Privacy Policy

Last updated: January 1, 2026

1. Introduction

Sun Jade Nigeria Limited ("Sun Jade", "we", "our", or "us") operates the SunPay mobile application ("the App"), a closed-loop prepaid payment system for use exclusively within Sun Jade's service network. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use the App. By using SunPay, you consent to the practices described herein.

2. Information We Collect

2.1 Information You Provide

• Account Information: Full name, email address, and optionally your phone number at registration
• Payment Information: Transaction history, SunCoin acquisition amounts, and payment channels used. Card numbers and bank details are handled exclusively by our payment processors and are never stored by Sun Jade
• Support Communications: Any messages or correspondence directed to our support team
• Merchant Registration Data: Business name, business type, and location submitted via our merchant interest form

2.2 Information Collected Automatically

• Usage Data: Features accessed, session duration, and in-app navigation patterns
• Device Information: Device type, operating system version, and App version
• Transaction Records: All SunCoin transactions including amount, type, timestamp, and parties involved
• NFC Activity: Card tap events, terminal identifiers, and associated transaction amounts

3. How We Use Your Information

We use your information to create and manage your SunPay account; process SunCoin acquisitions and transactions; verify your identity and prevent fraud; deliver transaction confirmations and account notifications; provide customer support; improve App performance and features; comply with applicable legal and regulatory obligations; and send service-related communications. We do not send marketing communications without your explicit consent.

4. How We Share Your Information

We do not sell your personal information to any third party. We may share your information with:

• Payment Processors: Including Flutterwave and other authorised processors, solely to facilitate transactions. These providers operate under their own privacy policies and are bound by contractual data protection obligations
• Infrastructure Providers: Cloud hosting and technical service providers necessary for App operation, including Supabase. All providers are contractually required to maintain appropriate data security standards
• Law Enforcement and Regulatory Bodies: Where required by Nigerian law, valid court order, or to protect the rights, safety, or property of Sun Jade or its users
• Business Successors: In the event of a merger, acquisition, or asset sale, with advance notice provided to affected users

5. Data Security

We implement industry-standard technical and organisational measures to protect your personal information, including TLS/SSL encryption for all data in transit; encrypted storage for sensitive data at rest; row-level database security ensuring users access only their own records; access controls limiting data exposure to authorised personnel only; and regular security monitoring and review. No method of electronic transmission or storage is wholly secure. You use the App at your own risk and are encouraged to maintain strong account credentials.

6. Data Retention

We retain your personal information for as long as your account remains active or as necessary to provide our services. Transaction records are retained for a minimum of seven years in accordance with applicable Nigerian regulatory requirements. Upon account deletion, personal data is removed within 30 days, except where retention is required by law or legitimate business necessity.

7. Your Rights

Subject to applicable law, you have the right to request access to the personal data we hold about you; correction of inaccurate or incomplete information; deletion of your account and associated personal data; a portable copy of your transaction history; and to object to processing of your data for purposes beyond service delivery. To exercise any of these rights, contact us at sunpayngltd@gmail.com. We will respond within 30 days.

8. Children's Privacy

SunPay is not intended for users under 18 years of age. We do not knowingly collect personal information from minors. If we become aware that a minor has registered, the account will be terminated and associated data deleted promptly.

9. Cookies and Tracking

The SunPay mobile App does not use cookies. Our website may use essential session cookies for navigation. We do not deploy third-party advertising trackers, analytics pixels, or behavioural tracking tools on our website or App.

10. Third-Party Links

The App may contain links to third-party websites or services. Sun Jade is not responsible for the privacy practices of such third parties and encourages you to review their policies before submitting personal information.

11. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be communicated via email or in-app notification prior to taking effect. Continued use of the App following notification constitutes acceptance of the revised policy.

12. Contact

Sun Jade Nigeria Limited
Email: sunpayngltd@gmail.com