Privacy Policy

This policy applies to five groups of people:

Under Nigerian data protection law (NDPR 2019 and NDPA 2023), we are required to have a lawful basis for processing personal information. We rely on the following:

• Contractual necessity — to process your orders, manage your account, or pay out your earnings as a merchant.
• Legal obligation — for financial record-keeping, identity verification, and responding to lawful requests from competent authorities.
• Legitimate interest — where we have a genuine business reason that does not unfairly override your privacy rights. Examples include fraud prevention, platform security, and recording how a customer reached a store so we can work out the fee we charge that store (see Section 4).
• Consent — for optional activities such as marketing communications. You may withdraw consent at any time.

Sensitive personal data

Some purchases on the Platform — for example health, wellness, or adult products — may reveal information that Nigerian law treats as sensitive personal data, such as data concerning your health or your sex life. Where we process such data, we do so only as necessary to fulfil your order, on the lawful basis of contractual necessity or, where required, your explicit consent. We apply additional care to this data and share it only with the parties needed to complete and deliver your order.

Age confirmation for restricted content

Where a storefront offers age-restricted products, we may ask you to confirm that you are 18 or older before showing them. This confirmation may be stored in a functional cookie on your device so that we do not ask again during your session. It records only that a confirmation was given and contains no other personal information. See our Cookie Policy for more detail.

Information you provide

When you create an account or use the Platform, we collect:

• Your name, email address, and phone number
• A password — stored as a secure hash; never in plain text
• A profile picture, if you choose to provide one or import it via Google or Apple sign-in

Information collected automatically

When you use the Platform, we automatically collect:

• Device information — device type, operating system, app version, and device identifiers
• Network information — IP address and mobile network details
• Diagnostic data — technical error reports and security logs generated while operating the Platform
• Push notification tokens — your APNs token (iOS) or FCM token (Android)
• Approximate location — if you grant location permission, the app checks your device location once when it opens (and again only if you tap the location button yourself) to show shops and prices for your area. We store only your state (for example, Lagos) and a coordinate rounded to roughly 110 meters — never your precise position. The app does not track you in the background, does not follow your movements, and works without location permission (you simply see nationwide listings instead)
• Saved payment methods — when you pay by card, Paystack (our payment processor) gives us a secure reusable token so your next checkout is one tap. We never see or store your card number. You can remove a saved card anytime in Settings. Bank transfer and USSD payments save nothing

Information from third parties

• If you sign in with Google or Apple, we receive your name, email address, and profile picture
• We receive payment confirmation data from Paystack upon completion of a transaction
• We receive payment confirmation data from Breet when you complete a transaction using cryptocurrency
• If you are a merchant and connect your Meta (Facebook/Instagram) account for social commerce, we receive your Instagram Business account ID, username, display name, and an access token from Meta (see Section 5)
• We may receive interaction data when you engage with our demand intelligence system on social media

This section applies to people using the Paylo Marketplace app.

Account registration

We collect your name, email address, and password — or your Google or Apple identity if you use SSO.

Payments

Paylo never receives your card number or CVV. Payment details are entered directly into Paystack's secure environment. Upon successful payment, we store only a card token issued by Paystack, together with: card type, last four digits, expiry date, issuing bank, and card country.

If you pay using cryptocurrency, your payment is processed by our partner Breet and automatically converted to Nigerian Naira. Paylo does not receive, hold, or store your cryptocurrency wallet credentials or private keys. We receive only confirmation that your payment succeeded and the associated Naira value and transaction reference.

Buyer protection

When buyer protection is enabled, a fee of 0.5% of your order subtotal (minimum ₦100, maximum ₦10,000) is collected. This fee is held in escrow and returned to your Paylo Credits balance upon delivery confirmation or automatically after seven days.

How you found a store

Paylo charges sellers a fee only on customers Paylo brings them, not on the seller's own customers. To tell the two apart, we record how you reached a store. That might be through the seller themselves, such as their link, QR code, social media or WhatsApp, or through something Paylo runs, such as the marketplace, search, the Nearby view, recommendations, a wishlist, a Paylo ad or creator link, a sourcing request, or an AI assistant. On our website, this comes from the link you arrived on, including its referrer and any campaign tags.

We note this when you first add one of the store's products to your cart, message the store, follow it, or save one of its products. When you pay for your first order with that business, we keep a record linking your account to the business, showing whether Paylo introduced you and when.

• It never costs you anything. It only decides the fee the seller pays, which is taken from their payout. Prices are the same whichever way you arrive.
• What the seller sees. The seller can see whether you are their own customer or one Paylo introduced, and in general terms how (for example, "found you through Nearby"). They do not see your searches or your browsing.
• What we use it for. Working out seller fees, showing sellers why a fee was or wasn't charged, measuring how well Paylo brings sellers new customers, and making sure that when you arrive through a seller's own link we don't recommend their direct competitors to you. We do not use it to advertise to you.
• How long we keep it. If you don't place an order within 90 days, the note of how you reached the store expires. The record created by your first order is kept while your account exists. When you delete your account it is anonymised, so the fees sellers were charged can still be checked, but it is no longer linked to you.

We process this on the basis of our legitimate interest in charging sellers fairly under our contract with them.

Visual search

If you upload a photo to search for products, your image is transmitted to Google Cloud Vision for analysis. Paylo does not store your image. Only the search results are returned.

This section applies to people using the Paylo Business app.

Identity verification and payouts (KYC)

Payouts are not available until identity verification is complete. For this purpose, we collect:

• A government-issued ID (NIN card, driver's licence, or international passport)
• Bank account details — account holder name, NUBAN account number, bank name and code
• Business registration details where applicable — company name and CAC registration number
• Optionally, social media profile URLs for brand verification purposes

Transaction records and compliance

Unverified merchants cannot process payments — payment methods are disabled until identity verification is completed. We maintain a detailed audit log of every payment split, escrow state change, and payout event associated with your storefront. This log is retained indefinitely for financial and regulatory compliance purposes.

Fees on your orders

For each order, we record the platform fee rate applied and the reason for it: the customer is your own, the customer was introduced by Paylo (and how), the customer's 12-month introduction period has ended, or your plan carries no fee. We show this to you on the order and keep it with your transaction records. See How you found a store for what we record about customers to make this decision.

Social commerce (Meta / Instagram integration)

If you choose to connect your Meta account to enable Instagram social commerce, you authenticate directly with Meta using Facebook Login — Paylo never sees or stores your Meta password. Upon connection, we receive and store:

• Your Instagram Business account ID, username, and display name
• An access token issued by Meta, which we store encrypted at rest (AES-256) and use solely to operate the integration on your behalf
• The ID of the product catalogue we create in your own Meta Business portfolio

We use this data for one purpose: keeping your Paylo product listings synchronised with your Meta product catalogue (creating, updating, and removing catalogue items as you change them on Paylo), so your products can appear on your Instagram profile and in your posts. We do not post content on your behalf, read your messages, or access your followers.

Disconnecting and data deletion: You can disconnect the integration at any time from Account → Social Commerce in the Paylo Business app — this immediately deletes your stored access token and profile details. You can also revoke Paylo's access from your Meta settings (Settings → Business Integrations); Meta then notifies us and we delete the same data automatically. The product catalogue itself belongs to your Meta Business portfolio and remains under your control on Meta after disconnection.

Meta Platforms processes data you share with it under its own privacy policy as an independent data controller.

This section applies to merchants who run Paylo POS terminals, and to the staff who work on them.

Staff members

When a merchant adds someone to their team, we create a staff record for that person. For staff added by name alone, such as cashiers and stockkeepers who do not need an email address, we also generate an internal system identifier so activity can be attributed correctly. That identifier is not a working email address, cannot receive mail, and cannot be used to log in anywhere.

For each staff member we hold:

• Their name and role (for example, cashier or stockkeeper)
• Their terminal PIN, stored only as a salted cryptographic hash
• An activity log of what they do on the merchant's terminals: signing in, recording sales, and requesting PIN changes

We process this data on the basis of our contract with the merchant and the merchant's legitimate interest in running their business. The merchant is responsible for telling staff, before adding them, that their activity on a terminal is recorded and attributed to them by name.

Terminal PINs

Each staff member chooses their own PIN at the terminal. It is stored only as a salted hash, never in plain text, and it is never visible to anyone, including the business owner. Owners can approve a PIN change or clear a PIN so a new one can be set; they can never read or choose one. We record failed sign-in attempts so that repeated wrong guesses temporarily lock the PIN.

POS terminals

A device enrolled as a POS terminal receives a name chosen by the merchant and a cryptographic identity of its own. The private key is created inside the device's secure hardware and never leaves it. Paylo stores only the corresponding public key, the terminal's name, and its enrolment details. Security-relevant terminal events, including enrolment, removal, and PIN changes, are written to an audit log, and the business owner is notified by email each time one occurs.

In-person sales

Sales recorded at a terminal capture what was sold, the amount, the payment method, and an optional payment reference. We do not collect any personal information about the in-store customer at the till unless they choose to give it. A customer can scan their Paylo code or give their phone number to get a digital receipt and be recorded as that store's customer. If they give a number, we send one text message with their receipt and a link to confirm; nothing else happens unless they confirm, and we never send a second message. Walk-in customers are not Paylo users, and nothing about an in-person sale requires them to become one.

Staff rights

Staff members have the same rights over their personal data as everyone else (see Section 11). Because staff records are created and managed by the employer, requests are usually handled through the merchant who added you. You can also contact us directly at legal@usepaylo.com.

Across all user types, we use personal information for the following purposes:

• Operating, maintaining, and improving the Platform
• Processing orders, payments, and merchant payouts
• Working out the fees we charge merchants, and showing them why
• Detecting and preventing fraud and unauthorised access
• Responding to customer and merchant support requests
• Complying with Nigerian law and regulatory requirements

We do not sell your personal information. We do not use your data to train third-party AI models. We do not permit advertisers to target you by name or identity on the Platform.

Paylo operates a demand intelligence system that monitors public social media activity to identify product and service intent signals.

What we do not do

• We do not create Paylo accounts on behalf of individuals without their express action
• We do not collect private messages or non-public content
• We do not store personal profile information beyond what is publicly visible

Your rights as a Social User

If you believe your public content has been captured by our system and you wish to have it removed, contact us at legal@usepaylo.com. We will respond within 30 days.

Between customers and merchants

When a transaction occurs, merchants receive your name, contact details, delivery address, and order details — sufficient to fulfil the order. Card details are never shared with merchants.

Merchants can also see whether you are their own customer or one Paylo introduced to them, and in general terms how you found them (see Section 4).

For legal and regulatory reasons

We may disclose your information where required by a court order, lawful government request, or applicable Nigerian legislation — including to the CBN, NITDA, NDPC, or NFIU where relevant. Where transactions involve cryptocurrency, relevant transaction data may also be shared with payment partners and competent authorities as required for anti-money-laundering and financial-compliance purposes.

The following companies process personal data on our behalf:

We retain your data only for as long as necessary for the purpose it was collected, or as required by law.

You have the following rights in relation to your personal information:

Access

You may request confirmation of whether we hold data about you and obtain a copy of that data.

Correction

Most personal information can be updated directly within the app. Contact us for information you cannot amend yourself.

Deletion

You may request deletion of your account and associated personal data. We will anonymise your information immediately and delete it permanently within 30 days.

Portability

You may request a copy of your data in a structured, commonly used format. Use the "Download Your Data" feature in the app, or email legal@usepaylo.com.

Withdrawal of consent

Where processing is based on your consent, you may withdraw that consent at any time without affecting processing carried out before withdrawal.

We will respond to all rights requests within 30 days. Contact us at legal@usepaylo.com or write to Greyline Innovations Limited, Abuja, Nigeria.

• Encryption in transit — all data transmitted between your device and our servers is protected using TLS/SSL
• Encryption at rest — data stored within Supabase (AWS) is encrypted using AES-256
• Password hashing — passwords are hashed using bcrypt and are never stored in plain text
• Access controls — internal access to personal data is restricted to team members who require it
• Payment security — all card data is handled exclusively by Paystack. We do not receive or store raw card numbers or CVV codes.
• Staff PINs — hashed using PBKDF2 with a unique salt per PIN. They are never stored in plain text and are never displayed to anyone, including the business owner.
• Terminal identity — each POS terminal authenticates with a hardware-backed cryptographic key that never leaves the device. Paylo holds only the public half.
• Biometrics — Face ID and Touch ID checks in our apps are performed entirely on your device by Apple. Paylo never receives or stores biometric data.
• QR pairing — during terminal setup, the camera is used only to read the pairing code, processed on the device. No imagery is stored or uploaded.

Paylo is intended for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we become aware that we hold data belonging to a minor, we will delete it promptly. Contact us at legal@usepaylo.com if you believe we have inadvertently collected data from someone under 18.

Your data is stored on servers located in London, United Kingdom and West Europe (AWS infrastructure, provisioned via Supabase). Users in Nigeria should be aware that their data is transferred to and processed in these regions when they use the Platform.

By using Paylo, you consent to this transfer. We take steps to ensure that such transfers are carried out in accordance with applicable data protection standards.

Paylo is fully committed to compliance with the Nigeria Data Protection Regulation (NDPR) 2019 and the Nigeria Data Protection Act (NDPA) 2023.

You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data has been handled unlawfully. More information: ndpc.gov.ng

Our Data Protection Officer is reachable at legal@usepaylo.com.

We may update this policy periodically to reflect changes to our practices, technology, or legal obligations. Where changes are material, we will notify you by email, in-app notification, or a prominent notice on the Platform prior to the changes taking effect.

Your continued use of Paylo following notification of changes constitutes acceptance of the updated policy.

Greyline Innovations Limited

RC No. 9126295, Abuja, Nigeria

We aim to respond to all privacy-related enquiries within 30 days.