This Privacy Policy explains what information Paylo collects about you, why we collect it, how we use it, and what rights you have over it. It applies to everyone who uses the Platform — customers who shop, merchants who sell, staff who work on a merchant's POS terminals, visitors to our website, and members of the public whose public social media activity is captured by our demand intelligence system.
By using Paylo, you agree to this policy. If you do not agree, please do not use the Platform.
This policy applies to five groups of people:
| Customers | People who browse, purchase products, or book services on Paylo |
| Merchants | Businesses and individuals who sell on the Paylo Business app |
| Staff | People a merchant adds to their team to work on the merchant's POS terminals, such as cashiers and stockkeepers |
| Visitors | People who visit usepaylo.com or contact support without a registered account |
| Social Users | Members of the public whose publicly posted social media content is captured by our demand intelligence system |
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:
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.
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.
When you create an account or use the Platform, we collect:
When you use the Platform, we automatically collect:
This section applies to people using the Paylo Marketplace app.
We collect your name, email address, and password — or your Google or Apple identity if you use SSO.
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.
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.
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.
We process this on the basis of our legitimate interest in charging sellers fairly under our contract with them.
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.
Payouts are not available until identity verification is complete. For this purpose, we collect:
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.
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.
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:
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.
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:
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.
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.
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.
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 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:
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.
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.
The following companies process personal data on our behalf:
| Partner | Purpose |
|---|---|
| Paystack | Payment processing and merchant payouts |
| Breet | Cryptocurrency payment processing and automatic conversion to Naira |
| Supabase (AWS) | Database infrastructure and file storage |
| Google Cloud Vision | AI-powered visual product search |
| Google Firebase | Android push notifications |
| Hostinger SMTP | Transactional email delivery |
| Meta Platforms | Social commerce — Instagram catalogue synchronisation for merchants who connect their Meta account (Meta acts as an independent data controller) |
We retain your data only for as long as necessary for the purpose it was collected, or as required by law.
| Data type | Retention period |
|---|---|
| Account personal data | Anonymised immediately on deletion; permanently deleted within 30 days |
| OTP codes | Auto-expire: 10-30 minutes |
| Order and transaction history | Minimum 7 years (tax and accounting) |
| Payment records | Indefinitely (regulatory compliance) |
| KYC documents | Minimum 5 years after account closure |
| In-app messages | 2 years |
| How you reached a store, before a first order | Expires after 90 days without an order |
| Customer–business record (whether Paylo introduced you) | While your account exists; anonymised when you delete your account. The fee recorded on each past order is kept with order history |
| Meta / Instagram connection data (access token, profile details) | Deleted immediately when you disconnect the integration, revoke access via Meta, or delete your account |
| Staff PIN hashes | Deleted when the PIN is cleared or the staff member is removed from the team |
| Staff and terminal records | Retained while active; marked removed or revoked thereafter and kept as part of the audit trail |
| Terminal audit logs (sign-ins, sales, PIN and device events) | Indefinitely (financial and security compliance) |
You have the following rights in relation to your personal information:
We will respond to all rights requests within 30 days. Contact us at legal@usepaylo.com or write to Greyline Innovations Limited, Abuja, Nigeria.
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
| General support | support@usepaylo.com |
| Legal & privacy | legal@usepaylo.com |
| Merchant support | partners@usepaylo.com |
| Data deletion | legal@usepaylo.com |
We aim to respond to all privacy-related enquiries within 30 days.
Paylo Privacy Policy — Greyline Innovations Limited. Version 2.6, September 28, 2026.