4. How We Use Your Information

We use your information to:

• Create and manage your account
• Verify your identity
• Process cryptocurrency trades
• Complete Naira settlements
• Prevent fraud
• Detect suspicious transactions
• Comply with AML and KYC obligations
• Perform sanctions screening
• Improve AI responses
• Improve our products
• Respond to customer support requests
• Investigate disputes
• Protect our systems
• Meet legal and regulatory obligations

5. Legal Basis for Processing

Where applicable, we process your personal information based on one or more of the following:

• Your consent
• Performance of our contract with you
• Compliance with legal obligations
• Legitimate business interests
• Protection against fraud
• Regulatory requirements

6. AI Processing

Swiftly uses artificial intelligence to provide faster customer interactions.

The AI may process your messages to:

• Understand trading instructions
• Answer questions
• Assist with account management
• Generate transaction confirmations
• Improve customer experience

7. Identity Verification (KYC)

To comply with financial regulations, Swiftly may request:

• Government-issued ID
• Selfie verification
• Proof of address
• Bank verification
• Additional supporting documents
• Source of funds documentation

8. Transaction Monitoring

Swiftly continuously monitors transactions for:

• Money laundering
• Terrorist financing
• Fraud
• Scam activity
• Account compromise
• High-risk blockchain activity
• Unusual trading behavior
• Sanctions violations

9. Cookies and Analytics

Where users access Swiftly through our website, we may use:

• Cookies
• Analytics tools
• Performance monitoring
• Security cookies
• Authentication cookies

These technologies help us improve security and user experience.

10. Information Sharing

We may share information with:

11. International Data Transfers

Your information may be processed or stored outside Nigeria where our technology providers or service partners operate.

12. Data Security

Swiftly employs commercially reasonable security measures including:

• Encryption in transit
• Encryption at rest
• Secure cloud infrastructure
• Role-based access controls
• Multi-factor authentication
• Continuous monitoring
• Security audits
• Fraud detection systems
• Incident response procedures

13. Data Retention

We retain information only for as long as necessary to:

• Provide our services
• Meet legal obligations
• Resolve disputes
• Detect fraud
• Enforce our agreements

14. Your Rights

Subject to applicable law, you may have the right to:

• Access your personal information
• Correct inaccurate information
• Request deletion of certain information
• Restrict processing
• Object to processing
• Withdraw consent where applicable
• Request data portability
• Lodge complaints with the appropriate data protection authority

15. Marketing Communications

We may send:

• Transaction notifications
• Security alerts
• Service updates
• Product announcements
• Promotional messages

16. Children's Privacy

Swiftly is intended only for individuals who are legally permitted to use financial and cryptocurrency services in their jurisdiction.

17. Third-Party Services

Swiftly may integrate with third-party providers including:

• Banks
• Payment processors
• Blockchain infrastructure providers
• Identity verification providers
• Analytics providers
• Cloud hosting providers
• WhatsApp (Meta)

18. Data Breach Response

If we become aware of a data breach affecting your personal information, we will investigate promptly and, where required by applicable law, notify affected users and relevant regulatory authorities.

19. Compliance with Applicable Laws

Swiftly complies with applicable laws and regulations governing:

• Digital assets
• Financial services
• Anti-Money Laundering (AML)
• Counter-Terrorist Financing (CTF)
• Fraud prevention
• Consumer protection
• Data protection
• Sanctions compliance

20. Changes to this Privacy Policy

We may update this Privacy Policy periodically.

21. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or the processing of your personal information, please contact:

22. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria, without prejudice to any applicable international data protection obligations.