Privacy Policy

Javex is a Nigerian-registered technology company that operates Javex App, a cryptocurrency exchange and digital services platform that enables users to buy and sell cryptocurrencies, trade gift cards, manage digital wallets, and pay bills (including airtime, data, electricity, internet and cable TV). This Privacy Policy explains how we collect, use, store and protect your personal data when you use the Javex mobile application, our website, or any related service. This Policy has been prepared in compliance with the Nigeria Data Protection Regulation (NDPR) 2019, the Nigeria Data Protection Act (NDPA) 2023, and other applicable Nigerian laws.

At Javex, your privacy is highly valued and we take all reasonable steps to protect your personal information in line with this Privacy Policy. By signing up for, accessing, or using the Javex App or any of our products or services, you accept and consent to the practices described in this Privacy Policy. The Javex service is not intended for children, and we do not knowingly collect data from individuals under 18 years of age.

To enable us to open and manage accounts, provide our services, and comply with Nigerian laws and regulations (such as KYC and AML obligations), we may collect the following: • Identity Data: Full name, gender, date of birth, means of identification (National ID, Passport, Driver's Licence, or BVN where required). • Contact Data: Residential address, email address, phone number. • Financial and Transaction Data: Wallet addresses, transaction history, payment details, linked bank accounts, gift-card exchange records, and billing details. • Technical Data: Device identifiers, IP address, mobile operating system, time zone settings, browser information, and logs of app interactions. • Profile and Usage Data: Username, preferences, transaction frequency, feedback, communication settings, and in-app activity. • Marketing and Communications Data: Preferences for receiving marketing information, promotional offers, and communication preferences.

We collect data in the following ways: • When you register an account on the Javex App or website • Through your use of our services and your interaction with our customer support • From transaction records, payment confirmations, and KYC submissions • When you contact us by email, phone, or in-app chat • Automatically through device logs, cookies, and app analytics • From third-party verification or payment partners, subject to your consent

Cookies are small text files placed on your device to help us provide a smoother experience and analyze user activity. We use cookies and similar technologies to: • Enable secure login and maintain session state • Track website and app usage for performance and analytics • Measure marketing effectiveness • Prevent fraud and enhance security You can disable cookies in your device settings, but this may limit certain app functionalities.

We process personal data for the following purposes: • To verify your identity and comply with KYC/AML regulations • To open, operate, and manage your Javex account • To execute cryptocurrency trades, gift-card exchanges, and bill payments • To communicate with you and provide customer support • To improve our services, products, and app functionality • To detect, prevent, and investigate fraud or suspicious activity • To send marketing information (only with your consent) • To comply with applicable Nigerian laws, regulatory directives, and court orders

To provide and operate our services, we may share your data with: • Third-party processors and partners, such as payment providers, banks, identity verification services, analytics providers, and cloud hosting companies • Professional advisers, such as auditors, legal counsel, or consultants (under confidentiality obligations) • Law enforcement or regulatory authorities, where required by law • Affiliates or service integrators, who assist in operating parts of our business We ensure that all third parties respect the confidentiality and security of your data.

Javex implements robust technical and organisational security measures including: • End-to-end encryption (in transit and at rest) • Two-factor authentication (2FA) • Role-based access control and internal audit logs • Secure cloud storage using compliant infrastructure • Staff training and confidentiality undertakings In the unlikely event of a data breach, we will promptly notify affected users and the Nigeria Data Protection Commission (NDPC) in line with Section 32 of the NDPA 2023.

Some service providers (e.g., cloud storage) may process your data outside Nigeria. When such transfers occur, we ensure compliance with Article 2.11 of the NDPR and Section 41 of the NDPA 2023, including the use of contractual safeguards or adequacy decisions to protect your personal data.

We will retain your personal data for as long as necessary to fulfil the purposes for which it was collected. • KYC and transaction records: minimum of 5 years in accordance with AML regulations • Account data: for the duration of your relationship with us • Backup and audit logs: as required for compliance and risk management • Marketing data: until you withdraw consent After expiry of the retention period, your data will be securely deleted or anonymised.

Under the NDPR (2019) and NDPA (2023), you have the following rights: • Access – to request a copy of the personal data we hold about you • Correction – to rectify incomplete or inaccurate data • Erasure – to request deletion where legally permissible • Restriction – to limit processing in certain circumstances • Objection – to object to processing based on legitimate interests • Portability – to request transfer of your data in machine-readable form • Withdrawal of consent – to withdraw previously given consent To exercise any of these rights, contact us at support@javex.app or +234 901 122 0027.

By creating an account or continuing to use Javex services, you signify your acceptance of this Privacy Policy. If you do not agree with this Policy, please discontinue use of the Javex App.

We may revise this Policy periodically to reflect regulatory or operational changes. Any material updates will be communicated via email, app notification, or website notice. Please review this Policy regularly. For data protection enquiries, contact our Data Protection Officer at: Javex Technologies Ltd Email: support@javex.app Phone: +234 901 122 0027 You may also contact the Nigeria Data Protection Commission (NDPC) at https://ndpc.gov.ng if you are unsatisfied with our response.