Privacy

Winpay Legal Policies

1. Privacy Policy

Effective Date: July 25, 2026

Introduction

Winpay (“Winpay”, “we”, “our”, or “us”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, disclose, and safeguard your information when you access or use the Winpay website, mobile application, APIs, and related services.

Information We Collect

We may collect:

• Full name
• Email address
• Phone number
• Residential address
• Date of birth
• Government-issued ID
• BVN/NIN (where applicable)
• Selfie and facial verification data
• Bank account details
• Transaction history
• Device information
• IP address
• Browser information
• Login activity
• Location information (where permitted)
• Social profile information and user-generated content

Why We Collect Information

We use your information to:

• Create and manage your account.
• Verify your identity.
• Process payments.
• Prevent fraud.
• Detect suspicious activities.
• Comply with financial regulations.
• Improve our services.
• Provide customer support.
• Secure our platform.

Information Sharing

Your information may be shared only with:

• Licensed financial institutions
• Payment processors
• Banking partners
• Identity verification providers
• Fraud prevention agencies
• Regulatory authorities where legally required
• Technology vendors supporting our platform

Winpay never sells customer personal information.

Data Protection

We protect your information using:

• Encryption
• Firewalls
• Secure infrastructure
• Role-based access control
• Continuous security monitoring
• Multi-factor authentication where applicable

Your Rights

You may request to:

• Access your data
• Correct inaccurate information
• Delete information where legally permitted
• Withdraw consent where applicable
• Request a copy of your information

Contact

For privacy enquiries, please contact Winpay Support through our official website or mobile application.

2. Cookie Policy

What Are Cookies?

Cookies are small files placed on your device to improve your browsing experience.

Cookies We Use

Winpay uses:

• Essential Cookies
• Authentication Cookies
• Security Cookies
• Performance Cookies
• Analytics Cookies
• Preference Cookies

Purpose

Cookies help us:

• Keep you securely logged in.
• Prevent fraud.
• Remember your preferences.
• Improve website performance.
• Analyze platform usage.
• Deliver a better user experience.

Managing Cookies

Most browsers allow you to disable cookies. Some website features may become unavailable if cookies are disabled.

3. AML/KYC Policy

Commitment

Winpay maintains a strict Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance program designed to prevent money laundering, terrorist financing, fraud, identity theft, and other financial crimes.

Customer Verification

Users may be required to submit:

• Government-issued identification
• Selfie verification
• BVN
• NIN
• Proof of address
• Additional verification where required

Risk Monitoring

Winpay continuously monitors:

• Transaction patterns
• Wallet activities
• Device behavior
• Login activity
• High-risk transactions
• Suspicious accounts

Reporting

Where required by applicable laws or regulatory authorities, Winpay may report suspicious activities to the appropriate government agencies without prior notice to the customer.

Account Restrictions

Winpay reserves the right to:

• Suspend accounts
• Freeze transactions
• Request additional documentation
• Reject transactions
• Permanently terminate accounts involved in fraudulent or illegal activities

4. Refund & Dispute Policy

Refund Eligibility

Refunds may be approved where:

• Duplicate payments occur.
• A transaction fails but funds are debited.
• Technical errors affect payment processing.
• Winpay determines that a refund is appropriate after investigation.

Non-Refundable Transactions

Refunds generally do not apply to:

• Successfully completed airtime purchases
• Successfully completed data purchases
• Utility bill payments successfully processed
• Bank transfers completed successfully
• Transactions initiated using incorrect information provided by the user

Dispute Process

To dispute a transaction, users should provide:

• Transaction ID
• Amount
• Date and time
• Description of the issue
• Supporting evidence where applicable

Investigation Timeline

Winpay aims to acknowledge disputes promptly and investigate them as quickly as reasonably possible. Resolution timelines may vary depending on the complexity of the case and any involvement of banks, payment processors, or regulatory bodies.

Chargebacks

Fraudulent or abusive chargebacks may result in account suspension while investigations are ongoing.

Final Decision

Winpay’s decision shall be based on transaction records, system logs, banking confirmations, and applicable regulatory requirements.

5. Service Level Agreement (SLA)

Service Availability

Winpay targets 99.9% platform availability, excluding scheduled maintenance and force majeure events.

Service Commitments

Winpay aims to provide:

• Secure wallet services
• Fast payment processing
• High platform availability
• Reliable API connectivity
• Continuous fraud monitoring
• Timely customer support

Customer Support Targets

Maintenance

Scheduled maintenance may be carried out periodically to improve performance, security, or reliability. Where practicable, advance notice will be provided.

Limitations

Winpay is not liable for service interruptions caused by:

• Banking network downtime
• Telecommunications failures
• Internet service disruptions
• Regulatory actions
• Force majeure events
• Third-party provider outages

Amendments

Winpay may revise these policies from time to time. Updated versions will be published on the official website and become effective upon publication.

By using Winpay, you acknowledge that you have read, understood, and agreed to these policies.