Privacy Policy

Privacy Policy for Earlybaze

Effective Date: July 25, 2025 Last Updated: July 25, 2025

1. Introduction

Welcome to Earlybaze (“we,” “us,” “our”), the mobile application that provides a platform for buying, selling, sending, receiving, and swapping cryptocurrency (“Services”).

This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use our mobile application and Services. We are committed to protecting your privacy and handling your data in an open and transparent manner. This policy is designed to comply with the requirements of the Apple App Store, Google Play Store, and applicable data protection laws, including the Nigeria Data Protection Act (NDPA).

By downloading, accessing, or using the Earlybaze app, you agree to the terms of this Privacy Policy.

2. Information We Collect

To provide our Services and meet our legal obligations, we collect the following types of information:

a) Information You Provide Directly to Us:

  • Personal Identification Information: Your full name, date of birth, gender, home address, email address, and phone number.

  • Formal Identification Information: Government-issued identity documents (e.g., National ID card, International Passport, Driver’s License), Bank Verification Number (BVN), and/or other information required for our Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) obligations.

  • Financial Information: Bank account number, bank name, and other payment details you provide to fund your account or process withdrawals.

  • Account Information: Your username, password, and other security credentials used to access your Earlybaze account.

  • Communications: Information you provide when you contact our customer support team or respond to surveys.

b) Information We Collect Automatically:

  • Transaction Information: Details of transactions you carry out through our Services, including the type and amount of cryptocurrency bought, sold, or swapped, wallet addresses, and timestamps.

  • Device Information: Information about the mobile device you use to access our app, including the hardware model, operating system and version, unique device identifiers, and mobile network information.

  • Log and Usage Data: Information about your interaction with our Services, such as your IP address, app features you use, pages viewed, access times and dates, and app crashes.

  • Location Information: We may collect your approximate location from your IP address to ensure service availability and for security purposes.

3. How We Use Your Information

We use the information we collect for the following purposes:

  • To Provide and Maintain Our Services: To create and manage your account, process your transactions, and provide you with customer support.

  • For Security and Fraud Prevention: To verify your identity (KYC), protect against fraud, spam, and abuse, and enforce our User Agreement.

  • To Comply with Legal Obligations: To fulfill our legal and regulatory requirements, particularly for Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF).

  • To Improve Our Services: To analyze how users interact with our app, troubleshoot issues, and develop new features and products.

  • To Communicate With You: To send you important administrative information, technical notices, security alerts, and marketing communications (from which you can opt-out).

4. How We Share Your Information

We do not sell your personal information. We may share your information with third parties only in the following circumstances:

  • With Service Providers: We share information with third-party vendors and service providers who perform services on our behalf, such as cloud hosting (e.g., AWS), identity verification (KYC/AML providers), payment processing, and analytics.

  • With Financial Institutions: We share information with banking partners to process your Naira deposits and withdrawals.

  • For Legal Reasons and Law Enforcement: We may disclose your information to law enforcement, government authorities, or other third parties if required by law, subpoena, court order, or other legal processes.

  • In Case of a Business Transfer: If Earlybaze is involved in a merger, acquisition, or sale of all or a portion of its assets, your information may be transferred as part of that transaction.

  • With Your Consent: We may share your information for any other purpose with your explicit consent.

5. Data Security

We implement robust security measures designed to protect your information from loss, theft, misuse, and unauthorized access. These measures include:

  • Encryption of data in transit (using TLS/SSL) and at rest.

  • Multi-factor authentication (MFA) for your account.

  • Strict access controls within our organization.

  • Regular security audits and vulnerability scanning.

While we take significant steps to secure your data, no security system is impenetrable, and we cannot guarantee 100% security.

6. Data Retention

We will retain your personal information for as long as your account is active or as needed to provide you with our Services. We may also retain your information as necessary to comply with our legal obligations (e.g., retaining transaction records for AML purposes for a minimum of 5 years after the business relationship ends), resolve disputes, and enforce our agreements.

7. Your Rights and Choices

Under the NDPA and other applicable laws, you have certain rights regarding your personal data:

  • Right to Access: You can request a copy of the personal information we hold about you.

  • Right to Rectification: You can request that we correct any inaccurate or incomplete information.

  • Right to Erasure: You can request that we delete your personal information, subject to our legal retention obligations.

  • Right to Restrict Processing: You can request that we limit the way we use your personal data.

  • Right to Object: You can object to our processing of your personal data, particularly for marketing purposes.

To exercise any of these rights, please contact us at privacy@earlybaze.com.

8. Children’s Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child under 18, we will take steps to delete such information promptly.

9. International Data Transfers

Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ. We ensure that appropriate safeguards are in place for any such transfers.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the “Last Updated” date. We encourage you to review this Privacy Policy periodically.

11. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Email: privacy@earlybaze.com

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