • Access inside Fiinwage is on a least privilege basis, and every administrative action is written to an audit log that cannot be edited.
  • Every money movement is recorded in a double entry ledger with its own reconciliation, so a transaction cannot be altered quietly after the fact.
  • Sign in is protected by a one time code and a PIN, with biometrics if your device supports it.
  • If there is a breach that puts you at risk, the Nigeria Data Protection Commission is notified within 72 hours, and you are told where the law requires it.

How long we keep it

Financial records have to be kept for a set period after an account closes, because that is what the law requires of a regulated service. Data that is not under such a duty is deleted once the purpose it was collected for has ended.

Needs Fiinwage

The exact retention period for each category has to be set against the record keeping rules Fiinwage is subject to, and confirmed by counsel before this page is published.

What you can ask for

Under the Nigeria Data Protection Act 2023 you can:

  • Ask what we hold about you, and get a copy of it.
  • Have it corrected if it is wrong.
  • Have it deleted, where no legal duty requires us to keep it.
  • Object to processing we carry out on the basis of legitimate interest.
  • Withdraw consent you have given, such as for location or marketing.
  • Take your data elsewhere in a portable form.
  • Complain to the Nigeria Data Protection Commission if you are not satisfied with how we respond.

Decisions made automatically

Your WageScore is calculated from how you use Wagezapp: whether advances were repaid as expected, how steady your earnings are, and how long you have been on the platform. It affects how much you can draw.

You can ask how a score was arrived at, and you can ask for a decision to be looked at by a person rather than left to the calculation. An assessment of the privacy impact of the scoring is carried out before it is put into use, as the Act requires.

Changes, and how to reach us

If this policy changes in a way that affects you, you will be told in the app before the change takes effect, not only by a new date at the top of this page.

Needs Fiinwage

A postal address, a contact email and the named data protection officer all have to come from Fiinwage. They are deliberately not filled in here rather than invented.