1. Introduction

Welcome to VTUGATE ("we," "our," or "us"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our VTU API gateway services.

We respect your privacy and are committed to protecting your personal data. By accessing or using VTUGATE services, you consent to the practices described in this Privacy Policy.

2. Information We Collect

2.1 Personal Information

When you register for VTUGATE, we collect:

• Full name and contact information
• Email address
• Phone number
• Business name and registration details
• Bank account information for settlements
• Government-issued ID (for KYC verification)

2.2 Transaction Data

When you use our API services, we collect:

• API keys and authentication tokens
• Transaction amounts and types
• Beneficiary phone numbers (for airtime/data)
• Meter numbers (for electricity)
• Smartcard numbers (for TV subscriptions)
• IP addresses and device information
• Transaction timestamps and status

2.3 Technical Information

• Log files and error reports
• API usage patterns and metrics
• Browser type and version
• Operating system
• Cookies and similar tracking technologies

3. How We Use Your Information

We use collected information to:

• Provide and maintain VTU services
• Process transactions and manage your wallet
• Verify your identity (KYC compliance)
• Prevent fraud and unauthorized access
• Send transaction notifications and receipts
• Provide customer support
• Improve our services and develop new features
• Comply with legal obligations and regulations
• Send service updates and marketing communications (with consent)

4. Data Sharing and Disclosure

4.1 Service Providers

We share data with:

• VTU service providers (for transaction processing)
• Payment processors and banks
• Cloud hosting services
• Customer support platforms
• Analytics and monitoring tools

4.2 Legal Requirements

We may disclose information when required by:

• Law enforcement agencies
• Regulatory authorities (e.g., CBN, NCC)
• Court orders or legal proceedings
• To protect our rights, property, or safety

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the business transaction.

5. Data Security

We implement appropriate technical and organizational measures to protect your data, including:

• End-to-end encryption for sensitive data
• Secure API key management
• Regular security audits and penetration testing
• Access controls and authentication mechanisms
• Data anonymization where possible
• Secure data centers with redundancy

However, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security.

6. Data Retention

We retain your data for as long as necessary to:

• Provide services to you
• Comply with legal obligations (minimum 5 years for financial records)
• Resolve disputes and enforce agreements
• Maintain business records

Transaction data is retained for 7 years to comply with Nigerian financial regulations.

7. Your Rights

You have the right to:

• Access your personal data
• Correct inaccurate data
• Request deletion of your data
• Object to data processing
• Request data portability
• Withdraw consent at any time
• Lodge complaints with regulatory authorities

To exercise these rights, contact us at privacy@vtugate.com.

8. Cookies and Tracking

We use cookies and similar technologies to:

• Authenticate users and maintain sessions
• Remember preferences and settings
• Analyze website traffic and usage patterns
• Improve user experience

You can control cookies through your browser settings. However, disabling cookies may affect website functionality.

9. Third-Party Links

Our services may contain links to third-party websites. This Privacy Policy does not apply to those sites. Review their privacy policies before providing personal information.

10. Children's Privacy

VTUGATE services are not intended for individuals under 18 years of age. We do not knowingly collect data from children. If you believe we have collected data from a child, contact us immediately.

11. International Data Transfers

Your data may be transferred to and processed in countries outside Nigeria. We ensure adequate protection through standard contractual clauses and other safeguards as required by law.

12. Changes to Privacy Policy

We may update this Privacy Policy periodically. We will notify you of significant changes via email or through our dashboard. Continued use of our services after changes constitutes acceptance.