Privacy Notice

1. Our commitment

SW Global Pay is operated by SAMWELL NM GLOBAL NETWORK. We aim to process personal data in accordance with applicable Nigerian data-protection law, including the Nigeria Data Protection Act 2023 (the Act) and the Nigeria Data Protection Commission’s General Application and Implementation Directive (GAID) 2025.

We aim to apply the data-protection principles in section 24 of the Act: fairness, lawfulness and transparency; purpose limitation; data minimisation; storage limitation; accuracy; confidentiality, integrity and availability; accountability; and duty of care.

2. Information we collect

Depending on your use of SW Global Pay, we may collect:

• Identification and account information, including name, email address, telephone number, date of birth and account identifiers.
• Business and transaction information, including business profile details, customers, invoices, payment links, transaction amounts, currencies, transaction references, payment status, refund and chargeback records.
• Security and technical information such as IP address, device and browser information, login history, security events, rate-limit events and audit records.

Where identity verification is enabled in the future, we may process identity-document information, verification status and supporting documentation as disclosed at the time.

We do not intentionally store raw card credentials where the payment processor can collect them directly.

3. Why we process information

We process information to provide accounts and Services, authenticate users, prevent fraud and abuse, process and reconcile transactions, provide support, manage disputes, maintain accounting and audit records, comply with legal and provider requirements, secure the platform and communicate with users.

Our legal bases may include performance of a contract, compliance with legal obligations, legitimate interests, consent where required and other lawful grounds recognised under applicable data-protection law.

4. Payment processors

Payment information may be transmitted to payment processors including Flutterwave. Such providers process information under their own legal and contractual obligations.

5. Infrastructure and service providers

We may use hosting, database, email, security, analytics and infrastructure providers where necessary to operate the Services. Current infrastructure may include Cloudflare, Supabase, Resend and payment-processing providers.

We require reasonable security and confidentiality protections appropriate to the service and information involved.

6. International transfers

Some service providers may process information outside Nigeria. Where personal data is transferred across borders, SW Global Pay will seek to rely on a basis for transfer recognised under Part VIII of the Act and apply the safeguards it requires.

7. Data retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including provision of Services, fraud prevention, contractual obligations, legal compliance, disputes, chargebacks, audits, security and recordkeeping.

Different records may have different retention periods. Information subject to litigation, a regulatory request, investigation, chargeback or dispute may be retained longer where necessary.

8. Your rights

Subject to applicable law and any lawful limitations, you may have rights to be informed about processing, access your personal data, correct inaccurate data, request deletion, restrict or object to certain processing, request portability, withdraw consent where processing relies on consent, and not be subject to certain decisions based solely on automated processing.

If you are not satisfied with how we handle your request or your personal data, you have the right to lodge a complaint with the Nigeria Data Protection Commission.

Requests may be sent to support@swgpay.com with the subject line “Privacy Request”.

9. Security

SW Global Pay uses technical and organisational safeguards designed to protect personal data. These may include encryption, restricted administrative access, access-restricted storage, secure session management, access logging, audit trails, rate limiting and monitoring.

No information system can guarantee absolute security.

10. Data incidents

Where a data incident occurs, SW Global Pay will investigate, contain and document the incident and make notifications required by applicable law.

11. Children’s data

SW Global Pay is not intended for individuals under 18. We do not knowingly provide accounts to children.

12. Changes

We may update this Privacy Notice when our Services or legal obligations change. Material changes will be communicated where appropriate.