Daya Borders Privacy Policy

1. Introduction

Daya Borders ("Borders", "we", "us", or "our") is a personal app for people in Nigeria who are paid from abroad, and the data controller for the personal information described in this policy. We are committed to protecting the privacy and security of your personal information.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you:

• visit or interact with our website at dayaborders.com and its subdomains;
• create or use a Borders account, including in the Borders app; or
• otherwise communicate with us.

We refer to all of these collectively as the "Service".

Please read this policy carefully. By accessing or using the Service, you agree to the collection and use of information in accordance with this policy. Where we rely on your consent for a particular activity, we will ask for it separately and you may decline or withdraw it.

2. Information We Collect

2.1 Website Visitors

When you visit dayaborders.com, we and our partners may collect:

• Device and browser information: browser type and version, operating system, screen size, and language settings.
• Network information: IP address (which indicates your approximate location) and user agent string.
• Usage information: pages viewed, time spent on pages, links clicked, referring website or advertisement, and the search terms that brought you to us.
• Identifiers set by cookies and similar technologies: see Section 3.

You do not need an account for us to collect this information, and some of it is collected automatically. Section 3 explains which of it is optional and how to decline.

2.2 Account Information

When you create an account or use our Service, we may collect:

• Account Information: email address, first name, last name, and username.
• Authentication Credentials: passkey data (WebAuthn credentials), PIN (stored securely on-device), and one-time passwords (OTPs) for verification.

2.3 Identity and Security Information

To enhance user protection and account security, and to help prevent fraud and bot activity, we collect identity and security information, including:

• Selfie Photographs and Identity Information: selfie photographs and identity-related information used to enhance protection and security for our users, confirm account ownership, and help prevent the Service from being spammed or abused by fraudulent users or bots.
• Identity Documents: government-issued identification documents (passport, driver's licence, or national identification card), selfie photographs submitted with those documents, and the country of issuance where needed to confirm account ownership and protect the Service from abuse.

2.4 Financial Information

In the course of providing the Service, we collect financial information, including:

• Bank Account Details: bank name, account number, and account name for withdrawals to Nigerian bank accounts and transfers to international bank accounts.
• Transaction History: records of deposits, withdrawals, conversions, transfers, and card payments (including amounts, fees, and status), and account balances.

2.5 Device and Technical Information

We automatically collect certain device and technical information when you use the Service:

• Device Identifiers: device type, device name, and operating system name and version.
• Network Information: IP address and user agent string.
• Application Information: app version and build number.

2.6 Usage and Telemetry Data

We collect limited usage data to improve the reliability and performance of the Service:

• Event Data: interactions with key features such as passkey setup, login flows, and recovery processes.
• Telemetry Logs: timestamped client events buffered in memory for diagnostic purposes. Telemetry collection may be enabled or disabled based on environment configuration.

2.7 Notification Preferences

We collect your preferences for receiving notifications, including:

• Communication Channels: push notification and email preferences.
• Notification Categories: preferences for deposit confirmations and withdrawal updates.
• Push Notification Tokens: device tokens required to deliver push notifications through our push notification provider.

2.8 Face Data-Specific Disclosures

To make our face-data practices clear:

• Device Biometrics Are Not Collected by Borders: we do not collect, receive, or store biometric templates or scans created by Apple Face ID, Touch ID, or similar device-level biometric systems. Those biometric templates remain on your device and are not shared with us.
• Passkey Recovery Selfies Are Not Retained by Borders: if you use the passkey recovery flow, we may ask you to capture a selfie to re-confirm your identity against information already linked to your account. We use that selfie for a one-time identity check and do not retain it after the request is completed.
• Selfie Images We Do Retain: we retain selfies and other face images submitted during account security and identity confirmation checks. We store this face data to enhance the protection and security of our users, confirm account ownership, help ensure the Service is not spammed or abused by fraudulent users or bots, and support short-term review of suspected abuse or account-security issues.
• We Do Not Retain Face Data Indefinitely: retained selfie images are stored for up to 30 days after submission and are then deleted. We use this specific retention period because it gives us a limited window to review security alerts, investigate suspected fraudulent or bot activity, and resolve related support issues without keeping face data longer than necessary.
• Third Parties We Share Face Data With: we do not share face data with third parties.
• Third-Party Storage of Face Data: because we do not share face data with third parties, no third party stores face data on our behalf.

Face data is not used for advertising, is not shared with advertising partners, and is never used to build a marketing profile.

3. Cookies and Similar Technologies

A cookie is a small text file placed on your device when you visit a website. We also use technologies that work in a similar way, including pixels (small pieces of code that record that a page was viewed), local storage, and software development kits inside the Borders app. In this policy we refer to all of them as "cookies".

3.1 The Categories We Use

Strictly necessary cookies are set automatically because the Service cannot be delivered without them. Everything else is set only if you accept it. Nothing in the other two categories runs before you make a choice, and you can accept some categories and decline others.

3.2 Your Choices

When you first visit dayaborders.com you will see a consent notice offering a clear option to accept or decline each optional category. Declining costs you nothing — the Service works the same way, and we will not treat you differently for it.

You can change your choice at any time using the "Cookie settings" link in the site footer. Withdrawing consent is as easy as giving it, and takes effect immediately for future collection.

You can also control cookies through your browser settings, and reset or limit the advertising identifier on your mobile device through your device settings. Blocking strictly necessary cookies through your browser may stop parts of the Service from working.

4. Analytics and Advertising Partners

We use third-party tools to understand how our website is used and to measure whether our advertising works. This section describes them and says what each receives.

Advertising pixels load only where you have accepted advertising cookies, and may not be active at all times.

4.1 Who They Are

These partners are established outside Nigeria. Section 7 explains the basis on which we transfer data to them.

4.2 What These Partners Receive

When the relevant category is active, these partners may receive your IP address, information about your browser and device, the pages you viewed on dayaborders.com, and the actions you took, together with an identifier they use to recognise your browser. If you are signed in to an advertising partner's own service on the same device, they may be able to connect this activity to your account with them.

They do not receive: your Borders account credentials, your identity documents, your face data, your bank account details, your balances, or your transaction history. We do not send any of that to any analytics or advertising partner, and we do not sell your personal information to anyone.

Our advertising partners use the information for their own purposes as well as ours, as described in their own privacy policies, and act as independent controllers of that data. We have no control over what they do with it once received. Our analytics partners act on our instructions and are not permitted to use the data for their own purposes.

4.3 If You Do Nothing

If you decline, or close the notice without accepting, no analytics or advertising cookies are set and nothing is sent to any of the partners above.

5. How We Use Your Information

We use the information we collect for the following purposes:

• Account Management: to create, maintain, and secure your account.
• Service Delivery: to provide your US dollar and euro account details and to facilitate deposits, conversions, withdrawals, transfers, and virtual card payments on the platform.
• Identity and Account Protection: to confirm account ownership, enhance protection and security for our users, and help prevent fraud, impersonation, and bot activity.
• Transaction Processing: to process and settle transactions, calculate and apply fees, and maintain accurate ledger records.
• Communications: to send you transaction confirmations, security alerts, account notifications, and service updates based on your notification preferences.
• Security and Fraud Prevention: to detect, investigate, and prevent fraudulent transactions, unauthorised access, and other harmful activities.
• Compliance: to comply with applicable laws, regulations, legal processes, tax reporting, and record-keeping obligations.
• Service Improvement: to analyse usage patterns, diagnose technical issues, and improve the performance and reliability of the Service.
• Marketing and Advertising: to measure the effectiveness of our advertising, and to show Borders advertisements to people who may be interested in the Service. We do this only where you have accepted advertising cookies, or where you have otherwise consented.

5.1 Our Lawful Bases for Processing

Under section 25 of the Nigeria Data Protection Act 2023, we must have a lawful basis for each thing we do with your personal information. Ours are:

Where we rely on your consent, you may withdraw it at any time and we will stop that activity. Withdrawing consent does not affect anything we did lawfully before you withdrew it, and does not affect processing we carry out on another basis — we cannot, for example, stop verifying your identity, because that is a legal obligation.

6. How We Share Your Information

We do not sell your personal information. We may share it in the following circumstances:

6.1 Service Providers

We share information with third-party service providers who assist us in operating the Service, including:

• Payment Processors and Banking Partners: including our partner banks and our card issuing partner, to provide your US dollar and euro account details and your virtual USD card, and to facilitate deposits, conversions, withdrawals, transfers, and bank account verification.
• Notification Services: to deliver push notifications and email communications.
• Cloud Infrastructure Providers: to host and operate the Service securely.
• Identity Verification Providers: to verify users' identities for KYC.

These providers act on our instructions and are not permitted to use your information for their own purposes.

6.2 Analytics and Advertising Partners

As described in Section 4, and only where you have accepted the relevant category of cookies.

6.3 Regulatory and Legal Obligations

We may disclose your information where required by law or in response to valid legal processes, including:

• requests from regulatory authorities, law enforcement agencies, or courts;
• compliance with applicable legal, tax reporting, fraud-prevention, and public-safety obligations;
• protection of our rights, property, or safety, or the rights, property, or safety of our users or the public.

6.4 Business Transfers

In the event of a merger, acquisition, reorganisation, or sale of assets, your information may be transferred as part of the transaction. We will notify you of any such change and any choices you may have regarding your information.

6.5 With Your Consent

We may share your information for other purposes with your explicit consent.

7. International Transfers of Personal Data

Some of the providers and partners described above are located outside Nigeria. This includes our cloud infrastructure, our push notification provider, and every analytics and advertising partner described in Section 4, all of which are established in the United States.

Where we transfer your personal information outside Nigeria, we do so on one of the following bases:

• the recipient is subject to laws, binding corporate rules, contractual clauses, a code of conduct, or a certification mechanism that provides a level of protection substantially similar to that required by the NDPA;
• the transfer is necessary for the performance of a contract with you;
• the transfer is necessary for compliance with a legal obligation; or
• you have consented to the transfer after being informed of the possible risks.

Transfers to the partners described in Section 4 take place only where you have accepted the relevant category of cookies. Where those partners in turn pass data to their own subprocessors outside Nigeria, that onward transfer is covered by the same basis.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal information, including:

• Encryption: sensitive credentials and authentication tokens are stored using device-level secure storage (encrypted keychain/keystore).
• Authentication Security: we use OAuth 2.0 with access and refresh token pairs, with automatic token rotation.
• Access Controls: role-based access controls for internal administrative operations, with audit logging for all sensitive actions.
• Secure Transmission: all data transmitted between the application and our servers is encrypted using industry-standard protocols (TLS/HTTPS).

While we strive to protect your information, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security.

8.1 Personal Data Breaches

If a breach of security leads to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your personal data, and that breach is likely to result in a risk to your rights and freedoms, we will notify the Nigeria Data Protection Commission within 72 hours of becoming aware of it, as required by section 40 of the Nigeria Data Protection Act 2023. Where the breach is likely to result in a high risk to you, we will notify you directly and immediately.

9. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you with the Service. We may also retain certain information as required by law or for legitimate business purposes, including:

• Transaction Records: retained in accordance with applicable financial record-keeping requirements.
• Selfie Images and Related Identity Data: retained for up to 30 days after submission so we can review security alerts, investigate suspected fraudulent or bot activity, and resolve related support issues, after which they are deleted.
• Passkey Recovery Face Images: used only for a one-time identity check and not retained by us after the request is completed.
• Audit Logs: suspension events and administrative actions are retained in immutable audit logs.
• Account Data: retained for a reasonable period after account closure to comply with legal obligations and resolve disputes.
• Cookie Identifiers: retained for the lifetime of the relevant cookie.
• Data Held by Partners: analytics and advertising partners retain data according to their own policies.

10. Your Rights

If you are in Nigeria, the Nigeria Data Protection Act 2023 gives you the following rights over your personal information. If you are elsewhere, you may have these or similar rights under your local law.

• Access: request a copy of the personal information we hold about you.
• Correction: request correction of inaccurate or incomplete personal information.
• Deletion: request deletion of your personal information, subject to legal and regulatory retention requirements.
• Restriction: request that we restrict the processing of your personal information in certain circumstances.
• Data Portability: request a copy of your personal information in a structured, commonly used, and machine-readable format.
• Withdrawal of Consent: where processing is based on consent, withdraw your consent at any time.
• Objection: object to the processing of your personal information for certain purposes, including direct marketing.
• Human Review: where a decision about you is made solely by automated means and significantly affects you, request that a person reviews it.

To exercise any of these rights, please contact us using the details provided in Section 14. We will respond within the period required by law. We may need to verify your identity before acting on a request, which protects you as much as us.

You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe we have handled your personal information unlawfully. We would ask that you contact us first so we can try to put it right, but you are not required to. The Commission can be reached at ndpc.gov.ng.

11. Device Permissions

The Borders app may request the following device permissions:

• Camera: required for capturing selfie photographs to enhance user protection and security and to help prevent fraudulent users or bots from abusing the Service.
• Photo Library: required for uploading identification documents during enhanced account security checks.
• Biometric Authentication (Face ID / Fingerprint): used for secure account access and transaction confirmation on your device. We do not receive or store the biometric template created by your device operating system.

You may manage these permissions through your device settings at any time. Disabling certain permissions may limit your ability to use specific features of the Service.

12. Children's Privacy

The Service is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will take steps to delete such information promptly.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on dayaborders.com and within the Borders app, or by sending you a notification. The "Last Updated" date at the top of this policy indicates when it was last revised.

Where a change requires your consent, we will ask for it rather than relying on your continued use of the Service.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Daya Borders
General enquiries: support@dayaborders.com
Website: https://dayaborders.com

For privacy questions, data subject requests, and complaints about how we handle your personal information, please contact us at support@dayaborders.com. If you are not satisfied with our response, Section 10 explains your right to complain to the Nigeria Data Protection Commission.

15. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria, including the Nigeria Data Protection Act 2023 (NDPA), the NDPA General Application and Implementation Directive, and any applicable regulations issued by the Nigeria Data Protection Commission (NDPC).