Privacy Policy

Last Updated:

1. Introduction

Welcome to Saly AI.

Saly AI is a financial technology platform operated by Saly App Nigeria Limited ("Saly", "we", "us", or "our").

Saly provides technology-enabled financial services and tools that may allow users to send and receive money, make payments, pay bills, manage financial activities, interact with financial services through artificial intelligence, and access other services made available through the Saly platform.

This Privacy Policy explains how we collect, use, disclose, store, protect and otherwise process personal information when you:

  • use Saly AI;

  • visit our websites;

  • create or maintain a Saly account;

  • make or receive transactions;

  • communicate with Saly;

  • use our APIs or other services;

  • interact with our AI systems; or

  • otherwise interact with us.

By using Saly, you acknowledge that you have read and understood this Privacy Policy.

2. Who We Are

Data Controller:

Saly App Nigeria Limited

Website: salypay.com

Email: privacy@salypay.com

Address: No. 2 Aliade CL. Garki 2, Abuja

Where required, Saly may work with third-party financial institutions, payment processors, identity-verification providers, technology providers and other service providers to deliver particular services.

Where another organisation determines how your personal data is processed, that organisation may have its own privacy policy and responsibilities.

3. Information We Collect

Depending on how you use Saly, we may collect the following categories of information.

A. Identity Information

This may include:

  • Full name

  • Date of birth

  • Nationality

  • Gender where required

  • Residential address

  • Government-issued identification

  • NIN or other identity information

  • BVN where applicable

  • Selfie/biometric verification information where required

  • Identification verification results

We collect this information where necessary for account creation, identity verification, fraud prevention, regulatory compliance and provision of financial services.

B. Contact Information

This may include:

  • Phone number

  • Email address

  • Address

  • Emergency/contact information where applicable

C. Financial Information

Depending on the services you use, we may process:

  • Bank account information

  • Account numbers

  • Wallet addresses

  • Transaction information

  • Payment information

  • Beneficiary information

  • Currency information

  • Payment history

  • Transaction references

  • Account balances

  • Card-related information where applicable

We do not intend to collect or store sensitive card authentication information such as your full PIN unless specifically required by a service and handled through an appropriately secured third-party provider.

4. Transaction Information

When you use Saly to make or receive a transaction, we may collect information including:

  • Amount

  • Currency

  • Sender

  • Recipient

  • Transaction type

  • Transaction reference

  • Date and time

  • Transaction status

  • Payment provider

  • Bank or financial institution involved

  • Related metadata

Transaction information may be retained where necessary to provide services, resolve disputes, detect fraud, meet legal obligations and maintain financial records.

5. Device and Technical Information

We may automatically collect information about the device you use to access Saly, including:

  • Device type

  • Operating system

  • Browser type

  • IP address

  • Device identifiers

  • App version

  • Network information

  • Language settings

  • Time zone

  • Crash reports

  • Diagnostic information

  • Log information

We use this information to secure, maintain and improve our services.

6. Location Information

Where you give us permission, Saly may collect approximate or precise location information.

Location information may be used for:

  • fraud prevention;

  • security;

  • service availability;

  • regulatory requirements;

  • improving user experience; and

  • providing location-dependent services.

You may disable location permissions through your device settings, although some features may not function correctly.

7. Information You Provide to Saly AI

Saly AI allows users to interact with financial services using natural language, including text, voice, images or other supported input methods.

Depending on the feature you use, these interactions may include:

  • payment instructions;

  • financial questions;

  • transaction requests;

  • uploaded images;

  • voice messages;

  • account-related requests;

  • beneficiary information; and

  • other information voluntarily provided by you.

We process these interactions to understand and execute your requests, provide responses, improve service reliability and protect against misuse.

Important

Saly AI is designed to assist with financial activities, but users remain responsible for reviewing transaction details before confirming transactions.

8. How We Use Your Information

We may process personal information for the following purposes:

Providing Services

To:

  • create and manage your account;

  • process payments;

  • process transfers;

  • provide financial services;

  • provide customer support;

  • process bills and other payments;

  • provide AI-powered functionality;

  • maintain transaction records.

Security and Fraud Prevention

To:

  • detect suspicious activity;

  • prevent fraud;

  • protect accounts;

  • investigate unauthorized transactions;

  • monitor system security;

  • prevent abuse.

Identity and Regulatory Compliance

To:

  • verify identity;

  • conduct KYC/AML checks where applicable;

  • comply with applicable laws;

  • respond to lawful requests from authorities;

  • maintain required financial records.

Product Improvement

We may use appropriately protected information to:

  • improve our services;

  • troubleshoot technical problems;

  • analyse product performance;

  • develop new features;

  • improve AI interactions;

  • improve fraud detection and security.

Where appropriate, we may use aggregated or de-identified information for analytics and product development.

9. Legal Bases for Processing

Depending on the circumstances, we may process personal information based on:

  • your consent;

  • performance of a contract;

  • compliance with legal obligations;

  • protection of your vital interests where applicable;

  • legitimate interests, where permitted by law; and

  • other lawful bases recognised under applicable data-protection law.

The NDP Act 2023 provides the framework governing personal-data processing in Nigeria.

10. Sharing Your Information

We may share information with carefully selected third parties where necessary to provide our services.

These may include:

Financial and Payment Partners

Such as:

  • banks;

  • payment processors;

  • payment gateways;

  • card providers;

  • settlement providers;

  • financial institutions.

Identity and Compliance Providers

Such as:

  • identity verification providers;

  • KYC providers;

  • AML screening providers;

  • fraud-prevention providers.

Technology Providers

Such as:

  • cloud infrastructure providers;

  • analytics providers;

  • communication providers;

  • cybersecurity providers;

  • customer-support platforms;

  • AI infrastructure providers.

Legal and Regulatory Authorities

We may disclose information where required by:

  • applicable law;

  • court order;

  • regulatory authority;

  • law-enforcement request; or

  • other lawful process.

We do not sell your personal information as a commodity.

11. International Data Transfers

Some of our technology or service providers may process information outside Nigeria.

Where personal information is transferred internationally, Saly will take appropriate measures required by applicable data-protection law to protect the information and ensure appropriate safeguards are in place.

12. Data Security

We use technical and organisational safeguards designed to protect personal information against:

  • unauthorised access;

  • accidental loss;

  • destruction;

  • alteration;

  • disclosure;

  • fraud; and

  • other unlawful processing.

Security measures may include:

  • encryption;

  • access controls;

  • authentication;

  • monitoring;

  • logging;

  • infrastructure security;

  • employee access controls;

  • vulnerability management; and

  • incident-response procedures.

However, no digital system can be guaranteed to be completely secure.

13. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including:

  • providing services;

  • maintaining financial records;

  • resolving disputes;

  • preventing fraud;

  • meeting legal and regulatory obligations;

  • enforcing agreements; and

  • protecting our legitimate business interests.

Different categories of information may have different retention periods.

Where information is no longer required, we will delete, anonymise or securely dispose of it where appropriate.

14. Your Data Protection Rights

Subject to applicable law, you may have rights including the right to:

  • request access to your personal information;

  • request correction of inaccurate information;

  • request deletion where legally applicable;

  • request restriction of processing;

  • object to certain processing;

  • withdraw consent where processing is based on consent;

  • request data portability where applicable;

  • object to certain automated decision-making; and

  • lodge a complaint concerning the processing of your personal information.

The NDPC itself describes rights including access, rectification, erasure, restriction, portability and objection in its data-subject request process.

To exercise your rights:

Email: privacy@salypay.com

We may need to verify your identity before processing certain requests.

15. Cookies and Similar Technologies

Our websites and applications may use cookies and similar technologies to:

  • maintain sessions;

  • remember preferences;

  • analyse usage;

  • improve performance;

  • detect security issues; and

  • understand how users interact with our services.

Where required, we will provide appropriate cookie controls.

16. Marketing Communications

Where permitted, we may send you information about:

  • new features;

  • product updates;

  • promotions;

  • events;

  • educational content.

You may unsubscribe from marketing communications at any time.

Transactional and security communications may continue where necessary to provide the service.

17. Children's Privacy

Saly is not intended for use by individuals who are legally unable to enter into the applicable financial services agreements.

We do not knowingly collect personal information from children in violation of applicable law.

If you believe a child has provided personal information to us improperly, contact:

privacy@salypay.com

18. Third-Party Services

Saly may contain links, integrations or connections to third-party services.

We are not responsible for the privacy practices of third parties.

You should review the privacy policies of those services before providing information to them.

19. Automated Processing and AI

Certain Saly features may use automated systems or artificial intelligence to:

  • understand user requests;

  • classify transactions;

  • provide recommendations;

  • detect suspicious behaviour;

  • personalise experiences;

  • improve customer support;

  • automate financial workflows.

Where automated processing produces a decision that has significant effects on you, we will provide applicable rights and safeguards required by law.

20. Data Breaches

If we become aware of a personal-data breach that requires notification under applicable law, we will take appropriate steps to investigate, contain and remediate the incident and make required notifications.

21. Changes to This Privacy Policy

We may update this Privacy Policy periodically.

When we make material changes, we may notify users through:

  • the Saly application;

  • email;

  • website notification; or

  • other appropriate communication channels.

The updated version will include a revised "Last Updated" date.

22. Contact Us

For privacy questions, requests or complaints:

Saly App Nigeria Limited

Email: privacy@salypay.com

Website: salypay.com

Address: No 2 Aliade CL. Garki 2, Abuja